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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 comparativeapproach identifies opportunities for harmonising regulatory efforts and highlights the importance of integrating ethical and legal standards at the global level.
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Khassanay et al. (2025) studied this question.
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