Artificial intelligence is subject to different regulations in Northern Ireland and Great Britain as a brand new EU law comes into force step by step from next month, just because the UK looks to step up its global AI ambitions.
With the United Kingdom leaving the EU, Northern Ireland continued to have access to the bloc's goods market and is subject to some EU laws. It established a politically sensitive customs border within the Irish Sea, which can now extend to some digital operations under the EU AI law.
The latest example of post-Brexit regulatory divergence is the differences between the UK and EU over permissible levels of arsenic in baby food and font size on chemical products. The British government announced a significant investment in its AI capabilities on Monday.
Just about 1 percent of UK AI firms are based in Northern Ireland, however the region has dynamic software, fintech, healthcare and digital services industries that use AI of their products or operations and will be subject to latest EU law.
“I don't think people have really realized that the digital border goes to matter,” said Steve Aiken, a senior member of the Ulster Unionist Party, which like other pro-British parties opposes a customs border within the Irish Sea, which was created by Brexit.
“We can’t be in a situation where, for instance, the UK is more aligned with the United States (on AI regulation) and Northern Ireland is stuck within the EU,” he said. Some “back office” functions for City of London firms are based in Belfast, he added.
British Prime Minister Sir Keir Starmer, keen to enhance relations with the EU while maintaining strong trade ties with the US under latest President Donald Trump, wrote within the Financial Times on Monday: “We don’t need to focus on the US or.” an EU path to AI regulation – we will go our own way and take a typically British approach.”
The government has revealed plans to construct a brand new supercomputer and spend money on a 20-fold increase within the UK's sovereign computing power.
British officials weren’t immediately available to comment on the prospect of regulatory divergence because the EU AI law comes into force step by step from February 2. Experts said the complete scope in Northern Ireland was unclear.
But Ryan Donnelly, co-founder of Enzai, a Belfast-based AI governance platform that advises Fortune 500 firms in healthcare, financial services, telecommunications, infrastructure and other sectors, said Northern Ireland might be “once more within the crisis zone.” be.
The regulatory divergence between Great Britain and Northern Ireland might be “messy”. . . and chaotic is just not very attractive to international AI firms,” he added.
“The government is committed to making sure the UK stays a number one AI nation and Northern Ireland will profit from our plan to harness the economic growth that AI will bring,” a government spokesperson said, declaring that “significant “Provisions” of the EU AI Act would only apply within the region following an agreement within the Joint Committee on the EU-UK Withdrawal Agreement.
Unionist politicians last month activated for the primary time a Brexit mechanism – the so-called Stormont brake – designed to permit them to lodge a proper objection to the applying of updated EU law within the region.
The British government is currently considering its objections to changes to an EU law governing the font used on chemical product labels, which it says could force costly relabeling.
But Barry Scannell, partner and AI specialist at law firm William Fry in Dublin, expected the EU AI law to have little impact on firms already exporting to the EU.
“I doubt compliance with latest regulations related to AI can be the straw that breaks the camel’s back because Northern Ireland is such a very good place to work on AI – the advantages outweigh the extra bureaucracy,” he said.
