The fast-developing innovations brought by generative artificial intelligence (AI) are hastening calls from industry and government to consider new regulatory frameworks. The EU was in the process of implementing its AI Act, first proposed on April 21, 2021 (as we previously summarized), before generative AI chatbots were widely released. While the EU’s AI Act was touted as the world’s first and most comprehensive regulatory framework, some observed that it risked being outdated before it was set to become legally effective. Since the initial proposal, the European Commission (the Commission), the Council of the European Union, and the European Parliament have been working on modifying and refining the initial draft, including most recently to consider the implications of generative AI.

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