Comparative Study of AI Ethics Frameworks in Europe vs. North America

Abstract

As artificial intelligence (AI) adoption accelerates across industries, ethical frameworks are critical to ensure responsible use, protect stakeholders, and maintain public trust. This study conducts a comparative analysis of AI ethics frameworks in Europe and North America, focusing on regulatory approaches, organizational policies, and practical implementation. Using a mixed-methods approach, including policy analysis, case studies of 50 companies, and interviews with AI practitioners, the research identifies key differences between the regions. European frameworks, shaped by regulations such as the General Data Protection Regulation (GDPR) and proposed AI Act, prioritize transparency, accountability, and data privacy, with strict compliance obligations. North American frameworks, in contrast, are largely industry-led and emphasize innovation, flexibility, and competitive advantage, with less formal regulatory oversight. While European approaches foster trust and legal certainty, North American strategies encourage rapid AI deployment but pose ethical and reputational risks. The study offers recommendations for harmonizing ethical standards, including cross-regional collaboration, adaptive governance models, and the integration of ethical AI toolkits into corporate decision-making. Findings provide insights for policymakers, managers, and researchers on balancing innovation with ethical responsibility in global AI deployment.