November 6, 2025
The European Union’s Artificial Intelligence Act (referred to here as the EU AI Act or the Act), which took effect on August 1, 2024, represents the world’s first comprehensive regulatory framework for AI. The EU AI Act takes a risk-based approach that categorizes AI systems based on their potential risks to health, safety, and fundamental rights. The Act is applicable to all players in the AI ecosystem, from developers to exporters to deployers. It not only regulates AI systems (i.e., products and services that are powered by AI) according to their design or model, but also based on the user and uses of those systems, and is particularly focused on those uses that are likely to produce the highest risks.
Like other EU regulatory efforts before it, such as the General Data Protection Regulation, the EU AI Act will impact industries and educational collaborations beyond the EU’s borders. That includes higher education institutions based in New York State and in the United States more broadly that have existing research or programmatic collaborations with EU-based institutions.
As the first compliance deadlines start in the summer of 2026, many higher-education institutions (HEIs) may still be working to grasp the full breadth of the EU AI Act. A clear understanding of the Act’s classifications, documentation standards, and interconnected data governance obligations is, however, essential to protect the integrity of ongoing and future collaborations with EU-based education institutions.
Building on this need, this policy brief analyzes the EU AI Act’s key provisions and evaluates their impact on New York higher education institutions, with attention to compliance obligations, cross-border data sharing, accreditation processes, and institutional accountability. By analyzing the first set of the 2025 regulatory changes, New York HEIs can strengthen their readiness, maintain the viability of transatlantic partnerships, and operate within evolving legal frameworks.
