Legal Aspects of Artificial Intelligence Regulation: A Comparative Analysis of the European Union and the United States of America

This bachelor's thesis focuses on a comparative analysis of the legal regulation of artificial intelligence in the European Union and the United States of America. The aim is to compare both approaches, identify their main differences, strengths and weaknesses, and assess their impact on citizens and the business environment. The thesis analyzes the European Artificial Intelligence Act, which introduces harmonized rules for AI systems based on their risk level, emphasizing the protection of fundamental rights and safety. In contrast, the American approach is more flexible, relying on sector-specific regulation and promoting innovation with minimal legislative intervention, as exemplified by the Blueprint for an AI Bill of Rights. The comparative analysis shows that the European model provides a higher degree of legal certainty and protection of fundamental rights, while the American model supports faster technological development. However, both models face challenges — the EU risks overregulation and slowed innovation, while the US faces issues with insufficient rights protection and regulatory fragmentation. The thesis concludes with recommendations suggesting possible paths for mutual inspiration and international cooperation, aiming to create an effective and balanced framework for the regulation of artificial intelligence on a global scale.