Stanford Journal of International Affairs

AI Treaty Framework Proposals: Comparative Analysis of EU, US, and China’s Regulatory Approaches

AI Treaty Framework Proposals: Comparative Analysis of EU, US, and China’s Regulatory Approaches

Abhinav Agarwal, Stanford University

Abstract

This paper compares artificial intelligence (AI) regulatory frameworks in the European Union (EU), United States (US), and China, examining their impact on innovation, competitiveness, and policy diffusion. Using Organisation for Economic Co-operation and Development (OECD) and World Intellectual Property Organization (WIPO) data, we analyze investment patterns, patent filings, and inter-jurisdictional influence. Our findings reveal distinct approaches: China’s state-driven model yields high absolute outputs in investments and patents; the EU’s comprehensive, risk-based framework promotes structured innovation and global standard-setting through the “Brussels Effect”; and the US’ sector-specific approach enables market-driven innovation while creating coordination challenges. These diverging paradigms offer important policy lessons.