Algorithmic Accountability in Global Frameworks: A Comparative Discourse Analysis of Legal Constructs

Abstract This study investigated how algorithmic accountability is discursively framed across major global AI governance models, aiming to uncover how regulatory narratives shape legal responsibilities and power relations within the European Union, the United States, and ASEAN frameworks. A critical discourse analysis, combined with framing theory, was applied to three key instruments: the European Union Artificial Intelligence Act, Executive Order 14110 of October 30, 2023, and the ASEAN Guide on AI Governance and Ethics. The analysis revealed three distinct framings: the EU adopts a legal and rights-based approach, the U.S. relies on voluntary and innovation-driven standards, and ASEAN emphasizes ethical and cooperative responsibility. Common anchors such as transparency, explainability, and human oversight offer opportunities for regulatory convergence. Algorithmic accountability functions as both a regulatory mechanism and a discursive tool, reflecting divergent governance philosophies and geopolitical strategies. These narratives shape how AI accountability is defined, implemented, and contested globally. Policymakers, industry actors, and civil society should pursue adaptive and interoperable governance frameworks that strike a balance between legal enforcement, innovation, and ethical principles to strengthen global AI accountability.