This article examines the unprecedented extraterritorial reach of Regulation (EU) 2024/1689 on Artificial Intelligence (the EU AI Act) and the conflicts it generates with the national regulatory approaches of the United States, China, and the United Kingdom. It analyzes the Act’s jurisdictional bases (effects-based application; coverage of providers, users, importers, and distributors; and the obligation for non‑EU providers to appoint an authorized representative), and contrasts the EU’s precautionary, rights‑protective model with the U.S. innovation‑first, case‑by‑case oversight, China’s sovereignty‑ and control‑oriented regime, and the U.K.’s pro‑innovation incrementalism. The article maps practical compliance burdens and legal uncertainty for multinational firms, including conflicting obligations and market exit risks. It critically assesses the efficacy and limits of the authorized representative mechanism, and advances proposals to improve cross‑border enforceability and coherence: potential subsidiary liability (with insurance) for representatives, mutual recognition and enforcement arrangements, regulator networks, alignment via international technical standards and transparency infrastructures, and calibrated domestic harmonization for third countries. The conclusion argues for balanced multilateral coordination to mitigate regulatory fragmentation while safeguarding fundamental rights and enabling innovation.
| Mualliflar | Ergashev , Vosidjon, Эргашев, Восиджон, Ergashev, Vosidjon |
|---|---|
| Jurnal | Жамият ва инновациялар / Общество и инновации / Society and innovations |
| Nashr sanasi | 2025-07-15 |
| Jild | 6 |
| Son | 4 |
| Betlar | 383-395 |
| Til | Rus |
| DOI | 10.47689/2181-1415-vol6-iss4-pp383-395 |
DOI: 10.47689/2181-1415-vol6-iss4-pp383-395 · Maqolaning asl sahifasi
экстерриториальность, Закон ЕС об ИИ, коллизия законов, «эффект Брюсселя», международное частное право, комплаенс, уполномоченный представитель, глобальное регулирование ИИ, extraterritoriality, EU AI Act, conflicts of laws, Brussels Effect, private international law, compliance, authorized representative, global AI governance, eksterritoriallik, EU AI Act, kolliziya qoidalari, “Bryussel ta’siri”, xalqaro xususiy huquq, muvofiqlik (compliance), vakolatli vakil, global AI boshqaruvi
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Жамият ва инновациялар / Общество и инновации / Society and innovations — barcha maqolalar