HARMONIZING GLOBAL AI GOVERNANCE: A COMPARATIVE STUDY OF CORPORATE COMPLIANCE FRAMEWORKS UNDER THE EU AI ACT V. EMERGING US AND ASIAN REGULATORY MECHANISMS

Artificial intelligence does not respect borders, but the law that governs it does. A single foundation model trained in California, fine-tuned in Bengaluru, and deployed to a hospital in Frankfurt now traverses at least four incompatible regulatory philosophies before it ever touches a patient. This paper examines the resulting fragmentation through the lens of the multinational firm that must actually comply. It juxtaposes the European Union’s rights-based, prescriptive architecture under Regulation (EU) 2024/1689, or the ‘AI Act,’ entered into force on 1 August 2024 and applies on a staggered schedule. Following the 2026 Digital Omnibus amendments, the transparency requirements under Article 50 apply from 2 August 2026, while the obligations for high-risk systems under Annex III apply from 2 December 2027 and those for high-risk AI embedded in regulated products under Annex I apply from 2 August 2028. The central argument is that “harmonization”, the reflexive policy aspiration of every international AI declaration since 2023, is largely a fiction at the level of binding obligation, and that convergence, where it exists, is occurring not through treaty or comity but through the extraterritorial gravity of the Brussels effect and the private ordering of technical standards. The paper concludes that the realistic near-term future is not a harmonized global regime but a stratified compliance market in which the most demanding jurisdiction sets the operational floor. For India specifically, this counsels neither imitation of Brussels nor abdication to Washington, but a calibrated interoperability strategy anchored in its existing digital public infrastructure.