[Answered] Compare and contrast the AI regulatory approaches of the European Union, China, and the United Kingdom with that of India. What lessons can India learn from these countries?

Introduction: Brief introduction to AI

Body: Analyse the regulatory approach of different nations

Conclusion: Way forward

The Artificial Intelligence (AI) space has seen certain developments crucial to its regulation in recent years, the recent being the United Nations’s Resolution on Artificial Intelligence which is a global acknowledgment of the risks associated with AI systems and the urgent need to promote responsible use of AI. The new resolution highlights the impact of AI on the 2030 Sustainable Development Goals (SDGs) & its adverse impact on the workforce.

Regulatory Approach of Different Nations

  • European Union: The EU’s AI Act categorizes AI systems based on risk and prohibits applications that threaten citizens’ rights. Exceptions are allowed for law enforcement with prior authorization. The Act addresses compliance burdens on businesses and regulates emerging technologies like Generative AI systems such as ChatGPT, underscoring the need for policymakers to keep pace with evolving AI.
  • China: China’s approach to AI regulation prioritizes promoting innovation while mitigating potential risks to national social and economic objectives. The country has introduced a phased regulatory framework addressing content moderation, personal data protection, and algorithmic governance. This framework emphasizes identifying content generated by AI systems, obtaining user consent for data access and processing, and ensuring security and ethical considerations in algorithm development and operation.
  • United Kingdom: In contrast to the EU’s approach, the UK has embraced a principled and context-based strategy for regulating AI systems. This approach involves mandatory consultations with regulatory bodies to enhance technical expertise and address regulatory gaps. The UK favors a decentralized and softer legal approach, prioritizing flexibility over stringent rules in AI regulation.

Lessons India can learn from these nations

  • Although draft laws like the Personal Data Protection Bill and the National Strategy for Artificial Intelligence have been produced, India has not yet put comprehensive rules about AI into effect.
  • With broader talks on AI ethics and governance, India’s current regulatory measures center on cybersecurity, data protection, and privacy.
  • India’s strategy combines government actions, developing legislative frameworks, and industry self-regulation.
  • India may benefit from learning how important it is to match AI rules with larger national interests, how to promote innovation while upholding moral standards, and how to use expert advisory groups to help shape policy.


India’s response to the global trend of AI regulation holds significant importance, given its status as one of the largest consumer markets and labor forces for technology firms. With plans for over 10,000 deep tech startups by 2030, India allocated ₹10,300 crore for the AI mission to enhance public-private partnerships and support startups.

Print Friendly and PDF