Japan’s parliament enacted Japan’s AI Promotion bill on Wednesday. Here’s a link to the bill and how it differs from the EU AI Act.

The EU Artificial Intelligence Act (Regulation (EU) 2024/1689) (available here and enacted on June 13, 2024) is a comprehensive (144 pages!) legal framework that applies directly across all EU member states. Its primary aim is to regulate the development, marketing, and use of AI systems in the EU to protect health, safety, and fundamental rights while fostering a unified internal market for AI technologies. In contrast, Japan’s Bill on Promoting Research, Development and Utilization of Artificial Intelligence-Related Technologies (available here – you’ll need to use translation to view it in English) is a national policy framework focused on advancing AI-related innovation as a cornerstone of economic development, social well-being, and international competitiveness. Unlike the EU’s regulatory approach, the Japanese bill emphasizes strategic planning, infrastructure investment, and multi-stakeholder collaboration. It’s much(!) shorter at only 7 pages when printed to PDF.

One of the most significant differences lies in their regulatory focus. The EU Act takes a risk-based approach, explicitly banning certain uses of AI such as social scoring by public authorities, emotion recognition in law enforcement, and manipulative techniques that can materially distort human behavior. It imposes strict compliance obligations on “high-risk” AI systems, including requirements for risk management, transparency, human oversight, and post-market monitoring. Meanwhile, Japan’s AI Promotion bill does not classify AI technologies by risk level nor impose bans but rather aims to promote responsible development and utilization by encouraging transparency, preventing misuse, and adhering to international norms.

Governance structures also differ notably. The EU’s regulation is enforced through a European Artificial Intelligence Board and national competent authorities, with a strong emphasis on regulatory oversight and market surveillance. Japan, on the other hand, establishes an Artificial Intelligence Strategy Headquarters within the Cabinet, led by the Prime Minister, to plan, coordinate, and implement policies in a top-down, centralized manner. This body is tasked with formulating a national AI Basic Plan, managing cross-ministerial coordination, and promoting cooperation between government, academia, and industry.

Regarding public sector use, the EU Act restricts the use of AI systems—particularly real-time biometric identification—in public spaces unless strict conditions are met. In contrast, Japan’s bill encourages the adoption of AI in national administrative agencies to increase operational efficiency. On international engagement, both documents stress cooperation, but the EU Act includes provisions that extend its applicability to foreign AI systems if they affect EU residents, whereas Japan’s bill emphasizes active participation in international standard-setting and scientific cooperation to ensure global leadership.

Finally, the two laws diverge in their treatment of infrastructure and talent development. The EU regulation addresses these areas only indirectly, primarily through innovation support mechanisms for SMEs and AI literacy initiatives. Japan’s bill, however, explicitly commits the government to investing in data infrastructure, supercomputing facilities, and educational programs to nurture a skilled AI workforce. While the EU Act is primarily about mitigating harm and enforcing standards, the Japanese bill is a blueprint for national mobilization and technological advancement.

Yes, I used ChatGPT to put together the comparison because who really has time to read 144 plus 7 pages? Want another comparison? Here is the comparison in table form (also created by ChatGPT). And here’s one from Fred Bingham in table form (hat tip to Donna Medrek for giving me the heads up on it!).

So, what do you think? Do you prefer the approach of Japan’s AI Promotion bill or the EU AI Act in regulating the use of AI? Please share any comments you might have or if you’d like to know more about a particular topic.

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