Global AI Regulation Review: Comparative Insights from EU, US and APAC
摘要
Artificial Intelligence (AI) is effecting significant transformations across various sectors; however, its swift integration into these industries engenders apprehensions regarding transparency, equity, and accountability. This review consolidates insights on the international regulatory framework governing AI as of June 2025, with particular emphasis on the European Union (EU), United States (US), and Asia-Pacific (APAC) regions. By employing the AI Governance Triangle (comprising Actors, Instruments, and Institutions) as a theoretical lens, it scrutinizes regulatory responses to challenges such as explainability, bias, and accountability. The investigation utilizes a methodology inspired by PRISMA to assess pivotal jurisdictions, integrating viewpoints from regulators, the industry, and civil society. The results underscore the EU’s risk-based AI Act, the fragmented legislative landscape at the state level in the US, and the heterogeneous regulatory frameworks within APAC, with an intensified examination of enforcement difficulties in the US. The review advocates for global harmonization to achieve a balance between fostering innovation and ensuring safety.