Sina Hoch, Daniel Mügge · Digital Society 2026 · 2026
DOI: 10.1007/s44206-026-00284-0
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When the European Union (EU) adopted its AI Act (AIA) in 2024, hopes were high that EU rules would diffuse globally through a “Brussels Effect.” We investigate how structural and contextual factors in the field of AI governance affect the likelihood and transformative potential of a Brussels Effect there. Because the AIA is still too young to allow a straightforward ex post analysis, we combine two inferential strategies: we compare AI as a governance challenge to other cases of successful EU rule export, identifying conditions that promote or obstruct global EU rule export. And we empirically canvas the rule-setting dynamics that have emerged since the AIA’s first legislative draft in 2021. Against the initially optimistic tenor of Brussels policy discourse from the time of the AIA’s adoption, we advance four reasons to be skeptical of big EU influence: first, the EU’s regulatory capacity is constrained by informational disadvantages, reliance on external standard-setters, and enforcement delays. Second, competitive pressures have led to pre-emptive concessions, watering down EU rules before they could travel. Third, the relative vagueness of EU rules means that de factor harmonization of rules and practices across borders remains shallow at best. Fourth, rule diffusion in AI is above all meaningful when it reaches countries that themselves are leading AI powers, notably the United States and China, and it is precisely there that EU influence seems negligible so far.
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