COMPARATIVE APPROACH TO THE LEGAL STATUS OF ARTIFICIAL INTELLIGENCE: THE EXPERIENCE OF THE EUROPEAN UNION AND UZBEKISTAN

Abstract

In this scientific article, the issue of the status of artificial intelligence as a legal entity is studied on the basis of a comparative legal analysis using the example of the legislation of the European Union and Uzbekistan. The study analyzes key EU documents such as the “AI Act,” “AI Liability Directive,” and “General Data Protection Regulation (GDPR),” highlighting their role in regulating AI systems by risk level, protecting human rights, and determining accountability. Also, special legal regimes created in the field of AI based on the adopted strategy “Digital Uzbekistan-2030,” the strategy “Development of Artificial Intelligence Technologies until 2030,” the Regulation “On the Procedure for Establishing a Special Regime for Supporting Artificial Intelligence Technologies and Establishing its Activities,” and new draft laws in the Republic of Uzbekistan were analyzed. The results indicated that the EU model relies on a human-centered, risk-based approach, while the Uzbek model is focused on innovation, economic growth, and technological independence. At the end of the article, the need for Uzbekistan to integrate the principles of risk-based regulation, transparency, and accountability into national legislation, using EU experience, is substantiated.