In High Wire: How China Regulates Big Tech and Governs Its Economy (2024), Angela Huyue Zhang examines China’s regulatory approach, comparing it with developments in the United States and the European Union. She argues that, despite differences in political and economic structures, China faces regulatory challenges similar to those confronting Western systems. Zhang frames this comparison along three core dimensions: shared regulatory problems, divergent governing philosophies, and patterns of mutual influence, emphasizing that regulatory approaches are neither entirely isolated nor entirely convergent. Her analysis provides a foundation for understanding how global experiences in governing technology intersect with domestic priorities, offering insights into the complexities of regulation in an interconnected world.
Common Challenges in Regulating Big Tech: China, the United States, and the European Union
Across China, the United States, and the European Union, regulators confront remarkably similar challenges posed by the rise of Big Tech. Angela Huyue Zhang emphasizes that while China’s regulatory approach may appear exceptional in execution, the underlying concerns—market concentration, data exploitation, labor precarity, and the difficulty of keeping pace with rapidly evolving digital platforms—are shared globally. These structural issues highlight the ways in which platform capitalism strains legal and policy frameworks, regardless of political system.
Antitrust regulation illustrates these shared difficulties. In all three jurisdictions, authorities grapple with the limitations of traditional market-definition tools when applied to multi-sided platforms. Debates in the US and EU about abandoning rigid market definitions mirror the dilemmas faced by Chinese regulators, demonstrating that the core challenge lies in adapting enforcement mechanisms to the realities of digital markets rather than in political philosophy alone.
Data governance represents another area of convergence. Regulators everywhere contend with cross-border data flows, surveillance risks, and the dominance of platforms over personal information. Although each system frames these risks differently—privacy in the EU, security in the US, sovereignty in China—the underlying challenge of managing personal data in a globalized digital economy is shared, requiring inventive policy solutions that balance innovation, control, and protection.
Labor regulation further underscores common struggles. Algorithmic management and the rise of gig work erode traditional labor protections across democratic and authoritarian contexts alike, creating enforcement gaps that regulators are only beginning to address. Taken together, these examples support Zhang’s argument that China’s tech crackdown should not be understood solely as a product of authoritarian ambition; rather, it reflects global pressures and regulatory stress inherent to governing platform-driven economies.
Contrasting Approaches: Regulatory Philosophies and Institutional Design in China, the US, and the EU
While China, the United States, and the European Union face similar challenges in governing Big Tech, their regulatory philosophies and institutional structures diverge sharply. Zhang, drawing on Anu Bradford’s framework, highlights that these differences reflect contrasting priorities and governance models rather than variations in the underlying problems. In the United States, regulation is market-centric: authorities prioritize competition and consumer welfare, relying heavily on courts and adversarial litigation. Enforcement is fragmented and often slow, constrained by procedural safeguards, political gridlock, and the emphasis on due process.
In contrast, the European Union adopts a rights-based approach, foregrounding citizen and consumer protections. Through sweeping ex ante instruments such as the Digital Markets Act and the Digital Services Act, the EU seeks to proactively discipline dominant platforms, emphasizing preventive regulation over reactive enforcement. China, by comparison, operates under a state-centric model in which the government sits at the apex of authority. Regulatory agencies wield administrative power to act swiftly, facing fewer judicial constraints, and prioritize substantive outcomes over procedural legitimacy.
Zhang’s “dynamic pyramid model” captures the functional logic of China’s system, explaining how its hierarchical structure, volatility, and occasional fragility produce sudden regulatory shifts. While such swings are far less common in Western systems, they aim to address similar governance failures, demonstrating that divergent institutional designs often reflect different pathways to managing shared regulatory challenges rather than entirely distinct objectives.
Antitrust Governance in the Age of Big Tech: Converging Pressures and Divergent Responses
Antitrust regulation occupies a central place in Angela Zhang’s analysis of how states respond to the growing power of digital platforms. She argues that China’s competition concerns are not fundamentally different from those confronting the United States and the European Union. Across jurisdictions, the rapid expansion of platform firms has generated market concentration, barriers to entry, and declining competitive dynamism. China’s experience with dominant firms such as Alibaba and Tencent parallels Western anxieties about “superstar” technology companies—including Google, Amazon, Meta, Apple, and Microsoft—that entrench their market positions and suppress innovation.
In this respect, China’s regulatory turn reflects a broader global movement to rein in monopolistic behavior. The European Union’s Digital Markets Act, which imposes ex ante obligations on designated gatekeepers, echoes China’s use of administrative penalties and merger controls to curb anti-competitive practices. High-profile enforcement actions—such as China’s substantial fines on Alibaba and Meituan—mirror Western efforts to discipline dominant firms through structural remedies and sanctions. Zhang emphasizes that the digital economy has produced unprecedented challenges, including income inequality and market entrenchment, prompting a shared international push to regulate Big Tech.
Despite these common pressures, China’s antitrust enforcement is shaped by distinctive institutional features. Its hierarchical political system allows top leadership to initiate sudden and sweeping interventions, as seen during the 2020–2022 regulatory campaign aligned with the “common prosperity” agenda. Unlike the United States’ litigation-heavy, court-centered process or the European Union’s rights-oriented and procedurally dense framework, China relies heavily on administrative discretion and faces fewer judicial constraints. This design enables rapid action but also introduces significant volatility into the regulatory environment.
Zhang concludes that China is, in many respects, catching up with global antitrust trends, borrowing tools and concepts from Western models while adapting them to domestic priorities. However, the concentration of political authority amplifies regulatory fragility, increasing the risk of overcorrection, information gaps, and unintended economic consequences such as market panic. Antitrust regulation thus illustrates a broader pattern in Zhang’s account: while the challenge of controlling monopoly power is universal, China’s centralized governance structure makes its enforcement both more forceful and more erratic than its Western counterparts.
Comparative Approaches to Data Governance in China, the United States, and the European Union
Across China, the United States, and the European Union, data regulation has emerged as a central policy challenge driven by the explosive growth of digital platforms and large-scale data extraction. Zhang highlights shared problems across these jurisdictions, including pervasive data exploitation by technology firms, the rise of underground data markets, and mounting threats to individual privacy amid ubiquitous data collection. In China, companies such as Tencent and ByteDance accumulate vast quantities of personal data, producing negative externalities that often extend beyond direct users. These dynamics closely resemble Western patterns of surveillance capitalism associated with firms like Meta and Google. Despite differing legal traditions, all three regions face persistent regulatory gaps, particularly in addressing algorithmic exploitation and the concentration of wealth generated through data monetization.
The European Union and the United States have pursued distinct but influential regulatory responses. The EU’s General Data Protection Regulation (GDPR), enacted in 2018, places strong emphasis on individual rights, consent, and accountability, while recent discussions on data localization further extend its regulatory reach. The United States, by contrast, relies on a fragmented, sector-specific approach, exemplified by state-level initiatives such as California’s Consumer Privacy Act (CCPA), and lacks a comprehensive federal privacy framework. Both systems nonetheless struggle to fully constrain corporate power or to mitigate inequality arising from the commercial use of data, reinforcing the sense of shared structural challenges in data governance.
China’s data regulatory regime, while influenced by the GDPR, reflects a fundamentally different political and institutional logic. Laws such as the Personal Information Protection Law and the Data Security Law, both enacted in 2021, prioritize data sovereignty, national security, and state control. Regulatory bodies like the Cyberspace Administration of China operate within a hierarchical system that allows data rules to be deployed for broader objectives, including political stability, content control, and resistance to foreign influence. Episodes such as the 2021 cybersecurity review and subsequent penalties imposed on Didi illustrate the volatility of this approach: periods of regulatory leniency that enable rapid platform growth can quickly give way to severe crackdowns triggered by political or social tipping points.
Zhang concludes that data regulation is increasingly shaped by transnational interactions and spillover effects. Western moves toward tighter data governance and localization have prompted reciprocal measures in China, including stricter controls on cross-border data flows used as strategic bargaining tools. While China shares with the US and EU the core challenge of balancing innovation with privacy protection, its state-centric and comparatively fragile regulatory system carries a heightened risk of overreach. Rather than correcting inequalities produced by data-driven capitalism, such an approach may ultimately entrench them further, underscoring the unresolved tensions at the heart of contemporary data governance.
Governing Work in the Platform Economy: Divergent Paths of Labor Regulation
Labor regulation has become a central concern in the digital economy as platform-based work expands across China, the United States, and the European Union. Zhang identifies a set of shared challenges that cut across these systems, most notably algorithmic exploitation, weak social protections, and structural barriers to collective action. In China, delivery drivers working for platforms such as Meituan face unstable incomes, opaque management by algorithms, and limited recourse against unfair practices. These conditions closely parallel those experienced by gig workers in the West, including Uber drivers in the United States or delivery workers employed through European platforms, underscoring the global nature of labor precarity under digital capitalism.
Western regulatory responses illustrate different strategies for addressing these problems. The European Union has pursued a rights-based approach, exemplified by the proposed Platform Work Directive in 2021, which seeks to reclassify certain gig workers as employees entitled to social benefits and collective bargaining rights. In the United States, labor regulation has largely unfolded through state-level initiatives and litigation, such as California’s AB5 law in 2019, aimed at correcting worker misclassification. Despite these efforts, debates persist over enforcement, corporate resistance, and the limits of legal reform in curbing inequality, suggesting that even relatively pluralistic systems struggle to discipline platform power.
China’s approach to labor regulation reflects a markedly different institutional logic. Policy responses, including the 2021 guidelines on protecting gig workers, are driven by top-down directives aligned with the Chinese Communist Party’s broader agenda of “common prosperity.” However, Zhang emphasizes that enforcement is highly uneven and volatile. Long periods of bureaucratic inaction often give way to symbolic or selective crackdowns that generate public visibility but yield limited structural change. Local courts and labor institutions remain weak, while regulatory interventions can produce unintended consequences, such as layoffs or platform retrenchment, that further destabilize employment.
In her conclusion, Zhang argues that China selectively borrows from Western regulatory trends, particularly the growing emphasis on correcting power imbalances in platform labor. Yet these ideas are reshaped within an authoritarian and state-centered framework that prioritizes economic stability and political control over participatory rights. While China shares with the US and EU the persistent challenges of inequality and worker exploitation in the platform economy, the suppression of worker voices and collective action renders labor reform more hierarchical and less inclusive. As a result, labor regulation in China remains fragile, reactive, and constrained by political imperatives that limit its transformative potential.
Regulating Generative Artificial Intelligence in Comparative Perspective
Generative AI regulation has emerged as a natural extension of earlier debates on data and platform governance, as governments confront the social and political risks posed by rapidly advancing artificial intelligence. In Chapter 11, Zhang emphasizes that China, the United States, and the European Union face largely shared challenges, including algorithmic bias, privacy violations, misinformation, liability for harmful outputs, and the phenomenon of AI “hallucinations” and deepfakes. China’s Interim Measures on Generative AI issued in 2023 reflect this convergence, echoing the EU’s risk-based AI Act and the United States’ 2023 Executive Order by emphasizing safety, transparency, and the accuracy of AI-generated content.
Despite these similarities, China’s regulatory approach is shaped by distinctive institutional and political priorities. While the EU foregrounds individual rights and accountability, and the United States adopts a comparatively permissive stance to preserve innovation, China places particular emphasis on content control and ideological alignment to maintain social and political stability. The generative AI framework explicitly requires outputs to conform to officially sanctioned values, underscoring the role of hierarchy and nationalism in Chinese governance. Zhang highlights the volatility of this system: early drafts of the regulations were notably stringent, but the final measures were softened to encourage technological development, reflecting pressure from stakeholders such as the Ministry of Industry and Information Technology and local governments heavily invested in AI growth.
Zhang concludes that China is not an outlier in confronting the risks posed by generative AI. Like Western jurisdictions, it grapples with profound and potentially existential challenges arising from powerful new technologies. What distinguishes China is not the nature of the risks themselves, but the state-centric manner in which regulation is designed and adjusted. This adaptive yet politically driven approach allows for rapid shifts in policy, but it also introduces regulatory fragility, as sudden changes can unsettle firms, researchers, and society more broadly in the evolving landscape of generative artificial intelligence.
Regulatory Convergence and Interdependence in Comparative Governance
A central insight in Zhang’s analysis is the growing regulatory convergence between China and Western jurisdictions, particularly the United States and the European Union, despite China’s explicit rejection of Western political norms. Chinese regulators in areas such as antitrust and data governance closely monitor debates and reforms unfolding in the US and EU, selectively borrowing regulatory concepts and policy tools. Ideas such as ex ante regulation of dominant platforms, heightened scrutiny of “killer acquisitions,” and skepticism toward platform self-preferencing have increasingly entered Chinese regulatory discourse, signaling a shared diagnosis of platform power and market concentration.
This convergence is evident in specific policy initiatives. Proposals by China’s State Administration for Market Regulation to relax traditional market-definition requirements closely resemble reforms advanced under the EU’s Digital Markets Act. Yet, as Zhang emphasizes, similarity in form does not imply equivalence in practice. Chinese enforcement remains more discretionary, less transparent, and more closely tied to administrative authority than its European counterpart, reflecting fundamental differences in institutional design and legal accountability.
At the same time, regulatory interdependence is reinforced by geopolitical rivalry. Expanding US assertions of extraterritorial data jurisdiction and broader strategic competition have pushed China toward stricter data localization requirements and sovereignty-based controls. While these measures often align China’s regulatory outcomes with Western trends, their underlying justifications diverge sharply, rooted in national security and state sovereignty rather than individual rights. Zhang thus illustrates how global regulatory convergence coexists with political divergence, producing a landscape in which interdependence shapes governance even amid intensifying strategic conflict.
Final Thoughts
Zhang concludes that China’s regulatory system differs from those of the United States and the European Union in degree rather than in kind. Like its Western counterparts, China operates on a precarious balancing act among innovation, economic growth, regulatory control, and political legitimacy. It confronts the same underlying anxieties surrounding platform power, inequality, and technological disruption, and it selectively borrows from Western regulatory innovations to address these challenges. What distinguishes China, however, is the absence of stabilizing institutions such as independent courts, a free press, and an autonomous civil society, which in liberal systems help moderate regulatory excess and provide feedback.
As a result, China’s approach is shaped by centralized political authority and bureaucratic incentives that concentrate both power and risk. The regulatory outcomes are not fundamentally alien to global trends, but rather represent a compressed, state-driven version of platform governance, in which familiar problems are managed through more hierarchical and interventionist means. This configuration allows for rapid policy shifts and decisive action, yet it also heightens fragility, as similar regulatory dilemmas are addressed without the institutional buffers that cushion experimentation and error in Western systems.
References
- High Wire: How China Regulates Big Tech and Governs Its Economy. Angela Zhang, 2024