AI Governance: Comparative Analysis of the European Union and Chinese Normative Frameworks on Generative Artificial Intelligence

This thesis aims at providing a general overview of AI governance, using a comparative approach and with a particular focus on the regulations enacted in the European Union and in the People’s Republic of China (PRC). The body text is structured in three chapters. The first chapter presents the broad context around artificial intelligence, with specific attention given to generative artificial intelligence, providing relevant definitions, explaining the risks that can emerge from the use of this technology and tracing the evolution of AI governance worldwide. The second chapter is divided into two sections; one is dedicated to the regulations promulgated in the European Union while the second one introduces China’s normative framework. Each section analyses one relevant regulation and a supporting policy: the “Ethics Guidelines for Trustworthy AI” (2019) and the “Artificial Intelligence Act” (2024) in the case of the EU, the “Regulations on the Interim Measures for the Management of Generative AI Services” (2023) and the “Global AI Governance Action Plan” (2025) in the case of the PRC. Along with an analysis of the contents of each regulatory framework, a small part is also dedicated to describing the issuing bodies. The final chapter offers a preliminary comparative analysis of the different regulatory approaches presented in the second chapter, highlighting points in common as well as significant divergences. Finally, a section is included discussing the long-term impact and shared global challenges in the field of AI governance.