AI businesses in Northern Ireland are set to face stricter regulations than those in the rest of the UK, according to legal experts in the field.
The European Commission has proposed adding the EU AI Act to the list of legislation that continues to apply in Northern Ireland post-Brexit. The final decision on whether to incorporate the law into Annex 2 of the Windsor Framework will be made by a joint EU-UK committee at its next meeting.
While the move is largely symbolic rather than commercially necessary—since any AI company in Northern Ireland intending to operate in the EU must already comply with the regulation—it has broader political and economic implications. This decision further integrates Northern Ireland into the EU’s legal framework in a rapidly evolving area of technology regulation. Although it helps prevent a hard border on the island of Ireland, it also increases the regulatory divide between Northern Ireland and the rest of the UK, which is pursuing a more relaxed approach to AI governance.
Over time, this divergence could reinforce a dual regulatory system, potentially affecting the cohesion of the UK’s internal market. AI companies in Belfast, for example, could find themselves at a disadvantage compared to those based in cities like Brighton, where they would operate under a different regulatory regime.
The EU AI Act, officially known as Regulation (EU) 2024/1689, came into force in August 2024 and is being implemented gradually over the next two years. It introduces a risk-based approach, where different AI systems are subject to varying levels of regulation depending on their potential risks.
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