AI Regulation in Ukraine: Governance Framework, Strategic Oversight, and Compliance Considerations

​Ukraine's approach to artificial intelligence regulation is shaped by a combination of strategic policy instruments, human-rights safeguards, and alignment with European and international norms.

 

While Ukraine does not yet have a standalone AI law comparable to the EU AI Act, its regulatory landscape is anchored in the National Strategy for the Development of Artificial Intelligence, supported by data-protection law, cybersecurity frameworks, and sector-specific rules. For organisations developing or deploying AI systems in or from Ukraine, compliance requires understanding how strategy-level governance translates into operational expectations, particularly for high-risk, security-sensitive, and rights-impacting AI systems.

 

Ukraine's Strategic Approach to AI Governance

Ukraine's AI governance model is strategy-led rather than statute-led. The National AI Strategy functions as a policy and coordination instrument, guiding regulators, public authorities, and private actors toward responsible AI development while supporting innovation and digital resilience. The strategy reflects two parallel national priorities:

• Accelerating AI-driven innovation across government, defence, justice, and the private sector
• Safeguarding democratic values, human rights, and information security, particularly in a high-threat environment

This dual focus has made Ukraine one of the most explicit Eastern European jurisdictions in embedding ethical and security considerations directly into AI policy design.

 

The National Strategy for AI Development

The National Strategy remains the cornerstone of AI governance in Ukraine as of 2025. It establishes objectives, implementation principles, and sectoral priorities rather than enforceable obligations. Ukraine's AI strategy prioritises:

• Responsible AI development across public administration, defence, healthcare, education, and business
• Protection of human rights in automated and algorithmic decision-making
• Transparency and accountability in high-impact AI systems
• Counter-disinformation, cybersecurity, and information integrity
• Development of national AI expertise and technological resilience

 

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The strategy is supported by sector-specific concept papers and white documents, which increasingly resemble EU-style governance guidance rather than abstract policy statements.

 

Alignment with European and International AI Norms

Ukraine has positioned its AI governance explicitly within a European and international normative framework, reinforcing its broader EU-integration trajectory. In 2024–2025, Ukraine strengthened its participation in:

• The Council of Europe Framework Convention on Artificial Intelligence, Human Rights, Democracy and the Rule of Law
• EU-aligned discussions on trustworthy AI, risk classification, and human oversight
• International dialogues on AI safety, military AI ethics, and information security

 

While Ukraine is not legally bound by the EU AI Act, its National AI Strategy increasingly reflects the same governance logic and risk-based philosophy, enabling regulatory convergence and smoother compliance for organisations operating across both jurisdictions.

 

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For organisations operating across Ukraine and the EU, this convergence significantly reduces compliance friction.

 

 

Key Areas of AI Deployment in Ukraine

Ukraine's AI governance framework pays particular attention to high-impact and high-risk domains, reflecting both civil governance needs and national security realities.

 

1) AI in the Judicial System

Ukraine is among the first Eastern European countries to formally articulate rules for AI use in the judiciary. AI is permitted as a supporting tool, not a decision-maker. Permitted and emerging uses include:

• Automated case-management and scheduling systems
• Legal research and precedent analysis tools
• Document classification and summarisation
• Decision-support tools for risk assessment, subject to human control
• AI-enabled access-to-justice tools for citizens

Judicial AI systems must operate under human-in-the-loop principles, and their deployment is guided by professional bodies, including the Committee for the Protection of the Profession of Lawyer, to ensure procedural fairness and legal accountability.

 

2) AI in the Military and Defence Context

Given Ukraine's security environment, AI governance in the military domain is explicitly regulated through ethical and legal constraints, even in the absence of a single AI statute. Key governance principles include:

• Mandatory human oversight for autonomous or semi-autonomous systems
• Compliance with international humanitarian law
• Controlled use of AI for intelligence analysis, logistics, and cyber defence
• Restrictions on fully autonomous lethal decision-making

Military AI governance in Ukraine is increasingly aligned with NATO and international AI ethics discussions, reinforcing interoperability and legal legitimacy.

 

3) Human Rights and Fundamental Freedoms

Human-rights protection is a cross-cutting requirement in Ukraine's AI governance model. The strategy explicitly links AI deployment to constitutional rights, privacy, and non-discrimination. Key safeguards include:

• Transparency obligations for high-impact AI systems
• Non-discrimination requirements in automated decision-making
• Privacy-by-design and data-minimisation principles
• Human review and contestability of automated outcomes
• Accountability mechanisms for public-sector AI use

These safeguards are reinforced through Ukraine's data-protection and cybersecurity laws, which increasingly align with GDPR principles.

 

4) Disinformation, Cybersecurity, and Privacy Protection

Ukraine's AI governance framework places exceptional emphasis on information integrity and resilience, reflecting long-standing exposure to cyber and information warfare. Key regulatory priorities include:

• AI-based disinformation detection and mitigation
• Secure AI development and deployment practices
• Data-protection rules aligned with European standards
• Safeguards for cross-border data flows
• Incident-response and reporting mechanisms for AI-related security events

For AI developers, this means security-by-design is not optional in the Ukrainian context.

 

5) Implementation, Oversight, and Capacity Building

The National AI Strategy is supported by a phased implementation roadmap, focusing on institutional capacity rather than immediate enforcement. Key implementation elements include:

• Sector-specific AI guidance for justice, defence, healthcare, and education
• Training programmes for public officials and regulators
• Pilot projects with monitored deployment
• Periodic strategy reviews to address emerging technologies

This adaptive approach allows Ukraine to update governance expectations without constant legislative change.

 

Challenges and Risk Management

AI governance in Ukraine faces structural and contextual challenges, including:

• Operating in a high-threat security environment
• Limited regulatory and technical capacity
• Balancing innovation with rights protection
• Ensuring consistent governance across sectors

Risk mitigation relies on multi-stakeholder governance, international cooperation, and iterative policy refinement, rather than rigid enforcement alone.

 

Future Outlook

Looking ahead, Ukraine is expected to expand sector-specific AI governance rules, strengthen alignment with EU AI Act methodologies, introduce more formal assessment, auditing, and certification mechanisms and deepen cooperation with European and international AI institutions. Organisations should anticipate progressive formalisation of AI governance, even without a single comprehensive AI law.

 

How Nemko Digital Supports AI Compliance in Ukraine

Nemko Digital helps organisations navigate Ukraine's evolving AI governance landscape by translating strategy-level expectations into operational compliance frameworks. We support organisations through:

• AI regulatory mapping aligned with Ukraine's National Strategy and EU AI Act principles
• Risk classification and impact assessments for high-risk AI systems
• Human-oversight and accountability framework design
• Documentation, transparency, and audit-readiness models
• Cross-border compliance strategies for EU–Ukraine operations

With deep experience across EU, international, and emerging AI regulatory regimes, Nemko Digital enables organisations to build trustworthy, resilient, and future-ready AI management systems in Ukraine and beyond.