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

Jon Chun, Christian Schroeder de Witt, Katherine Elkins

TL;DR

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, and influence each other, the broader international community, and the future of AI regulation.

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.

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

TL;DR

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, and influence each other, the broader international community, and the future of AI regulation.

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.

Paper Structure

This paper contains 34 sections, 10 figures.

Table of Contents

  1. Abstract
  2. Introduction
  3. AI Governance
  4. The European Union
  5. Overview
  6. The Geopolitics of the Act
  7. Laws and Regulation
  8. Systems and Models
  9. Roles
  10. Risks
  11. Prohibited use cases.
  12. High-risk use.
  13. Limited risk.
  14. Minimal risk.
  15. GPAI models of systemic risk.
  16. ...and 19 more sections

Figures (10)

  • Figure 1: Decision tree for providers of (GP)AI systems and GPAI models on the way to the EU market.
  • Figure 2: The risk pyramid for AI systems (taken from madiega2024artificial)
  • Figure 3: Chinese AI Laws and Regulations
  • Figure 4: AI Model Compliance Steps in China
  • Figure 5: Executive Order #14110 on the Safe, Secure, and Trustworth Development and Use of AI (* see Appendix A for agency acronyms)
  • ...and 5 more figures