Publication Type
Book Chapter
Version
acceptedVersion
Publication Date
10-2025
Abstract
Comparative analysis of European and certain Asian approaches to governance often degenerates into simplistic dichotomies based on universal human rights assumptions. This chapter rejects such dualities, ill-informed by theory and historical reflection. The emerging argument is founded on a historical realist approach to theorising difference. Assisted by Polanyi’s double movement, the detailed substantive comparison is preceded by considerations of how recent trends in governing AI have uniformly adopted a countermovement against the dis-embedding of data and technology from the social leading to a risk/responsibility paradigm. From here, a more nuanced reflection of AI governance approaches in the EU and Singapore is offered, wherein frontier technologies are preferred for economic growth and governance is tempered by subtly different understandings of risk qualified by a common desire for achieving economic and social betterment. Rather than expressing a preference for either approach, the chapter concludes that a more convincing comparative analysis requires focusing on structural, organisational and interactive/situational perspectives when directed to a complex dynamic such as AI deployed in particular community settings.
Keywords
AI governance, European Union, Singapore, comparative analysis
Discipline
Artificial Intelligence and Robotics | Asian Studies | Intellectual Property Law | Science and Technology Policy
Research Areas
Public Interest Law, Community and Social Justice
Publication
The European Artificial Intelligence Act
Volume
78
Editor
V. L. Raposo
First Page
473
Last Page
500
ISBN
9783031984068
Identifier
10.1007/978-3-031-98406-8_17
Publisher
Springer Nature
City or Country
Cham
Citation
LOO, Huijun,Jane and FINDLAY, Mark.
Juxtaposing approaches to risk-based AI governance in different ‘rights’ contexts: A comparative analysis between Singapore and the EU. (2025). The European Artificial Intelligence Act. 78, 473-500.
Available at: https://ink.library.smu.edu.sg/sol_research/4679
Copyright Owner and License
Authors
Creative Commons License

This work is licensed under a Creative Commons Attribution-NonCommercial-No Derivative Works 4.0 International License.
Additional URL
https://doi.org/10.1007/978-3-031-98406-8_17
Included in
Artificial Intelligence and Robotics Commons, Asian Studies Commons, Intellectual Property Law Commons, Science and Technology Policy Commons