Inter-Jurisdictional Regulatory Coordination on Cross-Border Data Flows in AIoT-Enabled Smart Grids: A Comparative Study Across the Taiwan Strait and between Hong Kong and Macao SARs

AIoT-enabled smart grids require real-time cross-jurisdictional data exchange for scenarios including virtual power plant dispatching and electric-vehicle-grid interaction. Under the framework of “One Country, Two Systems, Four Jurisdictions”, divergent data protection rules among Mainland China, Hong Kong SAR, Macao SAR and the Taiwan Region create compliance barriers for power-sector data circulation. This paper compares the four jurisdictions’ regulatory models and their underlying security-oriented, freedom-oriented and rights-oriented governance logics. Defining inter-jurisdictional coordination as a governance mode distinct from international and central-local coordination, it draws on GDPR adequacy determination and the institutional practice of the Guangdong-Hong Kong-Macao Greater Bay Area to propose a multi-directional equivalence-recognition system. Centered on an Inter-Jurisdictional Data Protection Coordination Committee, the system adopts tiered assessment standards and the procedure of “application-review-decision-supervision”, and suggests phased pilot implementation in the Greater Bay Area to facilitate compliant cross-jurisdictional data flows while respecting each jurisdiction’s regulatory autonomy.