In 2023, we are already seeing the potential of ChatGPT and next-generation AI technologies to change the way we learn, work, and interact. These are just the first steps of a technology that, in the best-case scenario, will push new frontiers of human knowledge and productivity, transform labor markets, reinvent economies , and lead to unprecedented levels of social and economic growth.
At the same time, the rapid pace of AI development is causing concern among inventors, tech leaders, and regulators. Even Sam Altman, CEO of OpenAI—the research company behind ChatGPT—has warned about the dangers AI poses to individuals, economies, and societies if left unchecked. Worst-case scenarios are based on the possibility that AI could overtake human control, allowing the technology to disrupt the labor market, render humans unnecessary, and even lead to the end of the human race, as some Hollywood sci-fi movies have suggested.
Against this backdrop, governments around the world – particularly in the US, China and the European Union (EU) – are facing increasing pressure to regulate the AI race between tech companies without completely squelching the development of the technology. Despite the same concerns, the US, China and the EU have begun to develop very different approaches to regulating AI technology, based on the values and ideologies that are considered most important in their societies.
The winner in the AI approach will have a huge impact on the future of technology and society, as decisions are being made at a time when AI technology is still new and has no clear direction for development. And none of us can afford to be left behind.
America
The US’s less-regulated approach to AI regulation is a testament to its strong belief in free-market capitalism and how these values enable technological innovation. Rooted in an economic governance model that allows companies to operate freely, which in turn gives them great political power, the US AI regulatory framework is clearly laissez-faire in character. It focuses on protecting free speech, a free Internet, and government policies that encourage innovation.
One of the main reasons for this approach is American society’s belief in innovation and new initiatives as the primary drivers of social progress and economic prosperity. American policymakers largely believe that overly restrictive regulations can stifle the innovation that has thrived here under free-market principles. This approach has led to America’s remarkable advances in AI, from OpenAI’s ChatGPT tool for everyday users to innovations in health care diagnostics, predictive modeling, and climate trends.
As a result, the US has not developed any meaningful federal AI regulatory policy, but has instead proposed a few voluntary standards that tech companies can choose to adopt or ignore. The most recent example is the Blueprint for an AI Bill of Rights, a handbook published by the White House in October 2022. It provides guidance to AI developers and users on how to protect the rights of the American public in the age of AI, but ultimately places trust in companies to govern their own technology. This support for private AI development can be seen in Washington’s increased focus on investing in AI research and development (R&D) and improving the federal government’s capacity to use AI in administrative operations.
Washington also sees AI as an opportunity to consolidate US military and technological supremacy amid intensifying US-China technological competition and growing concerns about geopolitical conflict between the two powers. The US focus on economic and geopolitical dominance has made technological control a secondary concern. This hands-off approach also reflects Washington’s geopolitical strategy, with policymakers believing that the US can use soft power to gain AI technological advantage and leadership. These geopolitical considerations inform Washington’s view that too much regulation will stifle AI innovation, thereby threatening America’s global leadership in the field. Instead, Washington relies on voluntary standards, hoping that the influence of US companies in AI development will allow the US to push this approach globally—consolidating US power.
European Union (EU)
The EU’s approach to AI regulation is shaped by a human rights-focused framework, building on the societal precedents that have shaped the General Data Protection Regulation (GDPR). The GDPR, which came into effect in 2018, laid the foundation for the EU’s human rights-based approach to AI.
The principles of data minimization, purpose limitation, and transparency requirements are all values that continue to be relevant in shaping how Europe regulates AI. In the same way, policymakers must weave ethical considerations and technological innovation together – to establish a framework for regulating AI with human interests at the heart. This approach aims to protect the privacy of individuals, ensure companies operate transparently, and maintain public trust in AI technology.
The biggest evidence of the EU’s commitment to strong AI governance is the European Commission’s proposed AI regulatory framework. This is the first regulatory framework to regulate AI technology. It seeks to set clear requirements and obligations for AI developers, implementers, and users, with a particular focus on high-risk AI applications. The proposal aims to address the various challenges posed by AI technology, including difficulties in understanding the decision-making processes of AI systems, and assessing cases where the technology is being used unfairly. In addition to ensuring the safety and fundamental rights of citizens and businesses, the proposal also aims to use AI to reduce the administrative and financial burden on businesses, especially small and medium-sized enterprises (SMEs).
The EU strategy also proposes a risk-based approach, distinguishing between AI applications on four levels – unacceptable, high risk, restricted, and no risk. AI applications that are considered to pose a clear threat to human safety, livelihoods, and rights would be banned, while high-risk applications – including AI technology used in critical infrastructure and in employment – would be subject to strict regulations. AI systems that pose minimal risk would also be subject to regulatory oversight, but at a minimal level.
Perhaps less explicitly than the US and China, the EU also recognizes the role of AI in helping geopolitical competition. By taking the lead in setting AI regulatory standards in Europe, Brussels hopes to spread its values of human rights, transparency, and consumer protection around the world. The EU’s ability to regulate technology, something it has demonstrated in the area of data protection with the GDPR, gives Brussels the opportunity to shape global AI norms—and thus provide the EU with a significant source of soft power.
The EU’s approach is not without its challenges, however. The potential for AI development in EU countries is currently not on par with what is seen in the US and China. Some observers argue that the EU’s strict regulations could stifle innovation and make European companies less competitive globally. This suggests that, while the EU hopes to set standards for AI regulation, it will not be able to develop the majority of these technologies, instead relying on its ability to control technology from outside. This could reinforce the perception in third countries that the EU is trying to impose European values on societies where they do not fit, with the opposite effect of losing European geopolitical influence.
China
In contrast to the free-market approach of the United States and the human rights-based control of Europe, China adopts a more assertive and centralized model of AI control. The top-down control model can be seen as the embodiment of China's blend of authoritarian state governance and market economics at the same time.
Underpinning this approach is the central role of the government in developing and overseeing AI. With a long-term strategic vision and a willingness to mobilize large resources to develop the technology, Beijing has placed AI at the forefront of the country’s development policy.
The “New Artificial Intelligence Development Plan,” released in 2017, outlines a blueprint for China to become a world leader in AI by 2030. The strategy sees AI as a core driver of China’s industrial upgrading and economic transformation, and in the process, will deeply integrate AI into governance and social management, including city governance, public services, and domestic security monitoring. The Chinese government believes that AI can be deployed to maintain order and maintain tight social control. China’s surveillance state model has incorporated AI into its national governance strategy, using it as a tool to monitor, censor, and control not only information sources in society.
The “Temporary Measures for Managing Innovative Artificial Intelligence Services,” which are set to take effect on August 15, show how China balances using AI to drive economic dynamism while maintaining state control over society. The policy includes AI controls similar to those in the EU and the US, such as protecting intellectual property rights, ensuring technology is developed transparently, and prohibiting discrimination between users, but also includes political elements that reflect China’s social context.
This includes requirements that AI development adhere to socialist values, prohibiting the use of AI to commit acts of incitement or anti-state activities. The policy also requires AI development companies to obtain state-approved licenses to provide AI services, showing how Beijing intends to maintain a high level of control over the deployment of this technology.
Like the US and EU, China’s approach is also shaped by domestic social, cultural, and political attitudes, while also influencing these attitudes through the government’s approach. The national push to master AI has fostered a society where AI technology has become an accepted part of people’s daily lives, from facial recognition payment systems to AI teaching assistants. Beijing’s willingness to adopt these technologies into everyday life compared to the US and EU will likely act as a catalyst to accelerate the rapid development of AI in China. While Western countries face deep debates about the application of AI in society, China can use its renewed public support to deploy AI on a large scale, without facing the popular resistance that has come with the West.
Beyond societal implementation, China’s superiority can also be seen in the way Beijing regulates the market to support AI research, rather than relying on the free market to drive innovation. China accounted for nearly one-fifth of global private investment in AI in 2021, and in terms of academic research, China published about one-third of all AI papers and citations in the same year. The Chinese government’s strong investment and support has fostered an increasingly dynamic AI technology sector, with the goal of making AI a key resource for all areas of the country’s development.
China’s policy is deeply rooted in the Confucian tradition of emphasizing social harmony and the power of the state to ensure this harmony. While China’s approach to AI regulation may continue to raise concerns about privacy and civil liberties—given the potential for AI applications to monitor and control society—it also demonstrates Beijing’s ability to adapt quickly to technological change. This shows how quickly Chinese policymakers are able to propose, implement, and change AI regulatory laws. Compared to processes in Europe and the United States, China will be better able to adapt its policies to keep pace with the rapid development of AI.
Lesson 2: Who will win the AI race?
Pham Vu Thieu Quang
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