Digital Authoritarianism Without Authoritarians? U.S. and Chinese Governance of Facial Recognition and the Global Circulation of Surveillance Logics

This paper examines how both liberal democratic and authoritarian states contribute to the global expansion of biometric surveillance through distinct but converging governance logics. Focusing on the United States and China, it challenges the assumption that digital authoritarianism is confined to autocratic regimes by analyzing how internal governance structures in each case facilitate the normalization and export of facial recognition technology (FRT). In the United States, federal law enforcement agencies have rapidly adopted FRT with minimal regulatory oversight. Oversight reports from the U.S. Government Accountability Office and the Commission on Civil Rights reveal that agencies routinely conducted FRT searches without training requirements, transparency mechanisms, or safeguards for civil liberties. Recent internal guidelines, introduced from 2023 onward, emphasize ethics and public trust but often lack enforceable constraints or independent oversight. These frameworks allow agencies to formalize discretion while projecting normative legitimacy, a phenomenon this paper conceptualizes as symbolic self-regulation. In contrast, China’s facial recognition infrastructure is more centralized, integrated, and politically explicit. State-led initiatives such as the Skynet and Sharp Eyes programs openly frame FRT as a tool for social stability and governance optimization. While China’s regime is overtly authoritarian, it too deploys justificatory narratives (e.g., “security,” “harmony,” and “technological modernization”) that seek to normalize extensive biometric surveillance. However, these discourses differ less in kind than in degree from those emerging in democracies. The paper adopts a comparative qualitative approach, combining analysis of official policy documents, privacy impact assessments, public discourse, and transnational technology standards. It shows how both U.S. and Chinese governance models reinforce discretionary power, albeit through different institutional languages and levels of transparency. Both regimes also play active roles in global norm diffusion: the U.S. through public-private partnerships and policy advisory networks; China through digital infrastructure exports and regulatory influence in the Global South. By juxtaposing these cases, the paper contributes to critical debates on digital authoritarianism, algorithmic governance, and techno-legal legitimacy. It argues that liberal democratic self-regulation may inadvertently legitimize forms of state surveillance that echo authoritarian practices, particularly when oversight is weak, civil society influence is limited, and legal accountability is fragmented. Moreover, the international circulation of FRT governance models illustrates how surveillance logics can transcend regime type, shaped instead by overlapping interests in security, technological leadership, and institutional insulation from democratic pressure. Ultimately, this paper urges scholars and policymakers to rethink the boundaries of digital authoritarianism and attend to the subtle ways in which liberal regimes may participate in its global diffusion - not only through inaction, but through the very architectures of governance designed to reassure the public. Selected bibliography: Caspian Policy Center. (2020). China’s Growing Influence In Central Asia Through Surveillance Systems Policy Brief By The Caspian Policy Center. https://api.caspianpolicy.org/media/uploads/2020/09/PB-Chinas-growing-influence-in-CA-through-surveillance-systems.pdf United States Government Accountability Office. (2023). FACIAL RECOGNITION SERVICES. Federal Law Enforcement Agencies Should Take Actions to Implement Training, and Policies for Civil Liberties. https://www.gao.gov/assets/gao-23-105607.pdf United States Commission on Civil Rights. (2024). The Civil Rights Implications of the Federal Use of Facial Recognition Technology. https://www.usccr.gov/files/2024-09/civil-rights-implications-of-frt_0.pdf