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A comparative analysis of AI policies in India and across the globe
A comparative analysis of AI policies in India and across the globe

December 6, 2023

AI

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Many political leaders and company heads believe that AI will soon become the norm in everyone’s life. From automatically playing music through speech recognition to analyzing loads of data to autonomous cars, AI has made life easier. AI is reshaping the globe, influencing economies and societies. Knowing this, countries have adopted various policies on AI to extract benefits from it while keeping into consideration the safety of people and the planet. India is also progressing towards becoming a global leader in AI, as a study by Nasscom says AI has the potential to contribute $450–$500 billion to India’s GDP by 2025, which is remarkable.

The United States does not have comprehensive legislation to regulate AI. However, various departments in the US have taken initiatives to regulate it. It is the federal agencies led by the White House that currently regulate AI. The Biden administration has created a blueprint for an “AI Bill of Rights" for 2022 for government and industry use of AI and also to protect the public from algorithmic discrimination. Thus, there is still some time for the US to come up with official legislation on AI. Till then, the invisible hand would keep on managing the AI scenario in the US.

China, on the other hand, has been investing enormously in AI and has outlined various policies to become a global leader in AI by 2030. China has one of the most extensive policies on AI vis-à-vis other countries. It covers areas such as algorithm recommendations, ethical review, and deep synthesis. In August 2023, China came up with a new law to regulate GenAI, becoming the first country in the world to explicitly manage GenAI. These rules are being viewed as quite stringent and thus could significantly impact China’s domestic AI sector as well as shape the AI policies of other countries that have yet to enact AI laws.

South Korea, known for its cutting-edge technology, seeks to become a global power in AI technologies. The “AI Act” is quite liberal in its approach, providing significant control to the users and also encouraging people to bring new tech without needing any pre-approval from the government. It also provides ethical guidelines for AI. The government is also promoting AI-based start-ups and setting up more schools and colleges to develop skills for AI. Hence, creating an enabling system for artificial intelligence.

The EU’s GDPR law is a comprehensive legal framework aimed at data protection and privacy. The heavy reliance of AI on data makes individuals vulnerable to data theft and security issues. Even though the GDPR doesn’t explicitly mention artificial intelligence, it contains provisions for the regulation of AI. GDPR gives the people of the EU greater control over their data and sets guidelines for storage and usage of data. Presently, the EU has taken the initiative to establish the “EU AI Act” for explicit regulation of AI by creating a “three-tier risk classification model." The model classifies AI systems according to the potential risks they pose to people’s fundamental rights.

India has enacted a similar law called the Digital Personal Data Protection Act, 2023. However, it gives significant control to the government over data vis-à-vis individuals, posing a threat to their right to privacy. This leaves a huge space for the misuse of AI. PDPA doesn’t provide for the right to data portability or the right to be forgotten, whereas GDPR provides for it. PDPA has set the minimum age to give consent for processing personal data to be 18 years, while it is 16 in GDPR and 13 in the USA.

Singapore is among the first countries to come up with a “national AI strategy." Consequently, a large pool of funds has been allocated for the development of AI. Recently, it announced NAIS 2.0, making it GenAI inclusive. NAIS 2.0 has twin objectives. First, to make use of AI regarding global causes like climate change and health. Second, to empower people and businesses to thrive in the AI environment. Singapore aims to become a smart nation, emphasizing AI for economic growth. Whereas, India's AI policies are more inclined towards social development and inclusivity. While major economies like the US and China are competing to become superpowers in AI, India is focusing on “AI for All.”

For instance, India has taken various initiatives in the field of AI, such as FutureSkills PRIME for upskilling and reskilling IT professionals and the Visvesvaraya PhD scheme to boost research work in AI and ML. Various Centers of Excellence (CoEs) have been created by the government for emerging technologies. India has yet to learn from other countries to formulate a policy that best meets social development requirements as well as creates an ecosystem for innovation in AI.

The international community's cooperation has become imperative to create a uniform AI policy across the world for a transparent, reliable, and innovative use of AI. Such collaboration on AI is visible in the "Bletchley Declaration 2023," attended by the US, UK, EU, China, India, and others, for innovation in AI with safety at its core. Moreover, the Global Partnership on AI (GPAI) has been established (India being among the founding members) to guide advancement in AI in accordance with human rights. Another such measure is Responsible AI for Social Empowerment (RAISE), which is a global meeting for inclusivity and social transformation through AI. With global effort, AI can be harnessed for the benefit of society. For global good.


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