Journal of Law and Political Sciences 182 Original Article The role of civil liability in artificial intelligence laws from the perspective of major global legal systems Reza Farajpour * PhD Student Private Law, Department of Law, Yas.C., Islamic Azad University, Yasuj, Iran Use yor device to scan and read the article online Citation R. Farajpour, The role of civil liability in artificial intelligence laws from the perspective of major global legal systems. J. Law Political Stud., 2025, 5(2), 182-196. https://doi.org/10.48309/jlps.2025.518711.1353 Article info: Received: 2025-04-23 Accepted: 2025-05-18 Available Online: 2025-06-01 ID: JLPS-2504-1353 Checked for Plagiarism: Yes Keywords: Artificial intelligence, Civil liability, Automated decision making, Strict liability, Comparative analysis, Legal system. A B S T R A C T Rapid development of artificial intelligence (AI) and its mass application to domains of medicine, transport, and industry made determination of civil responsibility for errors by automatic decision making mechanisms an issue of law. The traditional mechanisms of law, based on human agency and fault ideology, lack proper means to take account of the autonomy and opaqueness of AI, so called "black box" syndrome. Applying analytical deductive and comparative approach, the current study examines the mechanisms of law responsible for AI related civil responsibility of Germany (product responsibility), the United States (product responsibility and agency), China (strict responsibility and state administration), Japan (auto regulation and product responsibility), Canada (fault and common law), the European Union (strict responsibility and obligatory insurance), and Iran (human fault). The results indicate that AI is not viewed as an independent juridical person within any of the examined jurisdictions and any responsibility is always attributed to developers or operators. The study recommends that spurred by international practice, Iran elaborate and apply a mechanism of law including strict responsibility of high-risk systems and obligatory civil insurance to achieve the target of technology development and protection of victims' rights. Introduction Artificial intelligence (AI) transformed traditional paradigms of decision making in medicine, transport, and industry and opened up juristic questions around the subject matter of civil liability due to its autonomous character. Traditional paradigmatic theoretical and practical legal approaches are confronted and challenged by the new technology, and thus current systems become subject to revision. Jurisdictions grappled between opposing solutions, from fault to strict responsibility principles, and did not arrive at international consensus. This study contributes comparative analysis of the German, United States, Chinese, Japanese, Canadian, European Union, and Iranian legal systems to explore AI based civil liability and suggested solutions on law and technology harmonization [10]. Methodology This study utilizes an analytical descriptive and comparative law methodology. In the analytical descriptive portion, concepts of AI civil liability laws are examined through conceptual analysis and by means of juristic reasoning. Library 2025, Volume 5, Issue 2 *Corresponding Author: Reza Farajpour ( r.farajpour@iau.ac.ir )