Comparative Global AI Regulation: Policy Perspectives from the EU, China, and the US

TL;DR

This paper compares AI regulation approaches in the EU, China, and the US, highlighting their cultural, political, and economic differences and implications for global AI governance.

Contribution

It provides a detailed analysis of the distinct regulatory frameworks and perspectives of the EU, China, and US, including California's specific policies.

Findings

Divergent risk-benefit tradeoffs across regions

Contrasting trust models: centralized vs. decentralized

Regulatory approaches influence international AI governance

Abstract

As a powerful and rapidly advancing dual-use technology, AI offers both immense benefits and worrisome risks. In response, governing bodies around the world are developing a range of regulatory AI laws and policies. This paper compares three distinct approaches taken by the EU, China and the US. Within the US, we explore AI regulation at both the federal and state level, with a focus on California's pending Senate Bill 1047. Each regulatory system reflects distinct cultural, political and economic perspectives. Each also highlights differing regional perspectives on regulatory risk-benefit tradeoffs, with divergent judgments on the balance between safety versus innovation and cooperation versus competition. Finally, differences between regulatory frameworks reflect contrastive stances in regards to trust in centralized authority versus trust in a more decentralized free market of self-interested stakeholders. Taken together, these varied approaches to AI innovation and regulation influence each other, the broader international community, and the future of AI regulation.