Abstract

The rapid advancement of artificial intelligence (AI) has confronted legal systems with a fundamental question concerning the relationship between algorithmic action and legal responsibility. The core issue is whether autonomous AI systems can be regarded as holders of independent legal personality, or whether responsibility arising from algorithmic decision making must ultimately be attributed to human actors or human legal persons. Employing an analytical–comparative approach, this study examines AI governance models in the Islamic Republic of Iran and the United Arab Emirates, drawing upon the normative foundations of Imamiyyah Islamic jurisprudence alongside contemporary regulatory frameworks.

In the Iranian model, liability is grounded in classical jurisprudential concepts such as legal capacity (ahliyya), liability-bearing capacity (dhimmah), intention, and free will. Within this framework, artificial intelligence is treated solely as an instrumental tool rather than an autonomous legal subject. While this approach ensures normative stability and jurisprudential legitimacy, it also slows the process of adaptation to rapid technological developments. By contrast, the UAE adopts a functional and proactive model that prioritizes risk management and the distribution of liability through contractual mechanisms, insurance schemes, and technical compliance requirements, thereby emphasizing regulatory agility.

The findings indicate that the divergence between the two models can be analyzed along four key dimensions: sources of normative authority, ultimate governance objectives, the pace of technological adaptation, and the role of Islamic values. At the same time, the study demonstrates the feasibility of integrating the normative depth of Islamic jurisprudence with modern regulatory instruments. Such a synthesis may provide a balanced framework for responsible AI governance in the Islamic world—one that preserves ethical and normative integrity while facilitating technological innovation.