The Convergence Table: Who's Building What
China, the EU, India, the US, the UK — the control grid compared component by component. The gap between the systems is closing; the table shows which pieces each one has already built.
The Convergence Index
mean 33.75The gap —
closing
Thirteen capability components, each scored 0–100 on a fixed rubric — capability · scale · absence of limit. Every cell carries its C·S·U grades; an amber corner tick means no enforced limit at all. Hover a score for its basis, click it to jump to the sourced evidence below. How it’s scored ↓
How the score is computed
score = (C + S + U) / 9 x 100 · equal thirds. Each cell is graded on three axes from its sourced evidence (hover any score for its grades + basis):
- C — Capability — is it fielded and operational? 0 none · 1 proposed/pilot · 2 operational-limited · 3 operational-routine
- S — Scale — how comprehensive? 0 negligible · 1 local/sectoral · 2 broad-incomplete · 3 nationwide/universal
- U — Unconstraint — absence of an enforced limit? 0 strong/enforced · 1 partial/eroding · 2 paper-only · 3 none
The 'Legal limits on access' row is not scored as its own component (that would double-count limits); its evidence sets each row's U axis. The index runs over the 13 capability components. Every cell's C/S/U and its source are the audit trail.
China built it first. The democracies built it next, with regulations attached. Then the regulations got carve-outs. Then the carve-outs got their own carve-outs.
The table below sorts the rollout by structural properties — does the capability exist, is there a legal limit, how comprehensive is the deployment — and ignores the cultural framing each jurisdiction uses to justify it. The framings differ. The infrastructure does not. Each cell sources to a primary document, a tracker, or a beat reporter who has earned the byline.
Where it appears in print: The Ratchet, Chapter 19 (“The Model”). The book narrates the table; this page maintains it as deployments evolve.
The Table
The Trajectory Line
China: Built first, most comprehensive, weakest limits. The reference implementation. (China Law Translate is the standing source for tracking what’s actually deployed vs. what’s announced.)
India: Building fastest in a democracy. Democratic checks slow speed but not direction. India Stack is the open-source export of the model — Aadhaar + UPI + Account Aggregator + DigiLocker. Other countries (Philippines, Sri Lanka, Brazil) are now importing it.
EU: Regulating most aggressively. Brussels Effect exports standards globally. But building the same infrastructure (eIDAS, DSA, TCR, AI Act) — the EU’s bet is that comprehensive regulation of the infrastructure prevents abuse. The bet has not been tested at scale. And “EU” is itself an average that smuggles a bloc: it hides a rule-of-law spread from the Hague (brake engaged — SyRI struck down, a cabinet fell over the toeslagenaffaire) to Budapest (brake inert — Article 7 since 2018), with France’s general-will surveillance statutes and Poland’s post-2023 reversal in between. The disaggregation, framed by constitutional tradition, is in Three Legal Traditions and the Control Grid.
US: The economic-warfare state. Fragmented at home, dominant abroad. NSA / Five Eyes mass surveillance is operational, but the real leverage is economic: dollar-denominated sanctions are the global off-switch — de facto programmable money for anyone who clears in dollars — backed by BIS export controls, IEEPA tariffs, and industrial-policy equity stakes. Federal fragmentation hides total reach.
UK: The speech-control state. The Online Safety Act plus Ofcom enforcement and Met Live Facial Recognition make it the most aggressive Western speech-and-content regime — the opposite composition from the US it used to be averaged with. Add NHS-centralized health data, the Investigatory Powers Act (“Snoopers’ Charter”), and the Coutts/Farage debanking episode, and the UK is building the demand side of the same stack the US builds on the supply side.
Key Insight
The infrastructure gap between China and democracies is closing. The enforcement gap (judicial review, press freedom, civil society) remains — for now. The question is whether the enforcement gap narrows as fast as the infrastructure gap closes.
Primary signals to watch:
- Emergencies-Act-style invocations in democratic countries — see Canada 2022, and the Federal Court of Appeal’s 2026 ruling that the use was overreach. Judicial pushback is the friction democracies still have over China.
- Court rulings on biometric / data-protection limits — CJEU SCHUFA ruling C-634/21, K.S. Puttaswamy v. Union of India (Indian Aadhaar judgment).
- Backdoor / encryption mandates — UK Online Safety Act Section 121, EU CSAM Regulation. The crack in end-to-end encryption is where infrastructure converges fastest.
Bridges
- the-record — same 20 mechanisms, framed as country-by-country self-assessment
- the-record — the personnel network operating across these jurisdictions
- ai-governance-tracker — the AI-specific overlay on the infrastructure stack
- economic-statecraft-tracker — the outward economic instruments (export controls, tariffs, industrial policy) now scored in this grid
- Three Legal Traditions and the Control Grid — the causal layer: why the scores diverge (US republicanism blocks the speech ratchet, UK common law enables it, French general-will justifies it)
Sources
Inline citations above carry the primary documents. Standing trackers that should be checked first when updating:
- Atlantic Council CBDC Tracker — most reliable single source for CBDC deployment state
- HRF CBDC Tracker — rights-focused complement to Atlantic Council
- Access Now KeepItOn — internet shutdown tracker
- Freedom House Freedom on the Net — annual cross-country comparison
- Comparitech facial-recognition + surveillance indices — most useful aggregator for facial-recognition deployment counts
- China Law Translate — Jeremy Daum’s authoritative China social-credit primary-source library
- Project Panoptic — India facial-recognition tracker (IFF)
Companion research: Digital Identity Systems, CBDCs and Programmable Money, The Deplatforming Cascade.