EU · binding regulation
EU AI Act
EU-AIA-2024
Comparative jurisdictional memo · Agentic AI Governance
EU-AIA-2024 — coverage across 24 topics
Color = verdict, height = confidence. One tick per topic.
CN-GENAI-2023 — coverage across 24 topics
Color = verdict, height = confidence. One tick per topic.
EU · binding regulation
EU-AIA-2024
CN · binding regulation
CN-GENAI-2023
15 of 24 topics differ; 9 agree.
On the topic of Agentic AI Governance, EU AI Act is classified as implicit and Interim Measures for Generative AI Service Management as implicit. The editorial verdict is converges. The two regimes take the same position; this is a candidate for cross-jurisdictional alignment in industry guidance, voluntary codes, and harmonisation tracks.
Contested question: Should governance attach to the AGENT (multi-step actions, tool use, recursion) or to the model that powers it? Capability-tier vs action-tier frames are unresolved across jurisdictions.