Mapping the Regulatory Learning Space for the EU AI Act

Lewis, Lasek-Markey, Golpayegani & Pandit (2025)

Source Summary

This paper argues that the EU AI Act should be understood primarily as a learning framework rather than a static regulatory instrument. Given the rapid pace of AI advancement and significant uncertainties in fundamental rights enforcement, the authors propose a structured approach to “regulatory learning” across multiple arenas where different actors interact.

Key Framing Insight

The framing itself is the transferable insight: complex technology regulation operating in fast-changing domains cannot be designed for static compliance. It must be designed for adaptation and collective learning across all participants, regulated parties, regulators, and affected stakeholders.

Core Arguments

1. The EU AI Act introduces two major sources of uncertainty:

   • Extension from health/safety protections to fundamental rights (which lack clear direct effect in private disputes)
   • Application of horizontal AI requirements through vertical sectoral enforcement mechanisms

2. These uncertainties, combined with rapid technological change, require systematic regulatory learning rather than static rule enforcement.

3. The Act already contains extensive learning mechanisms (sandboxes, post-market monitoring, delegated acts, periodic review) but these need coordination.

4. Effective learning depends on interoperable information exchange between actors, the semantic web standards approach offers a model.

Notable Concepts Introduced

• Regulatory Learning Space: A parametrized 3-axis framework (AI system types × protections × learning activities) for locating and coordinating learning efforts
• Learning Arenas: Spaces where different actor classes interact to apply and learn from implementation measures
• Meta-learning: Observing outcomes of learning activities to revise governance arrangements

Extractions Made

• 05-atom—regulatory-learning-definition
• 05-atom—learning-arenas-governance
• 05-atom—meta-learning-governance
• 05-atom—fundamental-rights-direct-effect-problem
• 05-atom—standards-development-representation-gap
• 05-atom—horizontal-vertical-regulation-tension
• 05-atom—learning-activities-taxonomy
• 05-molecule—regulatory-learning-space-framework
• 05-molecule—regulation-as-learning-framework
• 05-molecule—technology-pacing-problem