REGULATING ARTIFICIAL INTELLIGENCE IN CORPORATE GOVERNANCE: A COMPARATIVE OVERVIEW OF THE UNITED STATES, THE EUROPEAN UNION, AND UZBEKISTAN

Abstract

Artificial intelligence is transforming how companies make decisions, run internal controls, and handle disclosure throughout every leading economy. Even so, the legal regimes that determine how firms use AI within their governance structures vary widely from one jurisdiction to another. This article presents a brief comparative survey of three distinct models. The United States has developed a fragmented, multi-tiered system resting on voluntary federal benchmarks, sector-specific securities oversight, and competing state statutes, more recently layered with an executive-branch effort to assert federal preemption. The European Union has chosen a horizontal, risk-graded approach in its 2024 AI Act, reinforced by the General Data Protection Regulation and the Digital Omnibus simplification package of November 2025. Uzbekistan has advanced quickly from strategic planning under Presidential Resolution PP-358 of October 2024 to a wide-ranging AI statute cleared by the Senate in November 2025, though several corporate-governance shortcomings persist. After charting each system, the article draws out six broad proposals for reform in Uzbekistan, centered on risk classification, board-level supervision, disclosure, developer–deployer liability, institutional capacity, and international alignment.