نوع مقاله : مقاله تخصصی
عنوان مقاله English
نویسندگان English
The evolution of the digital economy and the expansion of cross-border data flows have transformed data governance into one of the most significant regulatory domains in contemporary law. China and Iran, as two distinct models of addressing data transfer issues, have adopted data sovereignty-centric and legally controlled approaches. These approaches are in relative conflict with global standards based on data flow liberalization. This research, through a comparative focus on these two systems, examines the legal, institutional, and policy challenges arising from their misalignment with international data governance regimes. The main research question is: To what extent do the legal systems of Iran and China converge with global data governance standards, and what are the most significant legal and structural obstacles to this convergence? The objective is to analyze the legislative, institutional, and executive structures governing cross-border data flows in both countries and to elucidate the existing gaps with multilateral digital trade regimes. The research methodology is descriptive-analytical, based on documentary study and comparative analysis of domestic and international sources.The findings indicate that both systems, albeit with varying degrees of intensity, have adopted a control-oriented approach to data, emphasizing the primacy of security and sovereignty considerations over data flow liberalization. In China, this approach is institutionalized within a cohesive legislative and institutional framework, whereas in Iran, it appears more fragmented and unsystematic. This structural difference has led both countries to face similar challenges in adapting to global standards, reducing international digital interactions, and increasing compliance costs. Consequently, the gap between domestic systems and international data governance regimes has become a major impediment to legal convergence in the digital economy.
کلیدواژهها English