This study examines the contrasting AI regulatory frameworks of the European Union (EU) and China, shaped by their distinct political cultures and strategic objectives. The EU adopts a rights-oriented, risk-based model, categorising AI systems based on their potential impact on civil liberties. Conversely, China employs a sector-specific, security-driven model that emphasizes national security, social stability, and economic growth. The findings highlight three key differences: (1) Regulatory Philosophy: The EU prioritises rights protection, while China focuses on security and technological competitiveness. (2) Focus and Approach: The EU uses a universal risk-based model, while China tailors regulations to specific sectors. (3) Key Characteristics: The EU mandates explainability and accountability, while China prioritizes data labelling and content control. In conclusion, the EU envisions AI as an extension of its human rights-first philosophy, constrained by legal and ethical frameworks. China, by contrast, views AI as a tool for industrial and geopolitical dominance, driving what may be termed “AI-facilitated reindustrialization.” While global AI governance convergence is unlikely, pragmatic adaptation and mutual recognition of differing norms could facilitate cooperation.
Using firm-level panel data on fiscal subsidies and R&D investment, this study employs a propensity score matching method to obtain a matched datas...
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