Redefining China’s Approach to AI Governance: Beyond Top-Down, Government-Led, and Command-and-Control

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China’s approach to AI governance has been described as top-down and government-led, relying on command-and-control to pursue state-centered objectives. Drawing on an original corpus of primary sources, this Article challenges this narrative. First, AI governance in China exhibits federalism-like features, with local governments playing important roles and adopting regulatory approaches distinct from those of the central government. Second, market players are active co-regulators and strategic bargainers in the iterative governance process. Third, China’s diverse objectives and methods extend beyond what a command-and-control model can capture. Together, these dynamics reveal a polycentric and layered governance structure. These findings offer a more nuanced and contextual understanding of China’s AI governance, countering simplified geopolitical narratives and helping identify common ground for global cooperation.