Navigating the AI Regulatory Landscape: Europe vs. Southeast Asia and the Middle East

Artificial Intelligence (AI) is reshaping economies and societies across the globe, presenting both immense opportunities and regulatory challenges. As governments work to manage AI responsibly, regional differences in regulatory priorities and philosophies emerge. This article provides an overview of AI governance approaches to Europe, Southeast Asia, and the Middle East, highlighting key trends and contrasts while acknowledging that it is not possible to encompass the full complexity and diversity of policies across these regions.

Europe: Regulation grounded in precaution and ethics

The European Union has taken a methodical and risk-focused approach to AI governance. At the core of this effort is the EU AI Act, officially enacted in August 2024.[1] This legislation seeks to balance technological innovation with societal safeguards, focusing on risks to public health, safety, and fundamental rights. Transparency and non-discrimination are codified as essential principles. The act adopts a risk-based approach, categorizing AI systems into four risk levels: minimal, limited, high, and unacceptable.[2] For instance, facial recognition in public spaces is considered high-risk and is heavily regulated, while AI applications in healthcare are classified as high-risk and subject to strict oversight. [3] The European Regulation follows the principle that the higher the assessed risk associated with an AI application, the stricter the corresponding requirements occur.[4] However, critics argue that this regulatory depth may burden businesses, particularly startups, with compliance challenges that could hamper innovation.[5] Comparisons to Southeast Asia’s more flexible approaches highlight concerns that Europe’s rigidity might stifle its competitiveness in the rapidly evolving AI sector.

Europe`s General Data Protection Regulation (GDPR) further shapes its AI environment by mandating stringent data privacy protections. While the GDPR sets a global benchmark, it has also been critiqued for being overly restrictive, potentially limiting AI’s ability to leverage large datasets for innovation.

Southeast Asia: Pragmatism and growth-oriented governance

Southeast Asia, known for its dynamic digital transformation, adopts a more pragmatic and innovation-friendly approach to AI regulation.[6] The Association of Southeast Asian Nations correspondingly released a guide on AI Governance and Ethics in this regard.[7] Countries like Singapore, Indonesia, and Vietnam emphasize economic growth and technological competitiveness in their AI strategies.

Singapore stands out with its AI Governance Framework, a voluntary set of guidelines emphasizing transparency and accountability while allowing flexibility. This business-friendly model fosters innovation while addressing ethical and safety concerns. In contrast, countries like Indonesia and Thailand are still developing formal AI regulatory frameworks, focusing on digital transformation and alignment with national development goals. For example, Indonesia has launched initiatives to boost its AI capabilities, but its regulatory framework is still in progress.[8]

Malaysia is making strides toward becoming a leader in ethical AI and digital innovation as well. The government plans to establish a national cloud policy alongside regulations to encourage the responsible and sustainable use of AI. The national cloud policy will emphasize four key areas: enhancing public service efficiency, boosting economic competitiveness, reinforcing data security and user trust, and promoting digital inclusivity for citizens.[9]

Thailand has introduced a draft Royal Decree on AI System Service Businesses, reflecting influences from an earlier draft of the EU AI Act. Like its European counterpart, the Royal Decree adopts a risk-based framework that classifies AI systems into risk-categories. A distinctive feature of the Royal Decree is its proposal to establish minimum mandatory terms and conditions for its AI services, marking a unique approach to regulation service standards in the AI sector.[10]

Vietnam is in the process of drafting a Law on Digital Technology Industry, which introduces a regulatory framework for AI based on risk classification. The Ministry of Information and Communications is currently developing the classification criteria, which will consider factors such as safety, security, and the protection of legal rights and interests. Regulatory obligations, compliance measures, and technical controls will be tailored to the risk level of specific AI applications, though detailed guidelines are not yet available.[11]

Southeast Asia’s approach to regulation often involves collaboration between governments and industry stakeholders, favoring self-regulation over stringent mandates. This flexibility and more “hands-off” approach to AI[12] is appealing to investors and tech innovators but raises questions about consistency and enforcement across the region.[13]

Middle East: Innovation-Driven Strategies

The Middle East adopts a distinct approach to AI governance, focusing on innovation and national development goals. While this overview highlights key trends, it does not capture the full diversity of AI policies across the region. Unlike Europe’s ethic-driven model or Southeast Asia’s pragmatic flexibility, the region emphasizes leveraging AI for economic growth and state efficiency.

The United Arab Emirates (UAE) leads regional efforts with its UAE Strategy for Artificial Intelligence 2031, prioritizing AI integration across industries like healthcare, government, and education.[14] The UAE also established the world’s first Ministry of Artificial Intelligence, highlighting its commitment to becoming a global leader in AI.[15] Similarly, Saudi Arabia incorporates AI regulation into its Vision 2030 framework, with the Saudi Data and Artificial Intelligence Authority (SDAIA) driving standards for transparency, data ethics, and innovation.[16] While formal legislative frameworks remain limited, the Middle East relies on ethical guidelines and national strategies to regulate AI.[17] For instance, the UAE has introduced principles to ensure that AI systems are used responsibly, although enforcement mechanisms are less robust than in Europe. Data privacy regulations are uneven across the region. Countries like the UAE and Saudia Arabia have established strong data protection laws, but the use of AI for surveillance, such as facial recognition, is widespread and largely unregulated compared to Europe`s stricter standards.

Key Differences in AI Governance

In AI governance, there are notable differences between Europe and Southeast Asia and the Middle East. Europe adopts a precautionary approach, embedding ethics and human rights into its laws to proactively mitigate risks. In contrast, Southeast Asia’s growth-oriented philosophy focuses on fostering innovation, tailoring voluntary frameworks to local needs, and encouraging economic development.[18] Meanwhile, the Middle East emphasizes innovation-driven strategies, focusing on leveraging AI for economic and national development goals while adopting a more flexible regulatory approach. When it comes to enforcement, the EU uses centralized mechanisms, imposing penalties of up to 7 % of a company’s global turnover for non-compliance. Southeast Asia, however, relies on collaborative and voluntary compliance, which, while less stringent, may result in potential gaps in accountability. Regarding ethics and human rights, Europe integrates these aspects comprehensively into its legal framework, while Southeast Asia and the Middle East approach these issues more gradually, prioritizing innovation and economic growth. In terms of data privacy, Europe’s GDPR sets a global standard, whereas Southeast Asia’s regulations vary. While Singapore’s Personal Data Protection Act (PDPA)[19] is strong, countries like Vietnam and Indonesia are still in the process of strengthening their data protection laws.

Opportunities for Cross-Regional Cooperation

Despite differing approaches, Europe and Southeast Asia, and the Middle East share a mutual interest in ensuring responsible AI development. Europe’s experience with ethical regulation could guide Southeast Asia and the Middle East in crafting frameworks that balance growth with accountability. Conversely, Southeast Asia’s flexibility could inspire Europe to refine its regulatory processes to adapt to the global AI race. Collaboration on global standards, ethical AI development, and data-sharing frameworks could pave the way for responsible AI governance that benefits all regions.

Conclusion

The regulation of AI is not a one-size-fits-all endeavour. Europe’s cautious and ethics-driven model contrasts with Southeast Asia’s pragmatic, growth-oriented strategies and the Middle East’s innovation-focused approach, reflecting the unique economic and social contexts of each region. While Europe offers a structured and more risk-averse path, Southeast Asia’s adaptability and the Middle East’s strategic focus position them to quickly leverage AI’s transformative potential. All regions have valuable lessons to offer, highlighting the importance of shared learning and international cooperation in navigating the complexities of AI governance.[20]

[1] European Council, Timeline-Artificial Intelligence, 9 December 2024, https://www.consilium.europa.eu/en/policies/artificial-intelligence/timeline-artificial-intelligence/

[2] Article 6 - 8 of the AI Act.

[3] Article 5 III of the AI Act.

[4] European Commission, AI Act - Shaping Europe’s Digital Future, 14 October 2024, https://digital-strategy.ec.europa.eu/en/policies/regulatory-framework-ai.

[5] Pascale Davies, EU AI Act reaction: Tech experts say the world’s first AI law is historic, but bittersweet, 16 March 2024, https://www.euronews.com/next/2024/03/16/eu-ai-act-reaction-tech-experts-say-the-worlds-first-ai-law-is-historic-but-bittersweet.

[6] Athistha (Nop) Chitranukroh, Rada Lamsam, Comparing EU, Southeast Asia Approaches to AI Regulation, 4 July 2024, https://www.tilleke.com/insights/comparing-eu-southeast-asia-approaches-to-ai-regulation/.

[7] Association of Southeast Asian Nations (ASEAN), ASEAN Guide on AI Governance and Ethics, 2 February 2024, https://asean.org/wp-content/uploads/2024/02/ASEAN-Guide-on-AI-Governance-and-Ethics_beautified_201223_v2.pdf

[8] Nick Lauw, AI Regulation in Asia, 6 August 2024, https://www.rpclegal.com/thinking/artificial-intelligence/ai-guide/part-4-ai-regulation-in-asia/

[9] Danial Azhar, Rozanna Latiff, Malaysia plans national cloud policy, AI regulations, 1 October 2024, https://www.reuters.com/technology/google-says-its-investments-will-add-3-bln-malaysias-gdp-by-2030-create-26500-2024-10-01/

[10] AI Thailand - Thailand National AI Strategy and Action Plan (2022 - 2027), https://ai.in.th/en/about-ai-thailand/

[11] Ministry of Information and Communication Vietnam, Vietnam urged to build a legal corridor for AI industry, 25 April 2025, https://english.mic.gov.vn/vietnam-urged-to-build-legal-corridor-for-ai-industry-197240426165138552.html.

[12] Southeast Asia Public Policy Institute, Policy State of Play, Artificial Intelligence in Southeast Asia, August 2024, https://seapublicpolicy.org/work/policy-state-of-play-artificial-intelligence-in-southeast-asia/.

[13] Athistha (Nop) Chitranukroh, Rada Lamsam, Comparing EU, Southeast Asia Approaches to AI Regulation, 4 July 2024, https://www.tilleke.com/insights/comparing-eu-southeast-asia-approaches-to-ai-regulation/.

[14] United Arab Emirates, Minister of State for Artificial Intelligence, Digital Economy & Remote Work Application Office, UAE Strategy for Artificial Intelligence 2031, https://ai.gov.ae/strategy/.

[15] Omar Al Olama, I was the First AI Minister in History, 19 January 2024, https://time.com/6564430/ai-minister-uae/.

[16] Karen Silverman, Brinson Elliott, Artificial Intelligence Law, Edition 1, 17 January 2024, https://www.lw.com/admin/upload/SiteAttachments/Lexology-In-Depth-Artificial-Intelligence-Law-Saudi-Arabia.pdf.

[17] Raheel Butt, AI Watch: Global regulatory tracker – Saudi Arabia, 20 June 2024, https://www.whitecase.com/insight-our-thinking/ai-watch-global-regulatory-tracker-saudi-arabia.

[18] Nick Lauw, AI Regulation in Asia, 6 August 2024, https://www.rpclegal.com/thinking/artificial-intelligence/ai-guide/part-4-ai-regulation-in-asia/.

[19] Personal Data Protection Commission Singapore, Singapore’s Approach to AI Governance, 3 November 2023, https://www.pdpc.gov.sg/help-and-resources/2020/01/model-ai-governance-framework

[20] Olivia J. Erdélyi, July Goldsmith, Regulating Artificial Intelligence - Proposal for a Global Solution, AIES´18, February 2 -3, 2018, New Orleans, LA, USA: https://dl.acm.org/doi/pdf/10.1145/3278721.3278731