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◆ Journal of Governance and Regulation2025-12-05· Enforcement

A comparative analysis of artificial intelligence regulation in ASEAN and the European Union

Yan Lu, Fatt Hee Tie

原始摘要(英文原文)· Original abstract
This study conducts a comparative analysis of artificial intelligence (AI) regulation in the European Union (EU) and the Association of Southeast Asian Nations (ASEAN), examining their governance frameworks, enforcement mechanisms, and regulatory impact. The EU AI Act (EU, 2024) establishes a legally binding, centralized regulatory model that prioritizes risk-based AI classification, strict compliance obligations, and human rights protections (Huang et al., 2024). In contrast, ASEAN follows a decentralized, voluntary governance approach, promoting flexibility, innovation, and industry self-regulation (Putra, 2024). The analysis highlights the trade-offs between regulatory stringency and innovation flexibility. The EU’s strict enforcement model ensures accountability and consumer protection but poses compliance burdens for businesses, potentially slowing AI adoption. Conversely, ASEAN’s market-driven approach fosters rapid AI deployment but raises concerns about regulatory fragmentation, ethical risks, and cross-border governance inconsistencies. These findings are crucial for policymakers and businesses navigating AI governance complexities. As AI continues to evolve globally, harmonizing regulatory approaches and establishing mutual recognition mechanisms between regions could enhance AI accountability while supporting innovation, shaping a more cohesive global AI governance landscape.
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