Diverging Paths to AI Governance: A Comparative Analysis of the EU AI Act and the U.S. AI Action Plan

This paper compares the European Union’s AI Act Guidelines (2025) and the United States’ AI Action Plan (2025) to explore how political values shape contrasting approaches to AI governance. Using the Policy Styles Framework, the study categorises the EU as following an anticipatory-impositional style, while the U.S. exhibits a reactive-conciliatory style. A comparative thematic content analysis of the two policy documents was conducted across four dimensions: risk oversight, innovation focus, compliance, and international positioning. The findings show that the EU prioritises fundamental rights, precautionary regulation, and global standard-setting, whereas the U.S. emphasizes market-driven innovation and voluntary compliance. A radar chart visualizes these differences, highlighting the divergent institutional logics underpinning each approach and their implications for transatlantic cooperation and global AI governance.