This study developed a framework that compares the content and purposes of "federal" level European Union (EU) and United States (US) e-learning policy to ascertain trends, patterns, and points of convergence and divergence across the years 1994-2010. It reveals that the EU and US are applying similar rhetoric for policy framing, justification, provisions, mechanisms, and incentives for e-learning. However, the actual policies vary due to the structural differences between the governing regimes. This research also suggests that more rigorous analyses of educational policy can contribute to our understanding of the intersectionality of policy development and educational regulation at local, regional, and transnational levels.