The proliferation of artificial intelligence
(AI) systems offers significant benefits
but also presents considerable global
risks. Despite the international nature of
these risks, an internationally accepted
governance framework for AI remains
absent. This is largely due to geopolitical
tensions and the lack of consensus among
major global powers on the appropriate
scope and methods for regulating AI
development. The European Union (EU),
China, and the United States are key
players in AI regulation, each with
divergent approaches. However, common
themes can be identified to form the
foundation of a global regulatory
framework aimed at both managing risks
and fostering innovation. This
dissertation conducts a comparative
analysis of AI regulations in the EU and
China and examines the implications for
the development of a global AI
governance framework. Using deductive
thematic analyses, the study explores the
convergences and divergences in their
regulatory approaches. While differences
arise from China’s emphasis on socialist
values, national security, minimal focus
on individual rights, and geopolitical
rivalry with the United States, there are
areas of alignment. These include the
categorisation of AI systems, safety measures, human-centric design,
transparency, professional responsibility,
privacy, and accountability. The study
concludes that these shared regulatory
principles could serve as a foundation for
the development of a multilevel global AI
framework. Such a framework should
incorporate international, national, and
industry-level governance with clearly
defined outcomes and responsibilities.
The United Nations, as a politically
legitimate global forum with broad
influence, including among China, is well-positioned to lead this effort.
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