인공지능기본법 추진체계에 대한 검토 및 발전방향 — EU, 영국, 일본의 거버넌스를 중심으로 —

This study aims to present the developmental directions of the governance system under the Artificial Intelligence (AI) Framework Act in order to overcome the challenges currently faced by the Act and to enhance its competitiveness within the global AI governance landscape. As competition over AI technological hegemony intensifies, major countries are establishing diverse forms of governance to secure technological leadership. In Korea, the AI Framework Act, officially enacted in January 2025, has laid the foundation for AI governance by incorporating both a support system for AI promotion and regulatory mechanisms for ensuring trustworthiness. However, because the Act adopts a horizontal and comprehensive regulatory framework, concerns have been raised that excessive and overlapping regulations may create regulatory barriers and hinder innovation. Given the dynamic convergence of AI with various sectors of society, the limits of a purely comprehensive regulatory framework call for complementary vertical regulations under sector-specific legislation. In this regard, an AI control tower plays a critical role in effectively resolving regulatory overlaps and conflicts among different ministries. Accordingly, this study reviews governance models in the EU, the UK, and Japan, and draws implications for the improvement of Korea’s AI governance system. First, a cross-ministerial control tower should be established to address conflicts between the horizontal, comprehensive regulatory framework of the AI Framework Act and vertical, sector-specific regulations. This could involve transferring the National AI Committee under the Prime Minister’s Office or creating an independent regulatory body. Second, the National AI Committee must be empowered with substantive authority while ensuring the participation of diverse stakeholders, including the private sector, in its decision-making process. Upgrading the committee from an advisory body to a collegial central administrative agency would enable it to exercise policy coordination and budget deliberation powers, while enhancing expertise and rationality through inclusive governance. Third, strengthening global governance competitiveness requires the active use of standards. Drawing on cases such as the EU’s harmonized standards, the UK’s AI Standards Hub, and Japan’s engagement with international standardization, Korea should reinforce AI standardization research and international cooperation through the AI Safety Research Institute. This will reduce regulatory uncertainty and enhance both technological and regulatory competitiveness on the global stage.