Comparative analysis of AI and privacy laws in Europe and Asia : Identifying regulatory disparities and pathways for harmonisation

This paper provides a comparative analysis of artificial intelligence (AI) and privacy legislations in Europe and Asia, aiming to identify and bridge existing regulatory disparities to facilitate international cooperation and interoperability. The analysis contrasts Europe’s rights-based regulatory frameworks, notably the General Data Protection Regulation (GDPR) and the recently enacted EU AI Act, with pragmatic and innovation-driven models evident in Asian jurisdictions such as India’s Digital Personal Data Protection Act 2023 (DPDP Act), proposed Digital India Act, China’s Personal Information Protection Law (PIPL), Japan’s Act on the Protection of Personal Information (APPI) and Singapore’s Personal Data Protection Act (PDPA). By exploring geopolitical, economic and legal influences shaping these diverse regulatory approaches, the paper delivers critical insights through targeted case studies, illustrating both practical challenges and successes in balancing innovation with robust privacy safeguards. Key issues examined include cross-border data transfer complexities, the necessity for interoperability and the establishment of trust frameworks. The paper critically evaluates ethical considerations, particularly around consent mechanisms, data ownership rights and algorithmic transparency, within each regional context. This article is also included in The Business & Management Collection which can be accessed at https://hstalks.com/business/.