With AI’s exponential growth and pervasive use across various sectors, governments worldwide are racing to assert control over this rapidly advancing technology. In this high-stakes game, three major players have emerged: China, the European Union, and the United States, each wielding distinct approaches and philosophies toward AI governance. However, amidst their internal struggles for supremacy, they are also engaged in fierce competition to export their regulatory models to the rest of the world, with no clear leader in sight.
The importance of AI regulation
During a recent Club Lunch discussion hosted by the FCC, Professor Anu Bradford from Columbia Law School, an expert in international trade law and digital regulation, emphasized the significance of AI regulation. Bradford says, “There’s a recognition that AI is one of the most important ‘theaters of war.’ That’s where the most important battles are being fought and where you cannot afford to be left behind.”
Horizontal vs. vertical battles
Bradford elaborated on the dynamics of AI regulation, distinguishing between “horizontal” battles among different governments and “vertical” battles between governments and tech companies. While vertical battles often lead to either self-regulation by tech firms or government overreach, horizontal battles showcase the distinct approaches of the three major regulatory players and their efforts to export their regulatory styles.
China: the state-driven approach
China adopts a state-driven approach to AI regulation, aligning with its overall governance style. The Chinese model, characterized by higher surveillance, poses a significant challenge to the US and EU in extending their regulatory methods to the rest of the world. Countries with higher crime rates may find China’s approach appealing due to its perceived effectiveness in utilizing AI.
The US: market-driven and innovative
The US follows a market-driven approach, with core values such as free speech, internet freedom, and innovation guiding its legislation. Despite being considered a “liberal democracy” in the tech world, the US faces growing concerns about American internet users’ privacy and data safety. The failure to enforce self-regulation among tech giants has led to skepticism about the American digital empire’s vitality.
The EU: Rights-driven and democratic
In contrast, the European Union prioritizes the democratic rights of internet users, adopting a rights-driven approach to AI regulation. The US and EU are considered “liberal democracies” in the tech world, but China’s authoritarian model challenges the notion that freedom is a prerequisite for innovation.
China’s limitation
Despite its advancements, China faces a significant limitation in generative AI. Professor Bradford pointed out that the Chinese government’s censorship practices reduce the data pool for training Language Learning Models, giving the US an advantage in this domain. This limitation may allow the US to highlight the importance of free access to information.
India and Japan: blending approaches
Two outliers in this global battle for AI control are India and Japan. These countries opt for a mixed approach, picking elements from all three regulatory styles without necessarily emerging as separate digital empires. Such mixed approaches leave room for increased influence from authoritative models or tech companies, posing major risks to the US and EU regulatory models.
The challenge for liberal democracies
As the US and the EU grapple with diverse regulatory challenges and mixed models emerging worldwide, Professor Bradford concluded, “That leaves the US and the EU with a very big challenge that if they cannot show to themselves and to the world that there is a liberal democratic way to govern tech companies, the true digital empires are either the authoritarians or the tech companies, and that is a very disconcerting outcome for anybody who believes in liberal democracy as a foundation for human engagement and our digital society.”
In this global battle for AI control, the outcome remains uncertain, but one thing is clear: the direction AI regulation takes will profoundly shape the future of technology and its impact on societies worldwide. As China, the EU, and the US continue to vie for dominance, the world watches closely, recognizing that the stakes have never been higher in this digital age.
