Governing the rise of AI in healthcare: A comparative governance document and implementation implications across five jurisdictions.

Abstract

As AI increasingly reshapes healthcare delivery and innovation, global health systems face urgent imperatives to govern its development, deployment. Drawing on 43 regulatory and strategic documents in five jurisdictions, the study systematically assessed convergences and divergences in national AI strategies, risk classification schemes, software-as-a-medical-device (SaMD) frameworks, ethical oversight, and cross-border data policies. Policy and regulatory documents on AI in health (2017-2025) w