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AI Governance Capacity in Public Administration: A Comparative Analysis of the EU and Türkiye
Abstract
This study compares artificial intelligence (AI) governance in public services in the European Union (EU) and Türkiye, focusing on institutional design and administrative capacity. Through a comparative institutional–legal analysis grounded in administrative capacity theory and a four-dimensional analytical framework, it examines the EU AI Act and Türkiye's sectoral governance arrangements to assess accountability, transparency, and enforceability in practice. The findings show that the EU has established a horizontal, risk-based governance framework, whereas Türkiye's approach remains characterized by sectoral fragmentation and a lack of a unified regulatory framework, with limited coordination and weak oversight capacity. The analysis identifies three main gaps: the absence of a formal risk classification system, unclear accountability arrangements, and insufficient institutional capacity for effective supervision. The study offers theoretically grounded recommendations to strengthen Türkiye's public-sector AI governance capacity in line with international standards.
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