Understanding the Role of Algorithm Registers in AI Governance Through Comparative Analysis of China and the UK

Abstract

Algorithm registers are increasingly being both considered and deployed as instruments in AI governance. They are often expected to deliver transparency; however, in practice their design, scope, and implementation vary substantially. Currently, we lack a holistic understanding of the potential roles that registers might play in AI governance, and how different design choices both shape and reflect those roles. This paper therefore asks how do algorithm registers differ across jurisdictions, and what do these differences reveal about their roles in AI governance? Towards this, we conduct a comparative analysis of two influential but contrasting algorithm registration mechanisms, China's Beian system and the UK's Algorithmic Transparency Recording Standard (ATRS), drawing on publicly available regulatory documents, registration guidelines, and registry data. Crucially, our analysis shows that an algorithm register, depending on its design and implementation, can serve functions beyond transparency, including pre-market approval, enabling ecosystem-level understanding, and acting as a broader regulatory infrastructure. As algorithm registries proliferate globally, we stress the importance of researchers and policymakers considering and examining the concrete governance functions that algorithm registries can perform as a result of their design and institutional context, rather than approaching them primarily through a transparency lens.