AI Governance for Multi-Cloud Data Compliance: A Comparative Analysis of India and the USA

Аннотация

Multinational companies that manage data OPEN ACCESS across jurisdictional boundaries are having trouble SUBMITED 17 July 2025 integrating artificial intelligence systems with multi- ACCEPTED 24 July 2025 PUBLISHED 06 August 2025 cloud architectures. This is especially true since over VOLUME Vol.07 Issue 08 2025 90% of businesses use multiple cloud providers and deal CITATION with complicated AI governance frameworks. This paper Yashvardhan Rathi. (2025). AI Governance for Multi-Cloud Data Compliance: examines how well AI governance frameworks in India A Comparative Analysis of India and the USA. The American Journal of Interdisciplinary Innovations and Research, 7(8), 32–42. and the US deal with multi-cloud data residency https://doi.org/10.37547/tajiir/Volume07Issue08-03 compliance issues through a systematic literature evaluation based on PRISMA standards and thematic COPYRIGHT analysis of 26 publications, including academic articles, © 2025 Original content from this work may be used under the terms government policy papers, and industry reports of the creative commons attributes 4.0 License. published between 2020 and 2025. The study points out significant cross-border regulatory coordination problems and examines whether existing bilateral strategies need more ways to work together. The thematic analysis identified trends in regulatory frameworks and compliance problems, revealing "regulatory incommensurability" as a central theme— meaning that following one jurisdiction's rules goes against the basic ideas behind another's procedures. The Digital Personal Data Protection Act in India has a permission-by-default approach, which is very different from the USA's restriction-by-default approach. This leads to impossible compliance situations instead of coordination problems. Organizations face systemic inefficiencies because of duplicate infrastructure and multiple governance systems that do not provide the same level of AI safety or data security. For example, 35% of data breaches include "shadow data" not covered by existing frameworks. The results show that traditional working methods cannot settle significant disagreements between AI governance frameworks. The American Journal of Interdisciplinary Innovations and Research 32 https://www.theamericanjournals.com/index.php/tajiir The American Journal of Interdisciplinary Innovations and Research This means that new theoretical approaches are needed practical complexity shows that there is even less that acknowledge valid regulatory differences while written on this subject. Many studies have been done on making it easier for multinational companies to use AI the rules for AI governance in different countries and on systems in both jurisdictions. cloud compliance rules in general. However, we still do not fully understand how AI governance works with Keywords: AI Governance, Data Sovereignty, Multi- multi-cloud data residency compliance when it goes Cloud Compliance, Digital Personal Data Protection Act both ways (Roberts et al., 2024). It is essential to fill this (DPDPA) ,NIST AI RMF, India-USA Regulatory study gap because the current ways of governing AI and Comparison, Regulatory incommensurability ensuring that cloud data is safe are not enough to handle 1. Introduction the complicated issues businesses face when doing Using AI systems and multiple cloud architectures has business in multiple places. completely changed how multinational businesses send This study looks at how AI governance frameworks in and receive data across borders. Things have become India and the US handle the issue of multi-cloud data more difficult in the middle of technological growth and residency compliance. It also finds specific gaps or following the rules. Over 90% of companies now use conflicts in cross-border regulatory coordination. It more than one cloud provider. It is becoming even more decides if new ways are needed to ensure that important for governments worldwide to set up AI companies that run AI systems in both countries follow oversight systems and comprehensive data security the same rules. The results come at a good time because rules (Tata Communications, 2024) for multi-cloud data international efforts are still being made to make clear residency. rules for AI control. It helps with academic research and Two significant places have different rules about how to policy-making, where good governance is needed to handle these new tools. This shows how hard it is to keep an eye on the rules and encourage international follow the rules when not in the same place. Two cooperation in technology. important laws that affect how companies handle AI 2. Literature Review systems and data across borders are India's Digital 2.1. Fragmented National AI Governance Personal Data Protection Act (DPDPA) of 2023 and the Approaches US's new AI governance framework based on the NIST AI Risk Management Framework (Bahl et al., 2024; Cloud The academic literature reveals signifi