Source: Frontiers in Artificial Intelligence

This scholarly article in Frontiers in Artificial Intelligence provides a detailed comparative legal analysis of the emerging regulatory frameworks for AI foundation models in the European Union, the United States, and China. The authors examine the distinct approaches these major global powers are taking to govern the powerful, general-purpose AI systems that underpin many modern applications. The research highlights the different philosophies and priorities shaping these regulatory landscapes, from the EU's rights-based, risk-tiered approach to the US's more sector-specific, innovation-focused strategy, and China's state-led, social stability-oriented model.

The paper meticulously compares key aspects of each jurisdiction's approach, including their definitions of AI, their allocation of liability, and their requirements for transparency, data governance, and risk management. The analysis reveals both points of convergence, such as a shared concern over high-risk applications, and significant divergence in legal mechanisms and enforcement. The authors conclude that understanding these different regulatory paths is crucial for developers, businesses, and policymakers operating in the global AI ecosystem. They also discuss the long-term challenges and possibilities for achieving international regulatory interoperability to govern this transformative technology effectively.