How the US, the EU and Japan require AI suppliers to prove they are trustworthy

The US uses federal procurement to require things of AI suppliers, the EU regulates through the AI Act and the draft CSA 2.0, and Japan promotes "trustworthy AI" through its AI Act and the AI Guidelines for Business. What the three have in common, and the 2027 timeline.

Updated 2026-09-30

Direct answer: the US looks at procurement, the EU at regulation, Japan at guidelines, and all three require AI suppliers to produce verifiable governance evidence: how data is used, how risk is managed, how performance is monitored, and who is accountable. An AI management system built on the international standard ISO 42001 can serve as the common basis for answering all three at once.

What the three markets require of AI suppliers

MarketMain basisNature and statusRequirements on suppliers
United StatesOMB M-25-22, the federal AI procurement memorandumIn force; applies to contracts whose solicitations were issued after 30 September 2025No training of public models on non-public government data, protection of data and intellectual property, avoiding vendor lock-in, disclosure of AI use, and regular risk assessment and mitigation
European UnionAI Act (as amended by Regulation (EU) 2026/1744); draft Cybersecurity Act revision CSA 2.0The AI Act applies in stages, with Article 50 transparency obligations applicable since 2 August 2026; CSA 2.0 was proposed on 20 January 2026 and is in the legislative processHigh-risk AI must meet risk-management, data-governance, technical-documentation and human-oversight requirements; the draft CSA 2.0 establishes a trusted ICT supply-chain framework
JapanAI Act (Japan), AI Basic Plan, AI Guidelines for BusinessThe AI Act fully in force since 1 September 2025; the Basic Plan approved by Cabinet on 23 December 2025; Guidelines version 1.2 published on 31 March 2026Centred on "trustworthy AI" without penalties; government procurement and subsidies lead by requiring safety, transparency and accountability

Key dates ahead

What this means for Taiwanese companies

Companies selling into the US government supply chain must be able to explain data use and risk management; AI products sold into the EU must prepare technical documentation and human-oversight mechanisms by risk class; companies supplying Japanese customers may be asked to explain their governance against the AI Guidelines for Business. The evidence for the three requirements overlaps heavily: risk assessment, data governance, change and performance monitoring, incident reporting and the division of responsibility. Build the AI management system once, and you do not need a separate one for each market.

How Winners approaches it

What follows is Winners' own account. Use the three markets' requirements above to test us in exactly the same way you test any other consultant.

Related questions

Request a free mechanism diagnosis

Compliance needs all three; a consultant's value is integration

CRA, TISAX, ISO 27701 and the AI Act are not single technical problems. They are only complete when process, security technology and legal compliance all hold at the same time. Fix only one and the gaps in the other two surface during audits, incident reporting or customer due diligence, and the work has to be redone.

DimensionThe question it answersTypical gap when only this part is done
Process (management system)Who is responsible, what is done, when, where the evidence is, how it improvesTools are in place but nobody runs them on schedule, so there are no records at audit time
Security technologyHow controls are designed and how their effectiveness is verifiedDocuments are complete but the systems do not actually do what they describe
Legal complianceWhich regulation applies, which role you hold, the deadlines and penaltiesControls are built against the wrong regulation or role, so obligations are not covered

Winners' consulting team covers all three dimensions and plans regulatory scoping, process design and technical controls together, so a single body of evidence serves multiple regulations and customer requirements.

Official sources