Policies and Legal Frameworks for AI Governance: A Comparative Study of the European Union, Singapore, and Thailand

Abstract

        Artificial Intelligence (AI) has become a driving force in economic and social development worldwide. This article explores the regulatory frameworks and legal challenges in governing AI through a comparative study of the European Union (EU), Singapore, and Thailand. The study focuses on four critical legal dimensions: AI ethics and accountability, AI impact assessment, data privacy, and international alignment. The EU leads with a binding regulatory regime through the European Union Artificial Intelligence Act (EU AI Act) and the EU General Data protection Regulation (GDPR), emphasizing risk-based governance, transparency, and human oversight. Singapore, while lacking a specific AI law, has adopted a voluntary governance framework supported by tools like AI Verify, coupled with a flexible data protection regime under the Singapore Personal Data Protection Act 2012 (Singapore PDPA). Thailand, although developing its National AI Strategy and drafting the AI Innovation Promotion Bill, still lacks concrete provisions addressing ethical standards, risk assessments, and integration with data privacy law. This paper argues for Thailand to reform its legislative and policy instruments to align with international standards and ensure responsible, trustworthy, and sustainable AI development.