https://czasopisma.kul.pl/index.php/recl <p style="text-align: justify;"><strong>Review of European and Comparative Law</strong> (RECoL, formerly <em>Review of Comparative Law</em>) is issued as a journal publishing articles in English written by Polish and foreign authors. The <em>Review</em> also serves as a discussion forum in a broader international context. Moreover, it provides an opportunity to present Polish juridical output abroad. As the name of the periodical suggests, the intention of the Editors is to present legal institutions in the European and comparative perspective.</p> Katolicki Uniwersytet Lubelski Jana Pawła II en-US Review of European and Comparative Law 2545-384X https://czasopisma.kul.pl/index.php/recl/article/view/19283 <p>The European Union AI Act constitutes an important development in shaping the Union’s digital regulatory architecture. The Act places fundamental rights at the heart of a risk-based governance framework. The article examines how the AI Act institutionalizes a human-centric approach to AI and how the AI Act’s provisions explicitly and implicitly embed the protection of rights enshrined in the EU Charter of Fundamental Rights. It argues that fundamental rights function not merely as aspirational goals, but as legal thresholds and procedural triggers across the life cycle of an AI system. The analysis suggests that the AI Act has the potential to serve as a model for rights-preserving AI systems, while acknowledging that challenges will emerge at the level of implementation.</p> Georgios Pavlidis Copyright (c) 2026 Review of European and Comparative Law http://creativecommons.org/licenses/by/4.0 2026-02-23 2026-02-23 10.31743/recl.19283 https://czasopisma.kul.pl/index.php/recl/article/view/19473 <p>Autonomous Vehicles (AVs) call into question the driver-centered premises of road traffic liability, as the task of driving becomes a distributed, socio-technical process involving software, sensors, updates, connectivity, infrastructure, and (sometimes) remote supervision. This article offers a doctrinal comparative analysis of how liability can be attributed across three axes, civil, administrative, and criminal, when accidents occur where there are higher levels of automation. It argues that the European Union does not (and need not) rely on a single AV liability code. Instead, EU law combines an insurance-first, victim-compensation logic with the modernization of product liability for software-enabled harms and a risk-based regulatory style that imposes documentation, post-market, and safety-management duties on upstream actors. Using Germany, France, and the Netherlands as illustrative models, the article maps Vietnamese law through the same framework. It shows that Vietnam already embodies a strong victim-protection baseline through strict "source of extraordinary danger" doctrines and is developing more stringent product responsibility tools. At the same time, Vietnam faces persistent mismatch risks in evidentiary access, cyber incident attribution, and the calibration of criminal accountability. The article concludes with a direction of reform, modified as appropriate for Vietnam, that preserves rapid compensation while structuring recourse, data governance, and controlled piloting. </p> Phuc G. Dao Copyright (c) 2026 Review of European and Comparative Law http://creativecommons.org/licenses/by/4.0 2026-03-02 2026-03-02 10.31743/recl.19473