Sovereign AI Doctrine

Regulatory approaches

Only two catalogued instruments govern this topic explicitly, and they regulate by sharply different modalities. China's Interim Measures for the Management of Generative AI Services (effective 2023-08-15) bind deployment to the jurisdiction through registration and gatekeeping rather than infrastructure: Article 17 requires providers whose services have "public opinion attributes or social mobilization capacity" to complete a security assessment and an algorithm-filing procedure with the Cyberspace Administration of China before launch, while Article 7 obliges providers to use training data and foundation models from "lawful sources" (China Interim Measures 2023, arts. 7, 17). The lever is administrative permission, not domestic-compute mandates. The (now-rescinded) U.S. Executive Order 14110 instead engaged the compute layer through Commerce reporting requirements: §4.2 directed reporting on dual-use foundation models and large computing clusters and imposed know-your-customer-style rules on infrastructure-as-a-service providers (EO 14110 2023, §4.2). That choice tracks an argument that compute is a uniquely governable lever because it is "detectable, excludable, and quantifiable, and is produced via an extremely concentrated supply chain" ¹. California's SB-53 operates through a third modality—public capacity-building—via CalCompute, a consortium tasked with developing a framework for a public cloud computing cluster, with operation contingent on appropriation (Cal. Gov. Code §11546.8); such public-provision moves respond to findings that "no country today has data on, or a targeted plan for, national AI compute capacity" ². These map onto three distinct sovereignty levers: permission, hardware-flow control, and public provision.

Definitional contestation

"Sovereign AI" lacks a settled meaning, and the contest over its definition is itself a governance fault line. The term entered wide circulation through NVIDIA, whose CEO framed it primarily as national capacity—"a nation's capabilities to produce artificial intelligence using its own infrastructure, data, workforce and business networks"—and urged that "every country needs sovereign AI" built on domestic "AI factories" (NVIDIA 2024, World Governments Summit remarks). Academic work treats the concept as multi-dimensional rather than singular: recent frameworks decompose it into pillars such as data, compute, models, and norms, arguing sovereignty is a continuum balancing autonomy against interdependence rather than a binary of control ³. Scholars of national AI strategies show the term is also performative—policy documents "talk AI into being" through competing sovereignty and leadership imaginaries ⁴, mobilising democratic and sociotechnical imaginaries that frame sovereign capacity as a means for democracies to overcome governance challenges ⁵. Critics further note a "sovereignty as a service" paradox, in which vendors market compliance wrappers and hardware bundles that produce the appearance of control without delivering meaningful agency (TechPolicy.Press, "Rethinking Sovereign AI as Strategy," 2025). This contestation matters because instruments invoking sovereignty may pursue incompatible aims—domestic capability, foreign-dependency reduction, or content/jurisdictional control—under one label, complicating cross-jurisdiction comparison. The definitional split is an editorial reading of the cited literature, not a claim any single source frames identically.

Trajectory / what's changing

The doctrine's principal instruments have shifted rapidly since 2025, and most movement is occurring outside the formally catalogued texts. In the United States, Executive Order 14110—the catalogued "governs" instrument—was revoked on 2025-01-20 by Executive Order 14148 and superseded by Executive Order 14179 (2025-01-23), "Removing Barriers to American Leadership in Artificial Intelligence" (signed 2025-01-23), reorienting policy from containment toward export-led leadership (Federal Register, 90 FR 8741, 2025). On 2025-05-13 the Bureau of Industry and Security rescinded the Biden-era "AI Diffusion Rule" days before its effective date, abandoning its three-tier country framework as "overly bureaucratic" (BIS / Department of Commerce announcement, 2025). The America's AI Action Plan (released 2025-07-23) then directed Commerce to stand up an American AI Exports Program promoting "full-stack" U.S. technology packages to allied states (White House, 2025). This pivot exemplifies states asserting "strategic digital sovereignty...through selective alliances with firms and other governments," fragmenting global AI infrastructure into techno-blocs ⁶. In parallel, the EU launched its InvestAI initiative on 2025-02-11, mobilising up to €200 billion including €20 billion for up to five "AI gigafactories" to secure "sovereign access" to compute (European Commission, IP/25/467, 2025)—part of a broader restructuring of land, energy and regulatory systems to sustain national computing power ⁷. The net trajectory is toward sovereignty pursued via industrial policy and alliance-conditioned exports rather than the catalogued regulatory texts.

Historical primacy & cross-jurisdiction tension

First addressed by Interim Measures for Generative AI Service Management on 2023-07-13 (governs). Subsequent regimes have either codified, diverged from, or remained silent on this baseline.

• Forum-shoppingExecutive Order 14110 on Safe, Secure, Trustworthy AI↔EU AI Act
• Forum-shoppingInterim Measures for Generative AI Service Management↔Executive Order 14179 — Removing Barriers to American Leadership in AI

Silent regimes — gap signal

Instruments that do not address Sovereign AI Doctrine — candidates for future policy work.

• EU AI ActEU
• Executive Order 14179 — Removing Barriers to American Leadership in AIUS
• UK Pro-Innovation Approach to AI Regulation (White Paper)UK
• G7 Hiroshima AI Process Code of ConductG7
• OECD AI Principles (Recommendation)OECD
• Council of Europe Framework Convention on AIcouncil_of_europe
• UN GA Resolution on Safe, Secure, Trustworthy AIUN
• NIST AI Risk Management FrameworkUS
• Bletchley Declaration on AI Safetyglobal
• Seoul Declaration on Safe, Innovative and Inclusive AIglobal
• NIST AI RMF Generative AI ProfileUS
• California SB-1047: Safe and Secure Innovation for Frontier AI Models ActUS
• India Digital Personal Data Protection Act + AI Advisory (MEITY)IN
• Brazil AI Bill (PL 2338/2023)BR
• ASEAN Guide on AI Governance and EthicsASEAN
• African Union Continental AI StrategyAfrican_Union
• Anthropic Responsible Scaling Policy (RSP) v2US
• OpenAI Preparedness FrameworkUS
• Google DeepMind Frontier Safety FrameworkUS
• Meta Frontier AI FrameworkUS
• UK-US AI Safety Institute Memorandum of Understandingglobal
• White House Voluntary AI CommitmentsUS
• Singapore Model AI Governance Framework for Generative AISG
• Japan METI AI Guidelines for BusinessJP
• General Data Protection Regulation (GDPR)EU
• EU General-Purpose AI Code of PracticeEU
• OMB Memorandum M-24-10 (Advancing Governance, Innovation, and Risk Management for Agency Use of AI)US
• GSA Generative AI and Specialized Computing Infrastructure Acquisition Resource GuideUS
• DoD Responsible AI Strategy and Implementation PathwayUS
• FedRAMP AI Cloud Procurement GuidanceUS
• DFARS Subpart 252.204 (Safeguarding Covered Defense Information and Cyber Incident Reporting)US
• California SB 243: Companion ChatbotsUS
• California SB 942: AI Transparency ActUS
• Revised Product Liability Directive (Directive (EU) 2024/2853)EU
• UNESCO Recommendation on the Ethics of Artificial IntelligenceUNESCO
• Directive (EU) 2024/2831 on improving working conditions in platform workEU
• Provisions on the Administration of Deep Synthesis of Internet Information ServicesCN
• New York RAISE Act: Responsible AI Safety and Education ActUS
• TAKE IT DOWN Act (Tools to Address Known Exploitation by Immobilizing Technological Deepfakes on Websites and Networks Act)US
• UN Global Digital CompactUN

Does governance work? — the social-science evidence

What the peer-reviewed social science shows: whether the harm this topic addresses is empirically real, and whether governance of it works. The badge is the epistemic status of the evidence(not the policy debate) — “thin” or “absent” efficacy evidence is itself a finding (the “second silence”). Each epistemic-status label is Policy Window's editorial assessment of the cited evidence base (a structured classification), not a verdict any single source issues.

• Is the harm real?evidence: thin

  Sovereign-AI doctrine is post-2023 and largely aspirational, so its core empirical premise — that frontier model deployment can be meaningfully bound to a national jurisdiction — is only just beginning to be tested. What IS measurable is the underlying compute geography the doctrine reacts to: an audit of 775 non-U.S. data-center projects estimates U.S. companies operate ~48% of them when weighted by investment value (a proxy for compute capacity, and explicitly an initial public-data approximation), implying 'in-territory' hardware is frequently still subject to foreign corporate/legal control (Richardson et al. 2025). Honest caveat: there is no peer-reviewed evidence base establishing whether jurisdiction-bound frontier deployment is technically feasible at scale — the descriptive dependency (foreign operation of locally-sited hardware) is documented, but the doctrine's central feasibility claim is thin and early.

  Sources: Richardson et al. 2025 (arXiv:2508.00932, 'How Sovereign Is Sovereign Compute? A Review of 775 Non-U.S. Data Centers'); Gupta, Walker & Reddie 2024 (arXiv:2411.14425, 'Whack-a-Chip: The Futility of Hardware-Centric Export Controls', UC Berkeley Risk & Security Lab)

• Does governance work?evidence: absent

  There is no rigorous impact evaluation showing that sovereign-AI governance achieves its stated aim of secure, contained national AI capability. The closest direct levers have measurable but mostly adverse or contested evidence: ex-ante simulations of the closest analogue — data-localization mandates — project GDP losses (EU GDP −0.4% under proposed/GDPR-style measures rising to −1.1% under economy-wide localization; Bauer, Lee-Makiyama, van der Marel & Verschelde 2014, ECIPE Occasional Paper No. 3/2014) yet quantify no realized sovereignty benefit, and chip export controls — the other main instrument — show contested efficacy: one cross-firm study finds no innovation harm to 30 leading semiconductor firms (Schumacher 2024, CSIS) while case evidence documents systematic circumvention via software/efficiency gains and chip exfiltration/smuggling (Gupta, Walker & Reddie 2024). No replicated study demonstrates that any sovereign-AI regime measurably delivers the jurisdictional control it asserts.

  Sources: Bauer, Lee-Makiyama, van der Marel & Verschelde 2014 (ECIPE Occasional Paper No. 3/2014, 'The Costs of Data Localisation: Friendly Fire on Economic Recovery'); Schumacher 2024 (CSIS, 'Did U.S. Semiconductor Export Controls Harm Innovation?'); Gupta, Walker & Reddie 2024 (arXiv:2411.14425, 'Whack-a-Chip: The Futility of Hardware-Centric Export Controls')