AI Regulation in Uganda: Building a Rights-Based and Innovation-Driven Framework

By 2025, the government has accelerated work on a national AI regulatory framework, combining human-rights protections, data governance, and sector-specific oversight with ambitions for responsible digital transformation. Uganda's approach is guided by the Ministry of ICT & National Guidance, the Uganda Communications Commission (UCC), and the National Information Technology Authority (NITA-U), each contributing to the design of a structured and future-ready AI ecosystem. As Uganda deepens its partnerships with global organisations, strengthens national data-protection structures, and expands digital public infrastructure, AI is increasingly central to national development priorities from security and public administration to health, agriculture, and financial inclusion. The resulting framework is moving toward a risk-based model aligned with global practices, with formal legislation expected in coming years.

 

Uganda's Digital and Policy Context for AI

Uganda's AI governance is closely linked to its broader digital-transformation agenda. The government views AI as a catalyst for improved public-service delivery, greater efficiency, and stronger economic growth, while also acknowledging the risks associated with surveillance, data misuse, cybersecurity, and algorithmic discrimination. This dual imperative innovation and rights protection underpins all current policy developments.

 

National Direction: AI in Uganda's Development Vision

Uganda's policy direction positions artificial intelligence as a strategic tool for achieving national development goals, with applications already expanding across key sectors. In healthcare, AI-enabled diagnostics and rural telemedicine platforms are helping to close critical gaps in specialist access and early disease detection. Agriculture, a cornerstone of the Ugandan economy, is benefiting from precision-farming tools, yield-forecasting models, and crop-disease detection systems that support climate-resilient production. Security agencies are increasingly adopting AI-powered surveillance and facial-recognition technologies to enhance public-safety capabilities, while government ministries are integrating AI into public-administration processes to streamline citizen services and reduce administrative bottlenecks. In Uganda's dynamic financial and mobile-money ecosystem, AI plays a growing role in fraud detection, risk scoring, and expanding financial inclusion. The rapid rise of these applications, driven by public-private partnerships and foreign technology providers, underscores the urgency of a robust regulatory and accountability framework that can protect citizens while enabling innovation.

 

AI in Security & Surveillance: Governance Challenges and Rights Risks

Uganda has deployed several AI-enabled surveillance and public-safety tools, including facial-recognition infrastructure established through partnerships with technology companies such as Huawei. These systems enhance urban security and crime detection but raise important governance questions:

• How is biometric data processed and stored?
• Can citizens challenge automated or semi-automated decisions?
• Are the systems aligned with Uganda's data-protection law and constitutional rights?

The upcoming AI framework emphasises transparency, proportionality, and accountability in surveillance technologies, aiming to ensure that security initiatives do not violate privacy or human-rights commitments.

 

AI in Healthcare and Universal Health Coverage

AI is becoming integral to Uganda's drive toward Universal Health Coverage (UHC). NITA-U and the Ministry of Health are promoting AI-driven solutions to strengthen diagnostics, real-time disease surveillance, workforce support, and resource allocation.

AI plays a strategic role in:

• Expanding diagnostics in underserved regions
• Predictive analytics for maternal health and infectious-disease management
• Digital health record systems
• Cost-efficient healthcare delivery through automation

However, these innovations depend on strong data-protection controls and sector-specific governance, two areas the 2025 policy roadmap aims to clarify.

 

Key Partnerships and International Alignment

Uganda's policymakers participate in GlobalPolicy.AI and AU-level digital-governance initiatives, incorporating ethical guidelines, risk-assessment methodologies, human-rights evaluation models, regional harmonisation strategies. Partnerships with Huawei, medical-AI vendors and agricultural-AI startups accelerate adoption but also raise expectations for data-governance safeguards, cross-border data controls, transparency requirements, independent audits and due-diligence mechanisms.

 

Uganda's AI Governance Structure

Uganda does not yet have a dedicated AI Act, but the regulatory environment is evolving through multiple institutions.

Table 1: Key Ugandan Authorities Involved in AI Governance (2025)

Institution	Role in AI Governance
Ministry of ICT & National Guidance	Leads national AI policy, oversees strategic direction and legislation.
NITA–U (National Information Technology Authority)	Technical standards, digital infrastructure, cybersecurity, data governance.
Uganda Communications Commission (UCC)	Oversight for digital services, telecoms, online platforms, algorithmic digital-service compliance.
Office of the Data Protection Commissioner	Enforcement of the Data Protection & Privacy Act (DPPA) and privacy safeguards in AI.
Parliament of Uganda	Drafting and passing the upcoming AI law (expected by 2025/26).

 

The emerging framework builds upon Uganda's Data Protection & Privacy Act, Computer Misuse Act, and Digital Transformation Roadmap, using these as foundations for AI-specific obligations.

 

Lessons from Global Frameworks

Uganda is using international benchmarks, especially Kenya's digital regulation, Rwanda's sandbox tools, and the EU AI Act's risk-based structure to shape its regulatory direction.

Key elements adopted from global models:

• Risk categories for AI systems
• Sector-specific oversight (health, finance, telecoms)
• Audits and documentation requirements
• Public accountability for automated decision-making
• Human oversight and redress

 

​Fig 1.0 Key governance elements shaping Uganda's emerging AI regulatory model, illustrating how risk classification, sector-specific oversight, accountability mechanisms, and human-centric safeguards form the foundation of responsible AI deployment.

 

Uganda aims for a framework that is globally compatible, with potential references to ISO/IEC 42001, ISO 38507, and other AI governance standards.

 

Ethical, Social, and Rights-Based Considerations

Uganda's emerging AI policy is rooted in human rights and constitutional protections. Key priorities include:

Digital and Social Inclusion

Uganda's AI strategy places strong emphasis on digital inclusion, recognising that the benefits of emerging technologies must extend beyond major urban centres. Reducing the urban–rural divide is a central priority, with efforts focused on expanding connectivity, improving infrastructure, and ensuring that AI-enabled services are accessible to underserved communities. This includes making digital solutions affordable for households, schools, and health facilities that traditionally operate with limited resources.

Complementing these efforts are nationwide digital-skills programmes designed to equip citizens with the competencies needed to engage with AI tools safely and effectively. To further promote equitable access, Uganda is also encouraging the development of multilingual AI interfaces that support Luganda and other regional languages, ensuring that linguistic diversity is respected and that AI systems remain usable and relevant for all communities across the country.

 

Human Rights Protections

Uganda's emerging AI framework is firmly rooted in human-rights protections, with a particular emphasis on ensuring that AI deployment does not compromise individual freedoms or constitutional guarantees. Central to this approach are strong privacy and data-governance safeguards, which require organisations to handle personal and sensitive data responsibly, transparently, and in line with the Data Protection and Privacy Act. The framework also prioritises non-discrimination and bias reduction, recognising that AI systems used in sectors such as finance, recruitment, policing, and healthcare must be designed and tested to prevent unequal or harmful outcomes. Preserving human agency is another core principle: individuals must retain the ability to challenge, understand, and override automated decisions that significantly affect their rights or access to services. To support this, Uganda is introducing clearer obligations around algorithmic transparency, ensuring that users, regulators, and affected communities can understand how AI systems function, what data they rely on, and how decisions are made. Together, these elements form the ethical foundation of Uganda's AI governance model.

 

Challenges in Implementing AI

Uganda faces several structural and operational challenges:

• Balancing innovation vs. regulation for a rapidly digitising economy
• Cybersecurity weaknesses in AI systems
• Data-governance gaps in handling biometric and health data
• Potential algorithmic bias, especially in credit scoring
• Skills shortages in AI audit, assurance, and risk management

To address these gaps, the government is exploring regulatory sandboxes, flexible compliance frameworks, and structured risk-assessment methodologies.

 

Future Directions

Uganda is expected to introduce its first dedicated AI law between late 2025 and 2026, establishing a clearer and more comprehensive regulatory foundation for responsible AI deployment. The forthcoming legislation is likely to create a national AI governance authority, introduce risk-based classification rules, and require registration or notification for high-risk systems. It will also mandate human oversight in sensitive sectors such as healthcare, finance, and security, alongside new obligations for documentation, algorithmic transparency, ethical-impact assessments, and redress mechanisms to ensure citizens can challenge harmful or unfair automated decisions. Collectively, these measures aim to embed accountability and strengthen public trust in AI-enabled services.

In parallel, NITA-U is intensifying efforts to build national AI assurance and testing capabilities to support implementation of the upcoming law. Priorities include establishing rigorous system-testing and validation procedures, creating incident-reporting and response frameworks, and developing continuous-monitoring processes to track model behaviour over time. These initiatives are complemented by stronger risk-management and lifecycle-documentation requirements that prepare organisations for auditability and alignment with emerging global standards such as ISO/IEC 42001 and the NIST AI Risk Management Framework. Together, they will help Uganda foster a compliant, safe, and internationally compatible AI ecosystem.

 

Table 2: Expected Components of Uganda's Upcoming AI Governance Law

Component	Likely Focus
Risk Classification	Inspired by EU/UK models, with high-risk categories for health, finance, security, and civic systems.
Transparency & Explainability	Requirements for disclosures and user-level explanations.
Human Oversight	Mandatory human review in sensitive areas (credit, policing, healthcare).
Data Governance	Strengthening DPPA enforcement & biometric protections.
Accountability & Redress	Clear processes for citizens to challenge algorithmic outcomes.
Sector-Specific Rules	Healthcare, finance, agriculture, telecoms.

 

Regional Integration: East African AI Governance

Uganda is coordinating closely with Kenya, Rwanda, and the broader African Union AI policy discussions to harmonise:

• Data-governance frameworks
• AI-risk classifications
• Cybersecurity requirements
• Cross-border digital-trade standards

This is essential as East Africa strengthens common market digital policies and shared AI innovation pathways.

 

Conclusion: Uganda's Path Toward Responsible and Inclusive AI

Uganda is moving decisively toward a structured, rights-based, and innovation-ready AI regulatory framework. With legislation expected by 2025/26, organisations operating in Uganda will face more clearly defined requirements around transparency, human oversight, data protection, risk classification, and sector-specific compliance. At the same time, Uganda is positioning itself as a regional contributor to responsible AI innovation particularly across healthcare, agriculture, and public administration blending local development priorities with international standards. For businesses, this means preparing early for compliance, testing, documentation, and continuous-monitoring requirements as the regulatory landscape matures.

How Nemko Digital Can Help

Nemko Digital supports organisations deploying AI in Uganda and East Africa with:

• AI governance readiness assessments aligned with global standards (ISO/IEC 42001, NIST AI RMF, OECD).
• Regulatory monitoring for upcoming Ugandan AI law and sector-specific rules.
• AI compliance for DPPA, cybersecurity requirements, and biometric-data safeguards.
• AI risk classification and impact-assessment frameworks.
• Independent audits, testing, and trust-mark preparation.
• Documentation support for transparency, explainability, lifecycle governance, and incident reporting.

Our experts help companies navigate uncertainty, build trust, and align AI-enabled products and services with Uganda's emerging legal, ethical, and safety requirements. Get in touch with us.