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Free instrument

Same AI. Three jurisdictions.

Pick a case. One AI system, three legal realities. The board stamps what each regime does to the identical product: banned in one place, licensed in another, barely noticed in the third. Every verdict carries the instrument it comes from.

6 cases, 18 verdicts, VERIFIED 29 JUL 2026

The docket

Choose the system on trial

Six real deployment patterns, from CV screening to police face recognition. Arrow keys walk the docket.

Awaiting a case selection

EU vs US vs CN

European Union
Awaiting verdict
United States
Awaiting verdict
China
Awaiting verdict

6 cases, 18 verdicts. Each verdict is an editorial summary of the cited instruments, not legal advice. The official texts linked from every citation are always authoritative.

The full docket

Every verdict on the board, written out

All 18 verdicts across the 6 cases, each with the reasoning and the instrument it rests on. The board above is the fast way to read this; the text below is the whole of it.

Case 01: AI Hiring Tool

CV screening & candidate ranking

AI Hiring Tool: how does the European Union treat it?

HEAVILY REGULATED

High-risk by list position.

Recruitment and selection AI: targeted job ads, CV filtering, candidate evaluation, is Annex III high-risk: conformity assessment, human oversight, bias-controlled data governance, EU database registration. Obligations apply from 2 Dec 2027 (post-Omnibus).

Source: Annex III, point 4: AI Act: High-risk: employment & recruitment

The trapdoor: PROHIBITED

If the tool infers candidates' emotions, it's not regulated: it's prohibited.

Art. 5(1)(f) has been in force since Feb 2025: the ban applies today, not in 2027.

Source: Art. 5(1)(f): AI Act: Emotion-recognition ban

AI Hiring Tool: how does the United States treat it?

HEAVILY REGULATED

The most-regulated AI use case in America, without a federal AI law.

Title VII/ADA/ADEA disparate-impact liability stands (guidance withdrawn, statutes intact). NYC LL144 demands annual bias audits, Illinois AIVIA + HB 3773 cover interview and decision AI, Texas TRAIGA bans intentional discrimination, and Colorado's ADMT successor lands in 2027.

Source: Title VII: Civil Rights Act: disparate-impact liability; LL144: NYC Local Law 144: bias audits; AIVIA: Illinois AI Video Interview Act (820 ILCS 42); TRAIGA §552.056: Texas Responsible AI Governance Act

AI Hiring Tool: how does China treat it?

MOSTLY UNREGULATED

No dedicated employment-AI law.

Duties arrive sideways: PIPL Art. 24 grants explanation and refusal rights for automated decisions; public-facing platform features trigger CAC algorithm filing; Shanghai Art. 69 bars discriminatory conditions.

Source: PIPL Art. 24: PIPL: automated decision-making rights; S28: Fangda Partners: recruitment AI in China

The trapdoor

Foreign-hosted SaaS hiring tools typically can't pass the filing: they're quietly disabled or localized.

Case 02: LLM Chatbot

general-purpose customer service

LLM Chatbot: how does the United States treat it?

LIGHT-TOUCH

A plain service bot faces no AI-specific law.

Only FTC deception rules and state disclosure duties apply: California's SB 1001 bot law and Utah's on-request disclosure.

Source: FTC §5: FTC Act §5: deception rules; SB 243: California companion-chatbot law

The trapdoor

Companion chatbots are now specifically regulated (CA SB 243, NY) with a private right of action of at least $1,000/violation, and AI implying medical licensure is banned in California (AB 489).

Case 03: Medical Diagnostic AI

AI-driven diagnostic device

Medical Diagnostic AI: how does the European Union treat it?

HEAVILY REGULATED

Automatic high-risk via the device route.

AI needing third-party conformity assessment under the MDR/IVDR is automatically high-risk (Art. 6(1) + Annex I): one integrated CE/Notified-Body route. AI-Act application is deferred to 2 Aug 2028; the MDR itself fully applies today.

Source: Art. 6(1): AI Act: device-route high-risk; Reg. 2026/1744: Digital Omnibus on AI

Medical Diagnostic AI: how does China treat it?

LICENSED: FILING REQUIRED

NMPA device registration, typically Class III.

Pre-market registration, clinical validation and lifecycle oversight; the first AI diagnostic was approved in 2020, with 50+ deep-learning devices on the market by 2023.

Source: NMPA: NMPA medical device registration; S30: Chambers Healthcare AI 2025: China

The trapdoor

A hospital-facing GenAI chatbot additionally triggers a CAC GenAI filing: device registration alone isn't enough.

Case 04: Deepfake Generator

synthetic media tool

Deepfake Generator: how does the European Union treat it?

TRANSPARENCY DUTY

Label it, machine-readably.

Providers embed machine-readable marking (Art. 50(2)); deployers visibly disclose deepfakes (Art. 50(4)), with a relaxed disclosure mode for artistic and satirical works.

Source: Art. 50(2): AI Act: machine-readable marking; Art. 50(4): AI Act: deepfake disclosure

The trapdoor: PROHIBITED

From 2 Dec 2026, systems designed for non-consensual intimate imagery or CSAM become prohibited: a new Art. 5 category added by Reg. 2026/1744.

Source: Reg. 2026/1744: Digital Omnibus on AI

Deepfake Generator: how does the United States treat it?

LIGHT-TOUCH (TOOL) and PROHIBITED (OUTPUTS)

No law licenses the tool; liability hits the misuse.

The TAKE IT DOWN Act criminalizes nonconsensual intimate deepfakes and the FTC enforces 48-hour platform takedowns ($53,088/violation); ~20 states restrict election deepfakes; the FCC killed AI-voice robocalls; California watermarking starts 2 Aug 2026.

Source: Pub. L. 119-12: TAKE IT DOWN Act; FCC TCPA: FCC AI-voice robocall ruling

Case 05: Credit Scoring AI

automated creditworthiness

Credit Scoring AI: how does the United States treat it?

HEAVILY REGULATEDNARROWING

'The algorithm is too complex' is not a defense.

ECOA/Reg B demands specific, accurate denial reasons even after the CFPB withdrew its circulars in May 2025.

Source: ECOA/Reg B: ECOA / Regulation B: adverse-action reasons

The trapdoor

The Apr 2026 Reg B final rule (effective 21 Jul 2026) removes disparate-impact liability under ECOA: materially narrowing exposure.

Single-source: cited from compliance trackers quoting Federal Register notices.

Case 06: Police Live Facial Recognition

real-time biometric ID in public

Police Live Facial Recognition: how does the European Union treat it?

PROHIBITED

Banned, with three narrow exceptions.

Real-time remote biometric ID in public for law enforcement has been banned since Feb 2025: exceptions: missing/abduction victims, imminent terror or life threats, serious-crime suspects (≥4-yr, Annex II). Even then: prior judicial authorization, a FRIA, registration. Member states may ban entirely. Fines to €35M/7%.

Source: Art. 5(1)(h): AI Act: real-time biometric ID ban

Pattern spotlight

Three patterns worth remembering

The six cases are not six unrelated results. The same three habits produce every verdict on the board.

Context, not technology.

The EU bans emotion recognition in workplaces but asks only for a notice in shops, and roughly 85% of AI systems face no new duties at all.

The enforcer you did not expect.

America's deepest AI oversight comes from the FDA device regime and state attorneys general, not from any AI law.

Permission before launch.

China's filing system flips the order: review happens before market access, not after harm.

Knowing the verdict is step one. Passing the assessment is the job.

The board tells you which regime is strict about your system. The programs teach the work that follows: classification calls, conformity assessment, filings, documentation, and the judgment to defend every decision.