Enterprise AI Analysis
A comparative topic modeling analysis of Al policies in healthcare: insights from China, the United States, and the European Union
Authors: Pu Han, Wuyi Qian, Sengling Liu, Wei Wang, Xin Zheng, Shenqi Jing
Publication Dates: Received: 9 October 2025 | Accepted: 5 May 2026
Keywords: Healthcare, Artificial Intelligence, BERTopic, Topic modeling, Policy Text Mining
Executive Impact & Strategic Imperatives
This research provides a comparative analysis of healthcare AI policies across China, the U.S., and the EU from 2016 to 2025. By leveraging the BERTopic model, it identifies distinct policy orientations shaped by institutional contexts: China emphasizes application and infrastructure, the U.S. prioritizes institutional integration and practical application, and the EU focuses on risk governance and regulation, reflecting state-driven, market-driven, and rights-driven models, respectively. The study tracks the dynamic evolution of these policies, offering insights for building a diversified and mutually beneficial international AI policy system in healthcare.
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Policy Documents Analyzed
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Key Global Economies
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Analysis Period
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BERTopic Method Employed
Deep Analysis & Enterprise Applications
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Methodology
The study employs the BERTopic model for thematic modeling on AI policy texts in healthcare across China, the U.S., and the EU. This approach, integrating BERT's deep semantic understanding with topic clustering algorithms, efficiently processes multilingual and large-scale policy texts, enhancing accuracy and granularity of topic discovery. BERTopic first uses BERT to generate document embedding vectors, then performs dimensionality reduction through UMAP. The reduced vectors are clustered using the HDBSCAN algorithm to identify semantically similar document sets and finally extract representative keywords for each topic using class-based TF-IDF. This modular architecture enables personalized topic modeling and intuitive interpretation.
Overall Framework of the BERTopic Model
Documents
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Document Embeddings (BERT)
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Dimensionality Reduction (UMAP)
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Document Clustering (HDBSCAN)
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Topic Representation (c-TF-IDF)
531
Policy Documents Processed
Findings: Regional Orientations
Findings reveal that China, the U.S., and the EU have pursued different policy directions in tech orientation, data governance, ethical regulation, and service scenarios over the past decade. China emphasizes application breadth and infrastructure development; the U.S. prioritizes institutional coordination and practical feasibility; the EU underscores risk governance and regulatory frameworks. These differences reflect dominant directions of global AI policies in healthcare aligned with respective institutional backgrounds and development strategies.
| Region | Application Orientation | Technology & Data Governance | Regulatory Systems |
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| China |
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| U.S. |
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| EU |
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EU's AI Act: A Rights-Driven Approach
Sector: Healthcare AI Governance
Challenge: Balancing technological innovation with fundamental rights and public interest protection.
Solution: The EU's AI Act, as the world's first comprehensive AI regulatory framework, emphasizes risk governance and digital rights protection, influencing corporate governance and global healthcare AI governance.
Outcome: Sets a precedent for regulation-driven development, fostering steady progress and compliance, with profound impacts on global standards.
Dynamic Evolution of Policies
China, the U.S., and the EU exhibit distinct temporal patterns in their healthcare AI policy evolution, influenced by national strategies and public health events. China shows concentrated policy issuance with a peak in 2023, followed by a decline as institutional frameworks solidify. The U.S. demonstrates event-driven phased outbreaks, notably increased attention to telemedicine and AI-assisted diagnosis during pandemics. The EU follows a steady, regulation-driven path, with intense policy changes between 2020-2022 due to the AI Act and digital transformation plans.
2023
Year with Most Policy Documents in China
2020
EU AI Act Key Regulatory Period Began
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