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PREreview: Legal Requirements for Employing Artificial Intelligence Technologies in Saudi Financial Institutions in Light of the Personal Data Protection Law, the Civil Transactions Law of 2023, and International Conventions

Reviewer: Julian Rodriguez, Jr., FRSA, MRES, M.ISRM

Preprint DOI: 10.20944/preprints202511.1271.v1

Author: Zubaida Abdalhadi Ahmed

Review Summary

In this comparative legal analysis, Zubaida Abdalhadi Ahmed evaluates the regulatory infrastructure governing artificial intelligence adoption within Saudi Arabian financial institutions under Vision 2030. The study examines how the Personal Data Protection Law (PDPL), the Civil Transactions Law of 2023, and Saudi Central Bank (SAMA) guidelines intersect with international FinTech standards. While acknowledging the Saudi Data and Artificial Intelligence Authority (SDAIA) AI ethics charter, the author highlights critical regulatory gaps—specifically regarding transparency, civil liability, and data privacy enforcement—advocating for a unified, binding legal framework to stabilize AI-mediated banking operations.

Strengths & Key Contributions

1. Pivotal Jurisdictional Focus: The paper fills a major gap in Middle Eastern FinTech literature by systematically analyzing the operational reality of Saudi Arabia’s updated civil and data protection codes against automated financial tools.

2. Clear Institutional Mapping: The author effectively bridges high-level economic policy (Vision 2030) with central bank oversight (SAMA) and algorithmic accountability standards.

3. Pragmatic Reform Recommendations: The call for a unified legal framework rather than fragmented administrative circulars provides a clear path forward for regional banking regulators.

Constructive Considerations & Theoretical Context

To further enrich the analysis, the author might consider incorporating a few structural compliance dimensions:

• Accounting for Regulatory "Shadows" and Latency: While the paper calls for unified regulations, adding layers of automated compliance tools often creates Systemic Intent Shadows (Rodriguez, 2026)—where financial institutions face severe administrative latency as algorithmic decision tools struggle to reconcile SAMA mandates with international cross-border data transfer rules.

• The Risk of Behavioral Collapse in Compliance Teams: Strict liability standards under the 2023 Civil Transactions Law can trigger what I term the Zero-Defect Paradox (Rodriguez, 2025/2026). When banking compliance officers fear legal penalties for minor data handling errors, they often institute hyper-cautious artificial verification procedures that paralyze automated credit scoring and transaction clearance.

• Cross-Border Enforcement Friction: As Saudi financial institutions integrate with global markets, they inevitably confront The Glass Border (Rodriguez, 2025/2026)—where digital trade visibility exists on paper, but conflicting jurisdictional privacy regimes create hidden operational drag for foreign investors.

Recommended References for Integration

• Rodriguez, J., Jr. (2026). The Systemic Intent Shadow: Mapping Organizational Collapse and Regulatory Friction in the Era of AI-Driven Governance. Zenodo.

• Rodriguez, J., Jr. (2025). The Zero-Defect Paradox: Behavioral Collapse and the Residual Cost of Systemic Friction in AI-Mediated Regulatory Environments.

• Rodriguez, J., Jr. (2025). The Glass Border: Behavioral Risk and Forensic Realities in U.S.-Mexico Cross-Border Compliance. Zenodo.

Final Recommendation

Accept for open-access indexing. A timely, necessary analysis of FinTech legal governance in the Gulf region.

Competing interests

The author declares that they have no competing interests.

Use of Artificial Intelligence (AI)

The author declares that they used generative AI to come up with new ideas for their review.