IDEAS home Printed from https://ideas.repec.org/a/aza/jdpp00/y2026v8i4p374-396.html

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

Author

Listed:
  • Goh, Lanx

    (Prudential, Singapore)

  • Francis, Vinni Kalra

    (Prudential, India)

Abstract

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/.

Suggested Citation

  • Goh, Lanx & Francis, Vinni Kalra, 2026. "Comparative analysis of AI and privacy laws in Europe and Asia : Identifying regulatory disparities and pathways for harmonisation," Journal of Data Protection & Privacy, Henry Stewart Publications, vol. 8(4), pages 374-396, May.
  • Handle: RePEc:aza:jdpp00:y:2026:v:8:i:4:p:374-396
    as

    Download full text from publisher

    File URL: https://hstalks.com/article/11492/download/
    Download Restriction: Requires a paid subscription for full access.

    File URL: https://hstalks.com/article/11492/
    Download Restriction: Requires a paid subscription for full access.
    ---><---

    As the access to this document is restricted, you may want to

    for a different version of it.

    More about this item

    Keywords

    ;
    ;
    ;
    ;
    ;
    ;
    ;
    ;
    ;
    ;
    ;
    ;
    ;

    JEL classification:

    • K2 - Law and Economics - - Regulation and Business Law

    Statistics

    Access and download statistics

    Corrections

    All material on this site has been provided by the respective publishers and authors. You can help correct errors and omissions. When requesting a correction, please mention this item's handle: RePEc:aza:jdpp00:y:2026:v:8:i:4:p:374-396. See general information about how to correct material in RePEc.

    If you have authored this item and are not yet registered with RePEc, we encourage you to do it here. This allows to link your profile to this item. It also allows you to accept potential citations to this item that we are uncertain about.

    We have no bibliographic references for this item. You can help adding them by using this form .

    If you know of missing items citing this one, you can help us creating those links by adding the relevant references in the same way as above, for each refering item. If you are a registered author of this item, you may also want to check the "citations" tab in your RePEc Author Service profile, as there may be some citations waiting for confirmation.

    For technical questions regarding this item, or to correct its authors, title, abstract, bibliographic or download information, contact: Henry Stewart Talks (email available below). General contact details of provider: .

    Please note that corrections may take a couple of weeks to filter through the various RePEc services.

    IDEAS is a RePEc service. RePEc uses bibliographic data supplied by the respective publishers.