America publishes its AI plan. The two regulatory worlds are now clearly apart
The White House released a 90-plus action plan on Wednesday, nine days before Europe’s next obligations bite. Swiss companies trade with both.
On 23 July 2025 the White House published « Winning the Race: America’s AI Action Plan », setting out more than ninety federal actions across three pillars: accelerating innovation, building infrastructure, and international diplomacy and security. Accompanying executive orders followed.
Nine days later, the EU’s general-purpose AI obligations take effect. The contrast is now about as sharp as it gets: one jurisdiction removing friction, another codifying duties, on the same calendar.
What this means for a Swiss company, concretely
Nothing directly, for the same reason as January: an American federal plan has never applied to you.
Two indirect effects are worth noting, and only two.
Your suppliers now face divergent requirements. A US model provider serving the EU market must produce documentation for Europe that American policy does not ask of them. They will produce it, because the EU market is large. But the documentation you receive is an EU artefact, and if a vendor tells you they do not have it because they are American, that answer is incomplete.
The divergence is now structural, not temporary. For three years it was reasonable to expect eventual convergence. This week makes that unlikely for the foreseeable future, which means a Swiss exporter should stop waiting for one answer and simply hold both.
The Swiss position between the two
Switzerland chose in February not to write its own AI act, signed the Council of Europe convention in March, and expects implementing law by end-2026. That is a third path: lighter than the EU, slower than both, and anchored in a human-rights instrument rather than a product-safety one.
For an SME this is a comfortable place to be. Your domestic obligations stay in the laws you already know, and your EU-facing activity follows the European calendar. One page covers both.
The practical note
Add one line to the page at the July review: which of your activity touches the EU market, and therefore which calendar applies to what.
Most SMEs can answer in a sentence. The ones that cannot have found something worth ten minutes, and it is better found now than in a procurement questionnaire.