Comparative Analysis of Digital Legislation in Asia and Western Europe

The objective of the study is to identify key trends and features of digital legislation in Asian and Western European countries to develop recommendations for modernizing the Russian legal system. The objects of analysis include legislative acts and strategic documents of Italy, France, Germany, Great Britain, the USA (Western group), as well as China, India and Singapore (Asian group). The methodological basis is a comparative legal analysis, a systems approach to the study of regulatory texts, classification of countries by region, synthesis of general principles and a critical assessment of regulatory contradictions. The results of the study demonstrate that Western countries focus on the rights of citizens, decentralized governance and the balance between openness of data and its protection. In Asian countries, centralized control, priority of national security and strict regulation of new technologies dominate. Common features for all countries are the digitalization of public services, cybersecurity measures and risks associated with resource constraints and bureaucracy. The identified contradictions include the conflict between innovation and regulatory barriers, ambiguity of terminology and gaps in the regulation of cross-border data. Based on the analysis, recommendations are proposed for Russia: integration of Western experience in the field of transparency and protection of citizens’ rights with Asian approaches to security and technological sovereignty. The need for flexible regulation, investment in infrastructure and training of civil servants for sustainable digital transformation is emphasized.