Two paths of balancing technology and ethics: A comparative study on AI governance in China and Germany

Artificial intelligence is rapidly becoming a transformative technology on the agenda of global competition. Although it provides groundbreaking opportunities to benefit societies, the technology also evokes tremendous concerns about potential risk and harm. Mitigating such risks and turning technology into a responsible asset for humanity have been essential agendas in the emerging global architecture of AI governance. Thus, this study proposes an integrated CAMS framework of AI governance to examine the content, actors, means, and scope of AI technology regulations in China and Germany. Regarding AI governance as an active negotiation and regulatory trajectory, we investigate laws and policies on AI governance and the policy-making processes in both countries and articulate two paths of balancing technology and ethics. China adopts a utility-oriented approach featuring a state-led governance structure with complex central-local dynamics. In the Chinese model, AI technology is a driver of economic development, and ethics serves as a utilitarian tool to safeguard the advancement of technology. Germany constructs a right-based approach governed by multisectoral discussion and cooperation platforms with state supervision. In the German model, AI technology is a high-risk arena, and ethics represents the rights for which technological development should serve. This comparative study offers nuance to further understand the dynamic transformation of emerging AI governance.