Governing the Capability-Accountability Gap through Global Capability Centres as Regulatory Nodes in the Gulf

Global Capability Centres (GCCs), wholly-owned “captive” units through which multinational enterprises internalise offshore delivery, have migrated from cost-driven back offices toward research, engineering, artificial-intelligence (AI) development, cybersecurity and financial-control functions of global consequence. This article theorises the legal consequences of that migration in the Gulf, where the United Arab Emirates and Saudi Arabia have simultaneously constructed ambitious data- and AI-governance architectures. Its central and integrating claim is that when a GCC accumulates functional and technological capability faster than it acquires corresponding decision authority, legal responsibility and answerability, a Capability-Accountability Asymmetry emerges, producing a Regulatory Accountability Gap (RAG), a divergence between where consequential activity is performed and where legal answerability is located. The article makes four connected contributions. First, it develops the asymmetry into a Four-A model (capability, authority, responsibility, accountability) and operationalises the RAG through a diagnostic matrix and a set of threshold conditions, so that the gap becomes an analytical construct rather than a metaphor. Second, it offers a four-layer “Accountability Stack” (structural, operational, decision and behavioural) as a diagnostic instrument and applies it to a worked case. Third, it advances a four-stage “Regulatory Maturity Curve” on which RAG intensity rises during capability expansion and may fall as authority is re-allocated. Fourth, it reframes the “copy-paste” compliance error as Regulatory Translation Failure, grounded in legal-transplant theory, and reads the Saudi and Emirati regimes as two institutional solutions, centralised regulatory translation and polycentric regulatory reconciliation, to the same problem. Drawing on legal-pluralism, transplant, regulatory-intermediary and accountability scholarship and on doctrinal analysis of the relevant Gulf instruments, it conceptualises mature GCCs as sites of regulatory translation and co-production, and closes with boundary conditions, limitations and an agenda for empirical research.