AI Regulation Hub

Ukraine

Ukraine has no horizontal AI law. Its bottom-up approach (per the 2024 White Paper) starts with voluntary commitments, codes of conduct, sandbox preparation and sectoral guidance, with a future Ukrainian AI law analogous to the EU AI Act planned in stages between 2023 and 2026.

Key provisions

White Paper roadmap (bottom-up approach)

In force

The Ministry of Digital Transformation published a 2024 White Paper. Stage 1 prepares businesses with tools for future requirements and European market access. Stage 2 plans a Ukrainian AI law analogous to the EU AI Act.

Voluntary commitments & codes of conduct

In force

Self-regulation, voluntary commitments, codes of conduct, risk assessment, AI labelling initiatives, sectoral recommendations and human-rights impact assessment methodologies.

Regulatory sandbox preparation

Draft

Sandbox planning during the 2023–2026 period as part of the official AI roadmap.

NBU financial-sector AI guidance

Draft

The National Bank of Ukraine is developing sectoral guidance for ethical and responsible AI use in financial markets, addressing consumer protection, transparency, human oversight, risk management, operational resilience, data and model requirements and information security.

Ukrainian AI Act (analogous to EU AI Act)

Proposed

Planned future legislation analogous to the EU AI Act, to be developed during the 2023–2026 period.

Detailed overview

Ukraine does not currently have a full horizontal AI law equivalent to the EU AI Act. Ukraine's official AI regulation approach is based on staged preparation for future legislation, alignment with the EU AI Act and development of responsible AI practices before a binding AI law is adopted.

White Paper roadmap

The Ministry of Digital Transformation published a White Paper in 2024 describing Ukraine's approach to AI regulation. The approach is "bottom-up": first, Ukraine provides businesses with tools to prepare for future legal requirements and European market access; then, Ukraine plans to adopt a Ukrainian law analogous to the EU AI Act.

The first stage is based on self-regulation, voluntary commitments, codes of conduct, risk assessment, regulatory sandbox work, AI labelling initiatives, sector-specific recommendations and adaptation of human-rights impact assessment methodologies. The official roadmap refers to preparation of a regulatory sandbox and the development of Ukrainian law analogous to the AI Act during the 2023–2026 period.

Financial-sector AI

The National Bank of Ukraine has also published an official page on AI use by participants in the financial services market. The NBU states that Ukraine currently has no adequate legal framework or designated law to regulate AI, but that strategic documents provide for phased introduction of regulation and future sectoral guidelines. The NBU is developing sectoral guidance for ethical and responsible AI use in financial markets, with attention to consumer protection, transparency, human oversight, risk management, operational resilience, data and model requirements and information security.

Current compliance

Current AI compliance in Ukraine is therefore based on existing laws rather than a dedicated AI Act. Depending on the use case, AI may trigger requirements under data protection, consumer protection, financial regulation, cybersecurity, intellectual property, advertising, employment, criminal law or sector-specific regulation.

Penalties

There is no single Ukrainian AI-specific penalty table at this stage. Penalties depend on the underlying law breached. For example, an AI system that unlawfully processes personal data, misleads consumers, infringes intellectual property or violates financial-services rules would be assessed under those existing legal regimes.

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