Comparative Governance and Regulatory Approaches Towards Generative Artificial Intelligence

Abstract

Generative Artificial Intelligence (GenAI) use is not restricted to ordinary data processing and this is why it has become a key issue in the business landscape related to Corporate Governance and Technology Law. Content generation, impact on organizational decisions, legal, financial and reputational consequences are all areas where GenAI systems can impact. The risk of misinformation, copyright problems, data security and algorithmic bias and insufficient regulation have thus given rise to the need for good corporate governance structures. However, there are distinct jurisdictions' methods of control of such risks. The European Union has a comprehensive and risk-based approach, while the United Kingdom is moving towards a principles-based and sector-led approach; the United States has a primarily fragmented and enforcement-based approach; India has an approach driven by innovation and adaptation; and China has a compliance-based and state-led approach.