A Comparative Study of Artificial Intelligence Governance Patterns in Selected Countries

Abstract

This study employs a comparative qualitative approach to analyze AI governance patterns in seven countries (Iran, the US, China, the EU, the UK, Japan, and Singapore). Data from official documents and academic sources were analyzed across five dimensions: policy focus, regulatory approach, ethical principles, technological infrastructure, and international cooperation. The findings identify three dominant patterns: 1) State-centered (China, Singapore), emphasizing central control and large-scale investment; 2) Market-based (US), relying on decentralized innovation and voluntary standards; and 3) Participatory-rights-based (EU, UK), featuring a risk-based approach with a focus on transparency and algorithmic justice. Japan focuses on solving social challenges through voluntary innovation. Despite institutional advances, Iran faces obstacles such as sanctions and structural inconsistencies. The conclusion underscores the need for a hybrid model tailored to Iran, integrating the EU's risk-based approach, Singapore's institutional coordination, and the localization of Islamic values. Policy recommendations include developing binding ethical codes, committing to long-term investment in indigenous infrastructure, and leading regional coalitions.

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