Ethical AI for the Developing World: A Comparative Study of Global Frameworks and Their Applicability in Pakistan

Abstract

As of early 2026, the pace of expansion of Generative AI (Generative AI) has far exceeded the governing structures that have been developed between 2019 and 2021. To developing countries such as Pakistan, Western-centric laws, such as the EU AI Act, pose a kind of Compliance-Innovation Paradox, making it prohibitively expensive, yet it does not mitigate the real-world risks like Digital Colonialism and cultural hallucinations in Large Language Models (LLMs). A Qualitative Systematic Review (QSR) of 32 primary sources, assessed using a special Triple-Lens Matrix, is used in this study to determine gaps in system implementation. The study concludes that the current international norms lack the essential characteristics to manage the non-deterministic character of Generative AI and its socio-technical influence on the Global South. In filling these gaps, this paper will present the Three-Pillar Adaptive Governance Model of Pakistan that will combine regulatory innovation by including SMEs in safe-to-fail sandboxes, technical sovereignty by curating indigenous Urdu-centric datasets, and ethical regulation based on the Trusteeship (I’timāni) Paradigm. The model enables us to use Adl (Justice) and Maslaha (Public Interest) as the functional auditing standards to give us a blueprint on how to move out of the Algorithmic Dependence to Epistemic Sovereignty. The report concludes that value-based indigenized framework is necessary to ensure that Pakistan can spearhead a digital future that is both technologically proficient, economically inclusive, and culturally oriented.

Keywords: AI Governance, Generative AI, Pakistan AI Policy, Digital Colonialism, Epistemic Sovereignty, Islamic AI Ethics, Regulatory Sandboxes, Urdu LLMs, Algorithmic Auditing.