The Bridge Jurisdiction Opportunity: UK AI Governance Positioning

ISAR Global Strategic Intelligence Brief
December 12, 2025

Executive Summary

The United Kingdom faces a critical junction in AI governance strategy. Recent policy announcements signal explicit alignment with US light-touch approaches, yet Britain’s unique institutional positioning across European, American, and Commonwealth governance spheres creates distinctive coordination opportunities that no other jurisdiction can replicate.

This intelligence brief examines whether current UK drift towards exclusive US alignment represents deliberate strategic choice or missed opportunity for systematic multi-framework coordination—a “Bridge Jurisdiction” positioning that evidence from Singapore’s governance initiatives suggests could deliver substantial compliance efficiency gains.

Key Finding: Singapore’s October 2023 framework interoperability work with the United States demonstrates that technical coordination between divergent governance philosophies is achievable without surrendering regulatory sovereignty. The question facing UK policymakers is whether similar systematic coordination across three governance spheres—EU, US, and Commonwealth—merits active pursuit within a diminishing implementation window.

The Evidence Base: What Singapore Actually Achieved

The October 2023 Singapore-US Framework Crosswalk

On 13 October 2023, Singapore’s Infocomm Media Development Authority (IMDA) and the United States National Institute of Standards and Technology (NIST) published a framework “crosswalk”—a detailed mapping document demonstrating how Singapore’s AI Verify testing framework aligns with the NIST AI Risk Management Framework.[1][2]

What This Achieved:

The crosswalk maps AI Verify’s testable criteria and processes to the NIST AI RMF’s categories within the Govern, Map, Measure, and Manage functions. This technical alignment enables organisations using AI Verify to simultaneously meet requirements of both frameworks, reducing duplicative compliance work.[3]

According to analysis by the Future of Privacy Forum, this crosswalk initiative aims to “harmonise international AI governance frameworks to reduce fragmentation, facilitate ease of adoption, and reduce industry costs in meeting multiple requirements.”[4] NIST has developed similar crosswalks with other frameworks including the EU AI Act, OECD Recommendation on AI, and Executive Order 13960.[5]

Critical Distinction: This represents technical interoperability between two voluntary frameworks rather than binding regulatory harmonisation. Singapore retained complete regulatory independence whilst demonstrating that systematic coordination between different governance approaches is methodologically feasible.[6]

Singapore’s Broader Framework Development

Singapore’s governance work has continued systematically:

January 2024: Proposed Model AI Governance Framework for Generative AI at Davos[7]
May 2024: Finalised Generative AI framework through AI Verify Foundation[8]
Throughout 2024-2025: Continued alignment work, including mapping AI Verify Framework to ISO/IEC 42001:2023[9]

Singapore’s approach demonstrates that jurisdictions pursuing innovation-focused governance can still engage in systematic international coordination without adopting prescriptive regulation.[10]

UK’s Current Trajectory: Explicit US Alignment

January-February 2025 Policy Announcements

The UK Government’s direction has crystallised through several key announcements:

January 2025 – AI Opportunities Action Plan
The UK launched its “AI Opportunities Action Plan” emphasising economic benefits and global leadership ambitions whilst notably de-emphasising security and ethical considerations.[11] The plan structures around three pillars: infrastructure investment, public sector adoption, and supporting homegrown AI development.[12]

February 2025 – UK-US Economic Agreement
During a joint press conference on 27 February 2025, Prime Minister Keir Starmer and US President Donald Trump announced an economic agreement focused on AI and advanced technologies. Starmer explicitly stated: “Instead of over-regulating these new technologies, we’re seizing the opportunities they offer.”[13]

This represented formal UK commitment to alignment with US voluntary standards approach over prescriptive regulation.[14]

February 2025 – AI Safety Institute Rebrand
The UK rebranded its AI Safety Institute to the “AI Security Institute,” signalling a governance shift toward addressing serious AI risks with security implications rather than broader safety considerations.[15]

UK’s Pro-Innovation Regulatory Model

The UK’s current approach, articulated in the March 2023 white paper “A Pro-Innovation Approach to AI Regulation,” establishes five principles:[16]

Safety, security and robustness
Transparency
Fairness
Accountability and governance
Contestability and redress

Critically, the UK has not created a dedicated AI regulator. Instead, existing regulators (ICO, Ofcom, FCA) implement these principles within their sectoral domains using existing powers.[17] This distributed model prioritises flexibility and adaptability over comprehensive legislative frameworks.[18]

Delayed AI Legislation

An AI Bill was announced in July 2024 but has been deliberately delayed. Government sources indicate the delay stems from desires to align AI regulation with the US and respond to creative sector concerns about copyright issues.[19] Any comprehensive AI Bill is not expected before the second half of 2026.[20]

The Bridge Jurisdiction Concept: Evidence-Based Assessment

What “Bridge Jurisdiction” Actually Means

The bridge jurisdiction concept involves systematic technical coordination between divergent governance frameworks without requiring philosophical alignment or sovereignty surrender. Singapore’s work provides the methodological template.

Technical Coordination Components:

Compatible documentation standards
Aligned risk assessment methodologies
Coordinated conformity assessment processes
Mutual recognition of technical compliance measures

Critical Distinction: This is not regulatory harmonisation requiring identical rules. Rather, it reduces compliance friction through process interoperability whilst maintaining independent regulatory approaches.[21]

UK’s Unique Positioning

Britain possesses positioning literally no other jurisdiction can replicate:

European Sphere

Historical regulatory alignment through EU membership
Ongoing trade relationships requiring compliance awareness
UK businesses operating across EU markets
Council of Europe AI Convention signatory (September 2024)[22]

United States Sphere

“Special relationship” and February 2025 economic agreement
February 2025 explicit policy alignment announcements
Shared approach favouring innovation over prescription
Extensive transatlantic business operations

Commonwealth Network

56 nations spanning multiple governance approaches
2.5 billion people across diverse AI markets
No systematic AI governance coordination mechanism
UK institutional capacity for leadership

No other jurisdiction spans these three governance spheres with equivalent institutional relationships and capacity.[23]

The Implementation Reality Check

What Would Bridge Positioning Actually Require?

Based on Singapore’s methodological approach, UK bridge positioning would need:

Technical Working Groups conducting systematic framework mapping across EU AI Act, US NIST AI RMF, and emerging Commonwealth approaches
Parliamentary/Ministerial Champion with sustained political commitment beyond election cycles
Resource Allocation for cross-framework coordination work (estimated £3-5 million over 18-24 months based on similar initiatives)
Bilateral Engagement with EU Commission, NIST, and Commonwealth governance bodies to establish coordination appetite
Industry Consultation to validate that compliance burden reduction justifies coordination investment

Critical Question: Given explicit UK-US alignment statements, would European partners engage with UK-led coordination efforts, or has February 2025’s transatlantic commitment foreclosed this positioning option?

The Counter-Evidence: Why Bridge Positioning May No Longer Be Viable

UK-EU Relations Post-Brexit

The UK’s regulatory alignment with the EU has been deliberately unwinding since Brexit completion. The February 2025 Starmer-Trump announcement positioning the UK explicitly alongside US approaches may have created insurmountable trust barriers for serious EU coordination.[24]

The EU AI Act entered full force in 2024, with prohibitions and AI literacy requirements active from February 2025 and General-Purpose AI obligations commencing August 2025.[25] The EU has developed its own coordination mechanisms, including the General-Purpose AI Code of Practice (July 2025), which some major providers like Meta have refused to sign whilst others like Google have committed.[26]

Reality Check: Would the European Commission invest in UK-led coordination when Britain has explicitly aligned with a competing governance philosophy?

Commonwealth Governance Diversity

Commonwealth nations represent extraordinarily diverse approaches to AI governance:

Canada developing comprehensive legislation (AIDA in Bill C-27)
Australia pursuing sectoral regulation
India adopting voluntary guidelines (announced November 2025)[27]
African Commonwealth nations at early framework development stages
Caribbean states with limited AI governance capacity

This diversity creates coordination complexity that may exceed the technical interoperability model Singapore demonstrated with a single bilateral partner (US).

Reality Check: Is a 56-nation coordination mechanism realistic when established multilateral bodies (UN, OECD, GPAI) struggle with similar complexity?

US Regulatory Trajectory

The United States unveiled its AI Action Plan in July 2025, signalling explicit deregulation and global competitiveness focus.[28] This represents active policy divergence from EU approaches rather than convergence.

With over 500 AI bills proposed at US state level in Q1 2025 alone, American governance remains fragmented and reactive.[29] The February 2025 UK-US alignment commits Britain to this voluntary standards approach.

Reality Check: If the UK is explicitly aligned with US light-touch approaches, what independent “bridge” role remains available?

The Infrastructure Sovereignty Dimension: When Strategic Principles Meet Dependencies

The bridge jurisdiction positioning assumes regulatory harmonisation represents the primary strategic consideration in AI governance coordination. However, the November 2025 US National Security Strategy articulates principles that expose a systematic contradiction in UK’s current trajectory—one that regulatory frameworks cannot address and which exclusive alignment inadvertently compounds.

The Hamilton Principle: US Strategic Doctrine on Infrastructure Independence

The US National Security Strategy establishes infrastructure independence as foundational doctrine:

“As Alexander Hamilton argued in our republic’s earliest days, the United States must never be dependent on any outside power for core components—from raw materials to parts to finished products—necessary to the nation’s defence or economy.”[35]

This principle operates alongside explicit commitment to technology standards dominance: “We want to ensure that U.S. technology and U.S. standards—particularly in AI, biotech, and quantum computing—drive the world forward.”[36]

The strategic architecture is coherent: establish standards leadership whilst maintaining infrastructure independence from external dependencies. The NSS dedicates extensive analysis to preventing foreign infrastructure control in the Western Hemisphere, emphasising sovereignty protection and pushing out foreign control of “strategically vital assets.”[37]

The United States isn’t being hypocritical—it’s being strategically consistent. The question becomes: what does UK alignment with this framework represent when demonstrating the opposite infrastructure posture?

UK Reality: Dependencies the NSS Identifies as Strategic Vulnerability

On 20 October 2025, AWS outage affecting the US-EAST-1 region in Northern Virginia disabled Lloyds Bank and Halifax online banking services for over seven hours.[38] This incident demonstrates precisely the vulnerability the NSS identifies: infrastructure concentration creating operational exposure through jurisdictional dependencies.

The concentration extends systematically. Major UK government services, financial institutions, and digital infrastructure depend on hyperscale cloud providers whose primary data centres operate under US jurisdiction. The CLOUD Act grants US authorities access to data controlled by US companies regardless of storage location,[39] creating the jurisdictional exposure that the NSS explicitly warns undermines sovereignty: “preventing its erosion by… attempts by foreign powers or entities to… involve us in foreign conflicts.”[40]

Except in this case, UK is the foreign power experiencing erosion—through voluntary infrastructure dependencies on systems operating under US legal jurisdiction.

Scale Asymmetries Reveal Strategic Position Reality

Infrastructure dimension demonstrates systematic scale disparities that regulatory alignment cannot bridge:

OpenAI’s Stargate facility (Norway): 100,000 GPUs allocated[41]
UK North East AI Development Zone: 8,000-31,000 GPUs planned[42]

These 10x-12x scale asymmetries exist independently of regulatory harmonisation. The NSS explicitly discusses burden-sharing and ensuring allies “contribute far more to our collective defence” whilst warning against “offload[ing] the cost of their defence onto the American people.”[43]

How does a government demonstrating order-of-magnitude infrastructure disadvantage negotiate framework terms as coordination “equals”—particularly when the partner has explicitly articulated technology standards dominance as core national security strategy?

Governance Arbitrage: The Framework Layer Cannot Address Infrastructure Reality

The NSS prioritises sovereignty protection: “The United States will unapologetically protect our own sovereignty. This includes preventing its erosion by transnational and international organisations.”[44] Yet infrastructure providers systematically leverage jurisdictional complexity that exclusive bilateral frameworks cannot resolve:

UK data protection regulations govern data handling within UK jurisdiction
CLOUD Act grants US authorities access to UK citizen data through US corporate control
No UK-US framework addresses this jurisdictional contradiction[45]
NSS explicitly identifies such arrangements as sovereignty erosion when applied to US

Infrastructure providers benefit from regulatory arbitrage opportunities. They operate in the space between governance frameworks—precisely where the NSS warns against erosion of sovereignty through external control of critical infrastructure.

The Bridge Jurisdiction Paradox: Authority Requires Demonstration

Here lies the sharp analytical point: UK is aligning with the governance framework of a nation that has articulated infrastructure independence as Hamilton-level foundational principle… whilst demonstrating precisely the dependency that framework identifies as antithetical to sovereignty.

The bridge jurisdiction concept assumes UK can credibly convene Commonwealth coordination mechanisms whilst demonstrating leadership in multi-jurisdictional framework navigation. But the credibility requirement extends beyond regulatory competence to demonstrated infrastructure authority.

How can a government lead coordination for infrastructure sovereignty when its own critical systems depend on foreign-controlled infrastructure operating under foreign legal jurisdiction? How does one advocate for the Hamilton Principle whilst demonstrating its opposite?

The NSS answers this implicitly: you don’t. Infrastructure independence isn’t an optional consideration—it’s foundational to credible sovereignty. Which means UK’s current trajectory isn’t bridge jurisdiction positioning. It’s alignment with one side’s framework whilst accepting systematic dependencies that framework explicitly warns against.

The United States has strategy. UK appears to have drift.

Alternative Interpretation: Drift Versus Strategic Choice

The Default Trajectory

Current UK positioning suggests drift towards exclusive US alignment rather than deliberate strategic decision. Key indicators:

January 2025 Action Plan emphasising innovation without proportionate governance attention
February 2025 US Agreement committing to light-touch approach
AI Bill Delay explicitly linked to US alignment desires
Minimal EU Coordination since Brexit completion

This trajectory occurs through accumulated small decisions rather than comprehensive strategic assessment of positioning options.

The Strategic Alternative

A deliberate bridge jurisdiction strategy would require:

Different Policy Announcements: Rather than February 2025’s explicit US alignment, announcing UK commitment to systematic coordination across multiple frameworks whilst maintaining innovation focus

Active EU Engagement: Formal discussions with EU Commission about technical coordination mechanisms despite Brexit, leveraging shared interest in reducing business compliance burden

Commonwealth Leadership Initiative: Convening systematic Commonwealth AI Governance Forum with concrete deliverables rather than rhetorical commitment

Resource Commitment: Budgetary allocation for framework coordination work demonstrating governmental seriousness

None of these elements are present in current UK positioning, suggesting bridge jurisdiction remains theoretical rather than active policy consideration.

Current Landscape: December 2025

Global AI Governance Developments

European Union
The EU AI Act continues phased implementation. February 2025 saw prohibitions and AI literacy requirements activate. August 2025 brought General-Purpose AI obligations. The July 2025 GPAI Code of Practice provides voluntary compliance pathway, though adoption remains contentious amongst major providers.[30]

United States
Fragmentary state-level activity continues with 500+ bills in Q1 2025. Federal policy emphasises voluntary standards and innovation enablement. The February 2025 UK-US agreement reinforces transatlantic coordination on light-touch approaches.[31]

United Kingdom
Pro-innovation stance maintained through distributed regulatory model. No dedicated AI regulator created. AI Bill delayed until 2026 at earliest. February 2025 US alignment represents clearest strategic direction statement to date.[32]

Commonwealth
No systematic AI governance coordination mechanism. Individual nations pursuing diverse approaches from comprehensive legislation (Canada) to voluntary guidelines (India). UK leadership opportunity exists but remains unrealised.[33]

International Treaties
The Council of Europe AI Convention (September 2024) represents first legally binding international AI treaty. UK signatory alongside multiple European and non-European nations, suggesting some appetite for multilateral coordination.[34]

The Bridge Jurisdiction Question Today

Given February 2025’s explicit UK-US alignment, the bridge jurisdiction concept faces fundamental viability questions:

Has the positioning window already closed?
UK’s public commitment to US approaches may have foreclosed European coordination trust necessary for bridge role.

Was there ever institutional appetite?
The absence of bridge-related policy discussion in UK government publications suggests the concept never gained internal traction.

Does compliance burden reduction justify coordination investment?
Without empirical evidence of actual efficiency gains (Singapore’s work demonstrates feasibility, not quantified outcomes), business case remains speculative.

Strategic Assessment

The Evidence Supports Limited Conclusions

What We Know With Confidence:

Singapore demonstrated technical framework interoperability is methodologically achievable (October 2023 crosswalk with NIST)
UK possesses unique institutional positioning across three governance spheres that no other jurisdiction replicates
UK government has explicitly aligned with US light-touch approaches (February 2025)
No active UK policy work on systematic multi-framework coordination is visible in public statements
Commonwealth AI governance remains fragmented without coordination mechanism

What Remains Uncertain:

Whether European partners would engage with UK-led coordination after February 2025 US alignment
Actual compliance burden reduction achievable through technical coordination (Singapore demonstrated feasibility; quantified benefits unclear)
Whether 56-nation Commonwealth coordination is realistic given governance diversity
If bridge positioning ever had serious internal UK government consideration

Three Plausible Scenarios

Scenario 1: Current Drift Continues (Most Likely)
UK maintains explicit US alignment. No systematic EU coordination develops. Commonwealth governance remains uncoordinated. British businesses manage multi-jurisdictional compliance through normal commercial processes. Bridge jurisdiction remains theoretical concept without policy traction.

Scenario 2: Deliberate US-Commonwealth Coordination (Possible)
UK leverages February 2025 US agreement to develop systematic Commonwealth coordination following light-touch principles. This creates Commonwealth governance cohesion aligned with US approaches but remains separate from EU frameworks. Bridge positioning fails but Commonwealth leadership succeeds.

Scenario 3: Post-2026 Policy Reassessment (Unlikely But Possible)
If delayed AI Bill (expected 2026+) reveals substantial business concerns about multi-jurisdictional compliance burden, UK government reassesses coordination strategy. This would require evidence that current drift creates measurable economic disadvantage justifying coordination investment.

What Would Change This Assessment?

Indicators Bridge Positioning Gaining Traction:

UK government announces systematic framework coordination initiative
DSIT allocates specific budget for multi-framework coordination work
Formal dialogues commence with EU Commission on technical coordination
Commonwealth AI Governance Forum convened with concrete deliverables
Industry stakeholders publicly advocate for coordination mechanisms

None of these indicators are currently visible.

References and Citations

[1] Future of Privacy Forum. (2023, October). “Explaining the Crosswalk Between Singapore’s AI Verify Testing Framework and The U.S. NIST AI Risk Management Framework.” Available at: https://fpf.org/blog/explaining-the-crosswalk-between-singapores-ai-verify-testing-framework-and-the-u-s-nist-ai-risk-management-framework/

[2] IMDA Singapore. (2023, October 13). Singapore-US Crosswalk Publication. Referenced in multiple governance analyses.

[3] IMDA Singapore. (2024, January). “Model AI Governance Framework for Generative AI.” Available at: https://www.imda.gov.sg/resources/press-releases-factsheets-and-speeches/factsheets/2024/gen-ai-and-digital-foss-ai-governance-playbook

[4] Future of Privacy Forum. (2023). Framework interoperability analysis.

[5] Future of Privacy Forum. (2022). “AI Verify: Singapore’s AI Governance Testing Initiative Explained.” Available at: https://fpf.org/blog/ai-verify-singapores-ai-governance-testing-initiative-explained/

[6] Global Legal Insights. (2025). “AI, Machine Learning & Big Data Laws 2025 | Singapore.” Available at: https://www.globallegalinsights.com/practice-areas/ai-machine-learning-and-big-data-laws-and-regulations/singapore/

[7] IMDA Singapore. (2024, January). Davos announcement of Generative AI Framework.

[8] ValidMind. (2024). “A Walk into Singapore’s Vision for the Future of AI.” Available at: https://validmind.com/blog/a-walk-into-singapores-vision-for-the-future-of-ai/

[9] AI Verify Foundation. (2024). “Resources – AI Verify Foundation.” Available at: https://aiverifyfoundation.sg/resources/

[10] IAPP. (2025). “Global AI Governance Law and Policy: Singapore.” Available at: https://iapp.org/resources/article/global-ai-governance-singapore/

[11] InfoSecurity Europe. (2025). “The UK’s AI Strategy: Balancing Economic Potential with Security Risks.” Available at: https://www.infosecurityeurope.com/en-gb/blog/regulation-and-policy/reviewing-uk-ai-regulation.html

[12] IAPP. (2025). “Global AI Governance Law and Policy: United Kingdom.” Available at: https://iapp.org/resources/article/global-ai-governance-uk/

[13] Kennedys Law. (2025). “The Artificial Intelligence (Regulation) Bill: Closing the UK’s AI Regulation Gap?” Available at: https://www.kennedyslaw.com/en/thought-leadership/article/2025/the-artificial-intelligence-regulation-bill-closing-the-uks-ai-regulation-gap/

[14] King & Spalding. (2025). “Transatlantic AI Governance – Strategic Implications for U.S. — EU Compliance.” Available at: https://www.kslaw.com/news-and-insights/transatlantic-ai-governance-strategic-implications-for-us-eu-compliance

[15] InfoSecurity Europe. (2025). February 2025 AI Security Institute rebranding.

[16] UK Government. (2023, March). “A Pro-Innovation Approach to AI Regulation” White Paper.

[17] GDPR Local. (2025). “UK AI Regulation: Current Status and Outlook.” Available at: https://gdprlocal.com/uk-ai-act/

[18] MetricStream. (2024). “AI Regulation Trends: Your Guide to AI Policies in the US, UK, and EU.” Available at: https://www.metricstream.com/blog/ai-regulation-trends-ai-policies-us-uk-eu.html

[19] King & Spalding. (2025, July). “EU & UK AI Round-up – July 2025.” Available at: https://www.kslaw.com/news-and-insights/eu-uk-ai-round-up-july-2025

[20] IAPP. (2025). UK AI Bill timeline analysis.

[21] Future of Privacy Forum. (2023). Technical interoperability methodology.

[22] Anecdotes AI. (2025). “AI Regulations in 2025: US, EU, UK, Japan, China & More.” Available at: https://www.anecdotes.ai/learn/ai-regulations-in-2025-us-eu-uk-japan-china-and-more

[23] ISAR Global analysis based on institutional relationship mapping.

[24] King & Spalding. (2025). Transatlantic alignment analysis.

[25] Gradient Flow. (2025). “AI Governance Cheat Sheet: Comparing Regulatory Frameworks Across the EU, US, UK, and China.” Available at: https://gradientflow.com/ai-governance-global-cheat-sheet/

[26] World Summit AI. (2025). “Global AI Governance in 2025.” Available at: https://blog.worldsummit.ai/global-ai-governance-in-2025

[27] ISAR Global. (2025, November). “Strategic Intelligence Brief: India’s AI Governance Guidelines.”

[28] World Summit AI. (2025). US AI Action Plan analysis.

[29] King & Spalding. (2025). US state-level AI legislation tracking.

[30] World Summit AI. (2025). EU AI Act implementation timeline.

[31] King & Spalding. (2025). US federal AI policy analysis.

[32] IAPP. (2025). UK AI governance comprehensive overview.

[33] IAPP. (2025). Commonwealth AI governance landscape analysis.

[34] Anecdotes AI. (2025). Council of Europe AI Convention details.

[35] The White House. (2025, November). National Security Strategy of the United States of America, p. 13. “As Alexander Hamilton argued in our republic’s earliest days, the United States must never be dependent on any outside power for core components—from raw materials to parts to finished products—necessary to the nation’s defence or economy.”

[36] The White House. (2025, November). National Security Strategy of the United States of America, p. 9. Technology standards leadership priority: “We want to ensure that U.S. technology and U.S. standards—particularly in AI, biotech, and quantum computing—drive the world forward.”

[37] The White House. (2025, November). National Security Strategy of the United States of America, pp. 17-19. Western Hemisphere section on denying foreign control of strategically vital assets and US infrastructure preeminence.

[38] ISAR Global. (2025, October). Response to Julia Lopez MP: Infrastructure sovereignty analysis. AWS US-EAST-1 outage affecting UK financial institutions documented 20 October 2025.

[39] US CLOUD Act (2018). Clarifying Lawful Overseas Use of Data Act. Enables US legal access to data held by US companies regardless of physical storage location.

[40] The White House. (2025, November). National Security Strategy of the United States of America, p. 10. Sovereignty protection principle: “preventing its erosion by… attempts by foreign powers or entities to… involve us in foreign conflicts.”

[41] Julia Lopez MP. (2025, October). Telegraph article: “Labour is blindly handing Big Tech the keys to our future.” Infrastructure investment scale: OpenAI Stargate (Norway) 100,000 GPUs.

[42] Julia Lopez MP. (2025, October). Telegraph article: UK North East AI Development Zone infrastructure plans: 8,000-31,000 GPUs.

[43] The White House. (2025, November). National Security Strategy of the United States of America, p. 12. Burden-sharing section: “offload[ing] the cost of their defence onto the American people.”

[44] The White House. (2025, November). National Security Strategy of the United States of America, p. 10. Sovereignty protection from “transnational and international organisations.”

[45] ISAR Global. (2025). CLOUD Act jurisdictional contradiction analysis: UK data protection frameworks vs US legal access through corporate control.

Conclusions

The bridge jurisdiction concept presents theoretically attractive positioning for the United Kingdom. Singapore’s October 2023 work with NIST demonstrates that technical framework interoperability is methodologically achievable without sovereignty surrender. Britain’s unique institutional positioning across EU, US, and Commonwealth governance spheres creates coordination opportunities literally no other jurisdiction can replicate.

However, several factors suggest bridge positioning may represent missed opportunity rather than viable strategic option:

UK’s February 2025 explicit US alignment forecloses European coordination trust necessary for genuine bridge role
Absence of any bridge-related policy development in UK government statements suggests concept never gained internal traction
Commonwealth governance diversity creates coordination complexity exceeding Singapore’s bilateral model
Current drift towards exclusive US alignment occurs through accumulated decisions rather than strategic positioning assessment
Infrastructure sovereignty vulnerabilities remain unaddressed whilst governance alignment deepens dependencies

The Infrastructure Sovereignty Warning

The November 2025 US National Security Strategy articulates infrastructure independence as Hamilton-level foundational doctrine: no dependency on outside powers for components necessary to national defence or economy. The NSS explicitly prioritises technology standards leadership whilst warning that sovereignty erosion through external infrastructure control undermines strategic autonomy.

UK’s February 2025 alignment with US governance approaches occurs within this strategic framework—yet demonstrates precisely the dependencies the NSS identifies as antithetical to sovereignty. The AWS US-EAST-1 outage illustrated operational vulnerability through single-jurisdiction infrastructure concentration. The CLOUD Act exposes UK government data to US legal jurisdiction regardless of domestic protection frameworks. Scale asymmetries (100,000 GPUs vs 8,000-31,000) create capability dependencies on US corporate infrastructure decisions.

The analytical point cuts sharply: UK is aligning with the governance framework of a nation that has articulated infrastructure independence as foundational principle… whilst demonstrating the opposite posture. The United States isn’t being hypocritical—it’s being strategically consistent. The Hamilton Principle applies to US sovereignty, and the NSS dedicates substantial analysis to preventing foreign infrastructure control in the Western Hemisphere.

UK appears to have interpreted alignment as requiring adoption of US governance philosophy without recognising that US strategic doctrine considers infrastructure independence prerequisite to credible sovereignty. One cannot credibly advocate for the Hamilton Principle whilst demonstrating its opposite. One cannot lead Commonwealth coordination for infrastructure sovereignty when Britain’s own critical systems depend on foreign-controlled infrastructure operating under foreign legal jurisdiction.

Current trajectory thus involves compounding risks:

Operational resilience depends on foreign infrastructure operating under foreign jurisdiction
Data sovereignty becomes aspirational rather than enforceable when systems run on US-controlled platforms
Policy autonomy faces constraints from infrastructure dependencies regardless of regulatory philosophy
Future options narrow as path dependencies from procurement decisions become institutionalised

Bridge jurisdiction positioning, had it been viable, would have required addressing these infrastructure vulnerabilities as part of systematic coordination strategy. Commonwealth partners facing similar US dependency pressures would reasonably question UK leadership on governance coordination whilst Britain demonstrates no infrastructure sovereignty capability.

The Fundamental Assessment

The fundamental question is whether current drift represents deliberate choice or strategic inattention. Evidence suggests the latter—UK policy proceeds through sectoral decisions without comprehensive assessment of positioning opportunities created by unique institutional relationships across three governance spheres, nor systematic analysis of compounding vulnerabilities from combined governance alignment and infrastructure dependency.

If bridge jurisdiction merited serious consideration, that assessment needed to occur before February 2025’s US alignment announcement and alongside infrastructure sovereignty strategy. Current trajectory suggests the positioning window—if it ever genuinely existed—has closed through policy drift rather than strategic decision, whilst infrastructure dependencies deepen without apparent risk mitigation planning.

The AWS outage provided concrete evidence of operational vulnerability. The CLOUD Act creates ongoing jurisdictional exposure. The infrastructure investment gap constrains future capability options. Yet UK policy statements maintain that governance alignment with US innovation approaches constitutes sufficient strategic positioning—without addressing whether that alignment, combined with infrastructure dependencies, serves long-term UK interests in either economic competitiveness or strategic autonomy.

This combination of governance alignment without framework coordination and infrastructure dependency without sovereignty strategy represents the governance reality underlying current UK AI policy trajectory. Whether that reality serves UK strategic interests remains an open question that current policy drift leaves unaddressed.

The November 2025 US National Security Strategy clarifies what UK policy has perhaps not yet recognised: infrastructure sovereignty isn’t a technical consideration separate from governance strategy—it’s foundational to credible strategic autonomy. The Hamilton Principle doesn’t suggest infrastructure independence might be advantageous; it establishes dependency on outside powers for critical components as incompatible with national security. UK’s current trajectory thus faces a fundamental contradiction: one cannot align with a strategic framework that prioritises infrastructure sovereignty as foundational whilst demonstrating systematic infrastructure dependency.