CHAPEL HILL, N.C. — At this week’s G20 innovation summit, the Trump administration drew a clear distinction between the United States’ and the European Union’s approaches to AI regulation. Still, the EU’s top technology official says the United States is ending up with many of the same guardrails, just through different mechanisms.
Why it matters
The U.S. is encouraging countries to avoid Europe’s sweeping regulatory style, but the debate has shifted to which guardrails advanced AI requires and how governments should implement them.
What they said
Henna Virkkunen, the European Commission’s tech chief, told Axios that both sides often address the same safety concerns even if U.S. safeguards are emerging through state laws, court cases and voluntary measures rather than a single, broad statute like the EU AI Act.
“We see when it comes to technologies that in the USA the culture is different. So often it's coming via court cases, but often very similar things anyway, very similar concerns,” Virkkunen said. “I don't see that this is so like black and white.”
She also noted that ChatGPT is subject to stricter obligations under the Digital Services Act, and stressed the importance for the EU of simplifying rules to make the region “easier, simpler, faster” for businesses.
U.S. actions and industry reactions
The United States has not enacted sweeping federal AI rules, but Washington is shaping how companies develop and deploy advanced models through executive actions, voluntary frameworks, national security restrictions and other policies. States are also moving forward with varying levels of AI regulation, and legal challenges are forcing product changes for companies.
Virkkunen said the EU is working on a blueprint for pre‑deployment testing and trusted partner access — another area where the EU and the U.S. are wrestling with similar policy questions.
“So in [the] European Union, we are also working for that blueprint, and we are continuing to discuss also under G7, especially with our partners, how we should work on this topic.”
The Trump administration has developed a voluntary framework to review some advanced AI models before release, which could include granting government reviewers access for up to 30 days. The White House does not plan to publicly release that framework.
OpenAI CEO Sam Altman confirmed this week to Axios that the administration reviewed OpenAI’s Astra model and emphasized the process is voluntary: “But we of course did it.”
Industry figures at the G20 innovation summit criticized the EU’s regulatory approach. In response to a question from Michael Kratsios, Director of the White House Office of Science and Technology Policy, SpaceX CEO Elon Musk argued for an approach that is “relatively free of regulation.”
“You have to have an environment that's relatively free of regulation, meaning that new things must be default legal as opposed to default illegal,” Musk said, adding that in his view EU regulation is “extraordinarily high” and tends to slow progress on new technologies.
Bottom line
As AI systems become more powerful, U.S. authorities are increasingly involved in overseeing model releases. While the EU pursues a more centralized, pre‑defined regulatory framework, the United States is seeing a patchwork of laws, court decisions and voluntary federal steps that nonetheless address many of the same safety concerns.
