Regulatory Frameworks for Artificial Intelligence in the European Union and India: A Comparative Study

The fast advancement of AI has sparked discussions over optimal regulatory approaches. The regulatory approaches taken by the European Union (EU) and India are compared in this paper.The EU Artificial Intelligence Act (AIA) is the world's first comprehensive legislative endeavor on AI,providing a mandatory framework based on risk classification, clearly defined responsibilities for users and suppliers, and processes for market surveillance and conformance evaluation. India's AI laws are not specific; rather, they are based on the Information Technology Act of 2000, which creates data protection regulations and policy-driven programs like NITI Aayog's #AIForAll.Based on a review of legal and policy documents, the study identifies several significant differences in terms of risk classification, measures of responsibility, institutional governance, and protection of rights mechanisms. Findings suggest that the EU follows a clearer,rights-based model,whereas India's approach remains fragmented and evolving,characteristic of strong policy rhetoric but no binding protection.The study concludes that India may learn from the integration of formal risk-based obligations and algorithmic responsibility mechanisms from the EU while maintaining flexibility in responsive governance considerations.