A Rights-Based Approach to Artificial Intelligence : An Analysis of Regulatory Measures in the European Union, the United States, and China

This study adopts a rights-focused perspective to evaluate how Artificial Intelligence (AI) is regulated in the European Union, the United States, and China through a legal analysis. It uses a three-jurisdiction framework to examine the EU AI Act, assess its implications for fundamental rights and contrast it with AI regulatory approaches in the United States and China. The analysis focuses on how these legal frameworks safeguard fundamental rights and structure accountability in the development and deployment of AI systems. Drawing on doctrinal analysis of existing regulations, legal documents, case law and academic literature, the study identifies significant differences in regulatory strategies — ranging from rights-based and risk-based models to more security driven and market driven approaches. It concludes with recommendations for regulatory convergence and policy harmonisation aimed at strengthening human rights protection, transparency and accountability in AI governance.