Governing Public-Sector AI: A Comparative Study of Saudi Arabia and the United Kingdom
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Date
2026
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Publisher
Saudi Digital Library
Abstract
Artificial intelligence (AI) has moved from a largely technical domain to the centre of global legal
and policy debates . Today, AI systems include search engines, recommendation systems, and an
emerging class of generative and “frontier” models that can produce text, code, images, and other
content at scale. These systems create opportunities for economic growth, efficiency, and public-
sector innovation, but they also give rise to complex risks for safety, fundamental rights, and
security. This dissertation focuses specifically on the use of AI by government and public-sector
bodies rather than attempting to cover all private-sector applications.
States and international organisations have begun to develop principles and legal frameworks to
govern these risks under the banner of “trustworthy” or “responsible” AI. Saudi Arabia and the
United Kingdom occupy distinctive positions within this emerging global landscape. Saudi Arabia
has framed AI as a core enabler of its Vision 2030 economic diversification agenda and has created
a centralized institutional structure through the Saudi Data and Artificial Intelligence Authority
(SDAIA), supported by the National Data Management Office (NDMO) and other digital
regulators. The National Strategy for Data and AI (NSDAI) sets ambitious targets for AI-driven
growth and capacity building. Moreover, SDAIA has adopted national AI ethics principles and
guidance intended to shape both public and private sector deployment .
By contrast, the UK has presented itself as a global leader in “pro-innovation” AI governance. The
2021 National AI Strategy and the 2023 White Paper “A pro-innovation approach to AI regulation”
articulate a model that avoids a single comprehensive AI statute and instead relies on existing
regulators applying a common set of AI principles within their respective mandates. The
establishment of a dedicated AI safety body, the AI Security Institute, signals an increasing focus on
advanced AI safety and international cooperation, even in the absence of a full AI Act .
Both jurisdictions seek to be AI leaders through different institutional designs and regulatory
techniques. This dissertation uses these differences to examine how states can pursue innovation
while managing the risks and societal impacts of AI.
Description
The overarching aim of this dissertation is to analyze and compare the regulatory frameworks that
govern AI in Saudi Arabia and the United Kingdom specifically in public-sector decision-making. It
also attempts to evaluate the functional strengths and weaknesses of each model as tools for
managing AI-related risks while enabling innovation. The central research question is:
How do Saudi Arabia and the United Kingdom regulate the design and deployment of artificial
intelligence in public-sector decision-making, and what do their respective approaches reveal about
the possibilities and limits of harmonizing AI governance across different legal and political
systems?
In order to answer this question in a structured way, the dissertation asks a series of sub-questions:
1. Legal architecture for public-sector AI
How is responsibility for governing public-sector uses of AI allocated among institutions in
Saudi Arabia and the UK, and what are the main sources of legal authority that apply when
public bodies design, procure or deploy AI systems?
2. Risk and safety in government decision-making
How does each jurisdiction conceptualise and manage AI-related risks in public-sector decision-
making? These include safety, security and human rights impacts.
3. Data governance
How do the Saudi Personal Data Protection Law and the UK’s data protection regime structure
the use of personal data in public-sector AI systems, particularly for profiling and automated
decision-making?
4. Accountability, transparency, and remedies
What mechanisms exist in each jurisdiction to ensure transparency, explainability and
contestability of AI-assisted public decisions, and what forms of administrative or judicial
oversight are available where individuals are harmfully affected?
5. Harmonisation
How far do global AI governance initiatives and soft-law instruments shape public-sector AI in
Saudi Arabia and the UK, and where do the differences in legal culture, political structure and
administrative traditions lead to different regulatory choices?
Keywords
Comparative study, AI regulation
Citation
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