Regulating AI: Why the UK’s Caution May Outweigh the US’s Innovation-Driven Approach

With the extreme growth of Artificial Intelligence in the last decade or so, nations have responded to this sector in many ways. While both the UK and the US understand the capabilities and potential of AI, their approaches differ remarkably. The US prefers a more hands-off approach, prioritizing market freedom and promoting technological innovation. On the other hand, the UK has a more organized framework, laying out clear guidelines regarding AI development and usage and prioritizing ethics and human rights. Ultimately, the UK’s approach may be more sustainable for long-term AI development due to their balance of innovation with accountability and the confidence and security they supply to the consumer.

The United States’ approach has not only encouraged but also stimulated significant development, leading to breakthroughs in Artificial Intelligence. Healthcare is a good example of this as AI algorithms have significantly improved diagnostic accuracy. For example, Google Mind’s AI has been able to predict the progression of age-related macular degeneration (AMD) — a vision-reducing disease that is the most common cause of blindness in the developed world — to a more extreme version of AMD, equally or better than expert clinicians (“Using AI to Predict Retinal Disease Progression” 2020). Further, autonomous vehicles have seen significant progress with companies such as Tesla furthering safety and accessibility in self-driving technology. However, with these advancements, a number of ethical issues such as privacy concerns and potential biases in AI algorithms have risen.

Some argue that the approach of the US could create a path to unregulated AI applications. Michael J. Sandel, a political philosophy professor at Harvard, argues that “AI presents three major areas of ethical concern for society: privacy and surveillance, bias and discrimination, and perhaps the deepest, most difficult philosophical question of the era, the role of human judgment” (Pazzanese 2020). Incidents in the past regarding algorithms appearing to be biased in their hiring and facial recognition technology have raised questions about accountability and equality.

However, the UK’s framework for regulating artificial intelligence more greatly prioritizes ethics and transparency, which leads to increased public trust, an important part of ensuring the long-term success of Artificial Intelligence. The Center for Data Ethics and Innovation (CDEI) initiative demonstrates the importance of responsible and accountable AI use in the UK. The CDEI helps guide organizations to use AI in a productive way that still aligns with their moral codes while guiding policymakers to integrate ethics into AI development (“About Us,” n.d.). Thus, it ensures that the AI systems used by organizations both respect the rights and privacy of individuals and uphold societal values, improving public trust to ensure that AI can continue to develop and integrate more into society in the long term.

This cautious approach of the UK may hinder innovation and prevent technological advancement as argued by critics such as Cecilia Bonefeld-Dahl, the director general for DigitalEurope. “The new requirements — on top of other sweeping new laws like the Data Act — will take a lot of resources for companies to comply with, resources that will be spent on lawyers instead of the hiring of AI engineers,” she mentioned (“EU Agrees Landmark Rules on Artificial Intelligence,” n.d.). However, prioritizing ethics and public trust doesn’t necessarily need to stifle innovation. By taking care of the ethical concerns first, the UK will be able to ensure the longevity of AI. An example of the positive effect on innovation by regulation is seen in the financial sector. The Financial Conduct Authority (FCA) has implemented guidelines to ensure the ideals of transparency and accountability are utilized by AI systems in financial services which has led to increased consumer confidence and a more stable market (“Artificial Intelligence (AI) Update – Further to the Government’s Response to the AI White Paper” 2024). Ensuring that AI technologies are developed responsibly, securing long-term growth that aligns with societal and individual values is necessary to prevent pitfalls in the future that would decrease public trust. 

It is important to consider US efforts such as the AI Bill of Rights — legislation that provides a framework for the ethical use of AI in order to protect individual rights. This initiative reveals that the US is not entirely “hands-off” and is taking steps to address ethical concerns (The White House 2022). However, current US regulations are not enough. Taking inspiration from the UK and its initiatives, through the balance of innovation and oversight, the US would be able to continue to lead the advancement of AI while addressing concerns related to human rights and ethics.

To conclude, the US prefers a market-driven approach, prioritizing rapid AI innovation while the UK places more importance on public trust and ethical guidelines. Although the UK’s framework may be more restrictive, it encourages sustainable AI development and use by combining societal values with technological progress, ensuring the long-term progress of AI in the UK and promoting innovation and accountability.

Sources

“Using AI to Predict Retinal Disease Progression.” 2020. Google DeepMind. May 18, 2020. https://deepmind.google/discover/blog/using-ai-to-predict-retinal-disease-progression/.

Pazzanese, Christina. 2020. “Ethical Concerns Mount as AI Takes Bigger Decision-Making Role.” Harvard Gazette. Harvard University. October 26, 2020. https://news.harvard.edu/gazette/story/2020/10/ethical-concerns-mount-as-ai-takes-bigger-decision-making-role/.

The White House. 2022. “Blueprint for an AI Bill of Rights.” The White House. The White House. October 2022. https://www.whitehouse.gov/ostp/ai-bill-of-rights/.

“About Us.” n.d. GOV.UK. https://www.gov.uk/government/organisations/centre-for-data-ethics-and-innovation/about.

“EU Agrees Landmark Rules on Artificial Intelligence.” n.d. Www.ft.com. https://www.ft.com/content/d5bec462-d948-4437-aab1-e6505031a303.

“Artificial Intelligence (AI) Update – Further to the Government’s Response to the AI White Paper.” 2024. FCA. April 19, 2024. https://www.fca.org.uk/publications/corporate-documents/artificial-intelligence-ai-update-further-governments-response-ai-white-paper.

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