디지털 무역 규범의 다층 거버넌스 비교연구

Purpose – The purpose of this study is to comparatively analyze how digital trade rules are shaped and developed within the framework of multi-level governance. In particular, it explores the areas where rules converge and the areas where they diverge across the WTO multilateral framework, regional trade agreements such as CPTPP, USMCA, RCEP, and DEPA, as well as bilateral and multilateral agreements. Design/methodology/approach - This study conducts a comparative textual analysis of key provisions and institutional structures of major agreements. It further examines, from normative and institutional perspectives, how rules at different governance levels are interconnected. Findings – The findings indicate that digital trade rules have not yet consolidated into a unified international framework. Instead, diverse regulatory approaches coexist within multi-level governance. Nevertheless, certain areas reveal commonalities and institutional similarities between the WTO and mega-FTAs, particularly with regard to cross-border data flows, electronic commerce, and personal data protection. Research implications or Originality – This study contributes by moving beyond a mere listing of provisions to systematically analyze digital trade rules through the lens of multi-level governance. It also provides policy implications by suggesting that middle-power trading nations, including Korea, should consider the interactions of multi-level governance and the negotiation power gap when participating in digital trade rule-making.