Pakistan’s National AI Policy 2025: A Comparative Analysis with US, EU, and China’s AI Governance Frameworks

Abstract

Artificial Intelligence (AI) governance has evolved into a core issue for comparative public policy but, much of the scholarship has concentrated upon the United States (US), the European Union (EU), and China. Much less emphasis has been placed upon how emerging states create their own AI policy relative to these competitive governance models. The study fills this void by comparing the Pakistan’s National AI Policy (2025) using comparative policy analysis. By applying Qualitative Comparative Policy Analysis the National AI Policy of Pakistan is compared to the AI governance models of the US, EU, and China based upon seven dimensions: governance philosophy, legal and regulatory style, risk, ethics, privacy, and rights, institutional architecture and oversight, innovation and industrial policy, human capital and capacity development, and implementation and enforcement. The study utilizes comparative public policy and policy emulation as theoretical bases. The findings show that the Pakistan’s National AI Policy 2025 can be better understood as a hybrid governance framework as opposed to simply being an externally sourced derivative model. In terms of philosophical approach, the policy incorporates the "innovation" and "ecosystem" terminology commonly found in US-based innovation and technology strategy. In addition, the policy includes "rights", "ethics", and "privacy" terminology similar to that found within EU-based AI governance initiatives. Finally, the policy reflects strategic planning logic consistent with China's state-led economic development approaches. However, the authors conclude that the policy's potential success will likely rely less upon the scope of its ambitions then upon the government's ability to establish and enforce institutional arrangements which support those ambitions. Therefore, the findings from this case contribute to comparative AI governance by demonstrating that emerging state AI governance policies are formed at the same time they are subject to both international policy learning opportunities and domestic development challenges.