AI AND THE LAW: A COMPARATIVE OVERVIEW OF GLOBAL REGULATORY APPROACHES

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Zoyir Khusen ugli Eshmurodov

Abstract

This article provides a comparative overview of the legal approaches to artificial intelligence (AI) regulation in the European Union, the United States, and China. It examines the European Union’s pioneering AI Act, the first comprehensive legal framework for AI, which adopts a risk-based model aimed at balancing innovation with fundamental rights protection. The article contrasts this with the United States’ decentralized and sectoral approach, which emphasizes innovation and agency-specific oversight in the absence of a unified federal law. It also explores China’s state-driven strategy, characterized by centralized administrative control, content regulation, and integration of political ideology into AI governance. Through this comparison, the article highlights the legal, cultural, and political factors shaping global AI regulation, and underscores the need for cross-border cooperation, ethical alignment, and informed legal practice in the age of rapidly evolving AI technologies.

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