This paper presents a comparative analysis of the legal regulation of artificial intelligence (AI)
in the People's Republic of China (PRC) and the European Union (EU). Both jurisdictions aspire to
be leaders in AI technologies, but their approaches to the development and implementation of
regulations diverge significantly. The EU places significant emphasis on the implementation of robust
regulatory frameworks and the protection of human rights, with a view to fostering ethical standards
across a range of sectors, including defence. However, this approach has also attracted criticism for
potentially impeding innovation. A principal component of this strategy has been the “Artificial
Intelligence Act” 2024, which establishes a legal framework for the secure utilisation of AI and the
protection of citizens' rights.
In contrast, China has adopted a centralised approach to facilitate innovation and expedite
decision-making processes. This approach has enabled the country to retain its position at the
vanguard of AI legal regulation, implementing efficacious mechanisms such as the “The Internet
Information Service Algorithm Recommendation Management Regulations” and the “Personal
Information Protection Law”. However, there is a risk that the focus on rapid technology adoption
may result in inadequate protection of citizens' rights.
This paper analyses the advantages and disadvantages of both strategies, as well as their impact
on international AI regulatory practice. The comparative approach identifies opportunities for
harmonising regulatory efforts and highlights the importance of integrating ethical and legal standards
at the global level.
