Faces at Stakes: Comparative Insights on Facial Recognition Technologies Policy Implementation Arrangements across the EU, the US, and the PRC

Facial recognition technologies (FRTs) crystallize tensions between security, innovation, and fundamental rights, as their implementation follows markedly different policy arrangements across states and geopolitical blocs. This article explores how policy implementation arrangements for FRTs shape models of digital sovereignty in the European Union (EU), the United States (US), and the People’s Republic of China (PRC). Through a comparative, most-different systems design, and structured content analysis of secondary sources (laws; guidance; enforcement; grey literature), this investigation operationalizes four dimensions: regulatory frameworks; actor networks; implementation and enforcement mechanisms; and sovereignty implications. Three distinctive pathways emerge, namely, the EU’s rule-and-regulator, the US’s liability-and-localism, and the PRC’s command-and-integration, which shape digital sovereignty attributes by reflecting broader security-related strategies. The article advances a mechanism-based account linking policy implementation to sovereignty claims and offers policy recommendations for aligning policy instruments with regulatory oversight capacity.