Three-Jurisdiction Map: EU (Enforcement Live), US (State-Level Mosaic, Federal Absent), UK (Sector Guidance Only)

The three-jurisdiction picture this week is the sharpest divergence since the EU AI Act entered force in August 2024. EU: Article 50 obligations are live and fully operative as of August 2; the enforcement machinery (National Market Surveillance Authorities, AI Office, European Data Protection Supervisor) is active; three Member States (Netherlands, Germany, France) have meaningfully different national postures, with the Netherlands the most aggressive for legal sector surveillance. The classification dispute over whether lawyer-facing AI tools are limited-risk or high-risk has no definitive resolution — legal-sector actors are making classification decisions in an unresolved interpretive environment with significant penalty exposure (€15M or 3% of global turnover). US: no federal AI legislation; the state mosaic is thickening — Connecticut (CART Act, October 1, 2026), Ohio (AI ethics OCG template, July 30), Alabama (Formal Opinion 2026-01, August 4), Illinois (AI Act), Colorado (SB 205). The hallucination sanctions pattern is stabilizing at mandatory CLE + potential monetary sanctions. UK: voluntary compliance, sector guidance, no binding AI legislation; AI Copyright Transparency Bill and AI Safety Testing Framework in progress; malpractice insurers tracking US developments as cross-border reference points. The divergence map has practical consequences for any law firm or legal department operating across all three: EU disclosure obligations are binding now, US obligations are a state-level mosaic with no harmonized federal framework, and UK obligations are the most permissive but are being informed by US and EU developments. Firms that have built compliance architecture for EU Article 50 are best positioned for the US state-level disclosures that are converging toward the same structural requirements.