CIPESA Urges Kenya to Align and Strengthen Its Draft AI Policy

By Raylenne Kambua |

In August 2026, the Collaboration on International ICT Policy for East and Southern Africa (CIPESA) submitted a detailed set of recommendations to the Committee on the Draft Kenya Artificial Intelligence (AI) and Other Emerging Technologies Policy, 2026. The submission calls for closer alignment of Kenya’s policy with regional and international AI frameworks, alongside stronger protections for fundamental human rights.

The submission emphasises the need for Kenya to strike a balance between its aspirations for AI governance and strong safeguards that protect human rights, people, and democratic values. Without these, the nation risks developing systems that are innovative but exclusive, unfair, and harmful.

CIPESA argues that since Kenya is simultaneously advancing multiple AI-related processes, including a national AI strategy, a proposed AI Bill, and this draft AI policy, there is a need to align and harmonise the different proposed frameworks to ensure coherence and mitigate the risks of duplication and contradictory provisions.

For example, under section 3.5.1, the Policy commits the government to develop a dedicated AI and other Emerging Technologies Governance Act to provide the legal framework for its governance in Kenya, including the establishment, powers, and functions of the Council, without acknowledging that a similar Bill is already before the Senate.

Kenya’s policy direction is influenced by constitutional obligations as well as wider regional and international commitments that underscore the importance of human rights, accountability, transparency, and inclusiveness. According to CIPESA’s submission, Kenya should incorporate these principles into legally binding policy measures rather than just mentioning them.

The submission further encourages collaboration within the East African region and across the African continent, pointing to the value of shared standards, combined knowledge, and coordinated advocacy in strengthening governance outcomes.

CIPESA’s Navigating the Implications of AI in Kenya report also highlights that AI is reshaping digital participation, information access, and democracy in Kenya. In the absence of explicit protections and clear safeguards, AI systems can perpetuate discrimination, facilitate surveillance, violate people’s right to privacy, restrict freedom of expression, and undermine livelihoods. A rights-based approach that includes mandatory human rights impact assessments will ensure that potential harms are identified and mitigated before systems are deployed.

While the draft policy outlines institutional structures and governance ambitions, CIPESA argues that effective oversight will depend on institutional independence, clear powers, and meaningful accountability. The submission raises concerns about the proposed AI Council’s institutional independence and recommends giving it explicit authority to audit, obtain information, enforce compliance, and report directly to Parliament.

In automated systems, decision-making processes are often opaque and distributed across multiple actors. CIPESA therefore recommends clearly defining responsibilities and liability so that individuals harmed by AI systems have effective redress mechanisms.

Effective AI governance requires technical expertise, resources, and coordination across multiple agencies, yet many institutions in Kenya remain under-resourced. Therefore, proposed governance frameworks should be realistic about the state’s ability to implement and enforce stronger oversight mechanisms by investing in institutional capacity and talent retention.

According to CIPESA’s research, AI content moderation on major platforms is built largely for the Global North, with low-resource African languages. Many AI systems deployed in African contexts are trained on datasets that do not reflect local realities, leading to biased outcomes with direct implications for fairness, inclusion, and accuracy. This necessitates strong local data ecosystems and locally relevant content moderation systems and languages.

Kenya’s 2025 High Court ruling on the Worldcoin iris-scanning project affirmed the need for stronger data protection measures and integration with AI-specific legislation. According to CIPESA, incorporating pre-deployment oversight would transform AI governance from a reactive to a proactive model, particularly regarding sensitive biometric data.

AI systems are resource-intensive, consuming a lot of energy and requiring large amounts of water for data centre cooling. They also emit carbon and ultimately contribute to electronic waste. The submission recommends environmentally sustainable approaches, including independent third-party verification of environmental disclosures and publication of verified information in the public Registry.

The African Union AI Strategy identifies disinformation as a distinct risk. AI can influence public discourse by deciding which information is promoted, suppressed, or amplified. Disinformation, manipulation, targeted harassment, technology-facilitated gender-based violence (TFGBV), and AI-generated deepfakes can create particular risks in civic and democratic spaces, with disproportionate effects on women and other vulnerable groups. CIPESA proposes explicit recognition of these threats, implementation of gender impact assessments for high-risk systems, and stronger oversight of AI use in elections, political advertising, and content moderation.

Another recommendation is the inclusion of civil society representation at the steering committee, which is the top decision-making level. This is to ensure meaningful participation and alignment with the African Union AI Strategy and the UNESCO Recommendation on the Ethics of AI, which call for inclusive, multi-stakeholder involvement in AI governance, especially where major decisions are made.

Inclusion and public participation also require accessible language and processes that enable broader public engagement with what are often complex and technical issues, through investments in digital literacy and public awareness.

The submission further underscores the importance of labour rights and the often invisible workforce behind AI systems, many of whom work in unfavourable conditions. By highlighting the need for fair labour standards, protections, and recognition of data work, CIPESA also recommends including the workforce that sustains AI ecosystems in high-level policy discussions.

Explainability and transparency are essential to accountable AI governance. For people to trust AI systems, they need to understand how AI-driven decisions are made and contest results they believe to be unfair.  To prevent AI systems from being treated as black boxes beyond public scrutiny, there must be clear documentation, disclosure standards, and rights to explanation. This builds accountability and trust, especially in high-risk sectors like public services, healthcare, and finance.

Finally, CIPESA highlights the necessity of continuous policy review and adaptation, emphasising that governance frameworks must remain adaptable and responsive as AI technologies evolve quickly. This includes establishing mechanisms for periodic review, stakeholder feedback, and iterative policy development to ensure that regulations remain relevant and effective over time.

CIPESA’s recommendations provide a mechanism to close the gap between ambition and accountability as Kenya works to finalise its AI policy. The decisions made at this point will influence not only the development, deployment, and application of AI but also the distribution of its benefits and risks.

Key recommendations from CIPESA:

  1. Align Kenya’s AI policy and legislation to avoid duplication and conflicting provisions.
  2. Make human rights and gender impact assessments mandatory for high-risk AI systems.
  3. Strengthen the independence and powers of AI oversight institutions, including audit, enforcement, and redress.
  4. Protect workers across the AI value chain, including data annotators and content moderators.
  5. Require environmental accountability for AI, including disclosure and independent verification of energy, water, emissions, and e-waste impacts.
  6. Ensure transparency and meaningful participation, including stronger safeguards for AI-generated political content and a formal role for civil society in AI governance.

Read the full submission here: CIPESA Submission on Kenya’s Draft AI and Emerging Technologies Policy.

Rethinking Africa’s Approach to the Politics of AI Governance and Regulation

By Paul Kimumwe |

The past few years have witnessed a growing urgency for frameworks that regulate and harness the development and implementation of new and emerging technologies, especially Generative Artificial Intelligence (Gen AI).

At the international and regional level, the United Nations (UN) and the African Union (AU) have established norms through resolutions, strategies and guidelines to affirm the relationship between technology and human rights, and provide benchmarks for Member States developing rights-respecting AI governance and regulatory frameworks.

In March 2024, the UN adopted a landmark resolution on the promotion of “safe, secure and trustworthy” artificial intelligence (AI) systems that also benefit sustainable development. The resolution also calls upon Member States and other stakeholders “to refrain from or cease the use of artificial intelligence systems that are impossible to operate in compliance with international human rights law or that pose undue risks to the enjoyment of human rights.”

The 2024 resolution reaffirmed that “the same rights that people have offline must also be protected online, including throughout the life cycle of artificial intelligence systems.” It called upon member states to ensure that national AI governance and regulatory frameworks “promote safe, secure and trustworthy artificial intelligence systems” that are inclusive and benefit everyone in an equal manner.

In August 2025, the UN adopted resolution 79/325, establishing the Independent International Scientific Panel on AI and Global Dialogue on AI Governance. It aims to provide a platform to discuss international cooperation, share best practices and lessons learned, and to facilitate open, transparent and inclusive discussions on AI governance. However, a year earlier, in July 2024, the AU adopted the Continental AI Strategy, which emphasises the development of robust governance regimes for AI founded on ethical principles, democratic values, human rights, and the rule of law, in line with the AU  Agenda 2063.

Both the UN resolutions on AI and the AU continental strategy came on the backdrop of other AI-related policy guidelines such as Center for AI and Digital Policy’s 2018 Universal Guidelines for AI, the Organization for Economic Cooperation and Development (OECD) 2019 AI Principles / G20 AI Guidelines, the United Nations Education Scientific and Cultural Organization (UNESCO’s) 2021 Recommendation on the Ethics of AI, and the European Union Commission’s (EUC) 2024 European Union AI Act.

Many African countries have been actively developing AI-related laws, policies, and strategies. Rwanda was the first to adopt a national AI policy in 2019, followed by Ghana’s National Artificial Intelligence Strategy in October 2022, Egypt’s National Artificial Intelligence Strategy in January 2025, and Kenya’s own strategy in May 2025. Benin, Côte d’Ivoire, Ethiopia, Mauritius, Nigeria, Tunisia, Zambia, and Zimbabwe are among others that have developed AI policies or strategies. Others, such as Burkina Faso, Guinea, Lesotho, Mali, Namibia, and Uganda, are still at different stages in developing their AI policies or strategies.

A case of history repeating itself?

While all these have been welcome developments in the governance and regulation of AI, studies show that the adoption of international and regional human rights instruments and national laws, policies and strategies is often just the first step in a long process. If not well managed, it often results in provisions that are, although of a progressive nature, are hard to implement and fail to address local needs and realities.

This is because the process of drafting these laws and strategies in many developing contexts is often devoid of meaningful multistakeholder consultations and engagement. Moreover, there has also been a tendency to adopt and replicate models from the global North, whose texts, while progressive, have faced strong resistance from Member States as they sometimes do not align with local contexts and cultural norms.

For example, many African countries, including Algeria, Ethiopia, Cameroon, Kenya, Mauritius, Namibia, Rwanda, South Africa, and Uganda, expressed strong reservations about certain provisions contained in the Protocol to the African Charter on Human and People’s Rights on the Rights of Women in Africa (Maputo Protocol).

Additionally, most of these models are state-centric and grounded in frameworks that create a distinct binary between duty-bearers and rights-holders, but do not articulate how and what each party needs to do to ensure meaningful implementation of the initiatives.

While the state-centric and rights-based approaches may seem attractive, in practice, their relevance in advancing digital rights is often undermined, especially when the prescribed provisions and action points do not align with the country’s current social, economic and political realities. Indeed, cases abound in which initial promises have fizzled over time due to the political leadership’s inaction (and sometimes unwillingness) to fully adopt and implement the resolutions or strategies.

For example, it took almost nine years for the African Union Convention on Cyber Security and Personal Data Protection (Malabo Convention) to enter into force on June 8, 2023, after its adoption in 2014. Indeed, more countries (40) have enacted data protection laws as compared to those that have ratified (16), highlighting a disconnect between national legal reforms and their commitment to continental frameworks. Similarly, the AU Protocol to the African Charter on Human and Peoples’ Rights on the Rights of Persons with Disabilities in Africa, adopted on January 30, 2018, took six years to enter into force, after the 15th ratification was achieved.

More critically, however, the lack of political will often reflect in the absence of clearly defined funding mechanisms for the implementation of these policies and strategies. As a result, even well-designed and progressive frameworks face implementation challenges due to structural flaws and insufficient funding.

For example, while Africa has scored highly in enacting Data Protection laws, which have become central to ongoing AI governance frameworks, one issue affecting their effective implementation is the lack of clear funding mechanisms for the regulatory bodies responsible for oversight and implementation. Other challenges include weak governance structures that deny these oversight bodies financial, decisional and operational independence and place them under the supervision of political appointees rather than parliament.

Designing for Failure?

Apart from Kenya, most African countries that have developed or are in the process of developing an AI strategy or policy do not provide for budgetary allocations or estimates for the implementation of their AI strategies, laws or policies. Countries such as Rwanda provide for a project-level funding framework, while others, such as Egypt and Mauritius, rely on programmatic budgets to fund the implementation of their strategies.

Even then, while implementation of Kenya’s National Artificial Intelligence Strategy (2025–2030) was costed at KSh 152 billion over a period of five years, a review of Kenya’s 2026/27 national budget shows no dedicated funding allocation for the strategy. Instead, the Sh8.6 billion allocated to the ICT sector mainly targets the expansion of broadband access, the strengthening of digital skills, and the digitisation of government services.

Additionally, in countries such as Ethiopia and Rwanda, while the policies provide for the establishment of an implementation body, several functions have been split across different ministries, departments and agencies (MDAs), which, in practice, would pose a significant challenge to meaningful execution.

For example, Rwanda’s AI policy mandates the Responsible AI office under the Ministry of ICT and Innovation to be responsible for effective tech implementation. It also positions the Rwanda Utilities Regulatory Authority (RURA) as the technical regulator responsible for developing ethical AI guidelines and principles, and the National Cyber Security Authority (NCSA) to oversee data protection compliance relevant to AI systems.

In Ethiopia, the policy designates the Ethiopian Artificial Intelligence Institute (EAII) as the national coordinating body responsible for implementation, standards development, and capacity building, and the Ministry of Innovation and Technology is responsible for providing policy oversight. Other sectoral agencies, such as the Ethiopian Communications Authority (ECA), the Ministry of Health, and the National Bank, have mandates over telecommunications and data matters, health-sector-related AI, and financial AI, respectively.

While a multisectoral approach to policy and strategic implementation can improve cohesiveness and legitimacy, the approach is prone to risks such as divergent priorities, internal conflicts, power struggles, and regulatory fragmentation, which are likely to affect how the policies and strategies are executed.

Implications for the Future of AI Governance and Regulation

In many African countries, the development of AI governance and regulatory structures is still in its infancy and presents a unique opportunity for Africans to shape their own destiny on how AI should be developed and deployed in ways that respond to and respect local needs and contexts.

Enactment of AI-specific Laws

In many countries, governments are relying on existing laws, such as data protection, communications, and cyber-related legislation, alongside the AI policies and strategies being developed. Given the evolving nature of AI, countries need to work towards enacting AI-specific laws that clearly define and contextualise AI.

Empowering the Oversight Bodies

As currently structured, many of the existing and proposed oversight bodies are either not yet operational or lack a clear mandate and sufficient resources for effective oversight. Additionally, many of them are situated within fragmented regulatory environments with overlapping responsibilities, which results in uncoordinated implementation. It is important, therefore, that the mandate of the oversight bodies and resources are clearly defined and guaranteed to ensure independence and eliminate the possibility of political interference.

Meaningful Stakeholder Participation

Having empowered stakeholders who are meaningfully engaged and participate in the development processes for policies, laws and strategies is critical to ensuring that the resulting instruments address real needs, are people-centred and implementable, and have government buy-in, as reflected in the government’s funded priorities.

Adopting a Human Rights-Centred Approach

A 2025 study by CIPESA shows that in many countries, the adoption of a human rights-centred approach to AI governance remains aspirational due to gaps in implementation, technical capacity, and stakeholder engagement in policy development and implementation. It is important, therefore, that current efforts prioritise safeguarding fundamental human rights and freedoms, enhancing human capabilities over replacement, and ensuring meaningful human control, transparency, fairness, and inclusivity in AI systems.

What Global South Civil Society Wants from AI Governance

By CIPESA Writer |

As global discussions on the future of Artificial Intelligence (AI) governance take place at the AI for Good Global Summit and the Global Dialogue on AI Governance, questions about who shapes AI systems, whose interests they serve, and how affected communities can participate in decision-making are becoming increasingly urgent.

The Collaboration on International ICT Policy for East & Southern Africa (CIPESA) is pleased to share this joint statement by the Global Digital Justice Forum and the Global South Alliance, of which it is a member. The statement reflects concerns that CIPESA has consistently raised through its research and policy engagement, namely, current approaches to AI development risk deepening existing inequalities, and meaningful AI governance requires stronger corporate accountability, equitable data governance, and investment in public-interest AI infrastructure.

Through submissions to national AI strategies in Africa, analysis of AI governance trends across 14 African countries, and engagement with global AI policy discussions, CIPESA has consistently advocated for inclusive, rights-based approaches that ensure communities most affected by AI developments have a meaningful role in shaping its future.

The statement below brings together civil society perspectives from across the Global South and calls for an AI governance approach grounded in human rights, equity, public interest, and meaningful participation.

Joint Statement issued by the Global Digital Justice Forum and the Global South Alliance in the lead-up to the Global Dialogue on AI Governance

July 2026

The current trajectory of Artificial Intelligence (AI) innovation has consolidated the neocolonial structures of development. Today, a handful of US and Chinese transnational corporations dominate global AI systems. Driven by massive capital, semiconductor manufacturing dominance, and hyperscale cloud infrastructure, these companies control over 90% of global AI data center capacity. Their market capitalization exceeds the combined national income of many countries in the Global South. The wealth and power amassed by these corporations come at a staggering cost, borne disproportionately by the South. From the devalued, dehumanizing labor that is essential for training AI models to the critical minerals, land, energy, and water, communities in the South continue to provide the scaffolding for the AI economy and society, without the voice and power to shape and benefit from this paradigm. These systemic injustices also perpetuate deep dependencies on current and future infrastructures — over which communities lack control and sovereign agency.

The Global Digital Justice Forum (GDJF) and the Global South Alliance (GSA) believe that the emerging AI order lacks legitimacy; it grants unbridled impunity to powerful corporations, while reducing humanity and nature to objects of limitless extraction. The many summits and conversations about AI governance have failed to tackle these core issues. 

Against this backdrop, we exhort the UN Global Dialogue on AI Governance to deliver on a South-led AI paradigm, anchored in a vision of rights-based development, respectful of planetary boundaries, and committed to intergenerational justice and human rights. We urge that the Global Dialogue on AI Governance commit to the following.

  • End AI extractivism 

A ‘move-fast-break-things’ approach to digital innovation aids profit, not people. In particular, the systemic and collective risks and harms associated with the violation of human rights, the erosion of democratic processes, the abuse of the environment, and the discrimination and invisibility of marginalized citizens in AI-driven decision-making in public services remain consistently ignored and underplayed in international consensus declarations. AI innovation must embrace the precautionary principle. It must be ethically and transparently developed, democratically accountable, and grounded in a globally agreed minimum floor for meaningful and dignified work, pluralistic knowledge, diversified economies, and planetary flourishing.

  • Apply the Common But Differentiated Responsibilities (CBDR) principle in international AI cooperation

The reckless path of data and AI technologies, designed and controlled by a few, has led to predatory value capture, strengthening the geo-economic and geo-political power of a handful of corporate actors and countries. The human and planetary costs arising from such opportunism are indeed a common concern. However, power diff erentials in international economic law have led to a status quo where trade, taxation, and Intellectual Property regimes clearly disadvantage developing countries, disproportionately enabling a massive transfer of wealth from the South to the North. This seriously undermines the development of digital infrastructure and human and institutional capabilities in developing countries. Such asymmetry must be remedied through global commitments to underwrite the development of regenerative, locally-led, AI infrastructures and models in the South.

  • Address corporate impunity in data and AI value chains

A global moratorium on the sale and use of AI systems that pose a high risk to human rights (such as remote biometric recognition, social scoring, spyware, and AI-driven autonomous weapons) is urgently needed. The proposed UN Binding Treaty on Transnational Corporations (TNCs) to hold global businesses accountable for human rights violations and environmental degradation in supply chains needs to be adopted without delay and appropriately future-proofed against the specific risks of harms and abuses in data and AI value chains.

  • Design a data governance framework that delivers on global equity

A ‘one-size-fits-all’ policy playbook for cross-border data flows governance will not deliver on equitable development. Development sovereignty must be recognized as a core principle in the global governance of cross-border data flows. Furthermore, the governance of the non-personal data commons requires a societal approach that includes safeguards for collective privacy and the rights of communities to steward the use and re-use of their data resources in innovation ecosystems, together with strong personal data protection rights.

  • Invest in the development of global public compute

The foundational infrastructure of compute is controlled by a few corporations. Even open-source AI models are often dependent on closed/proprietary infrastructure systems for their hosting and distribution. To ensure that data science and AI innovation deliver on public innovation, a global facility for public compute is needed. A ‘CERN for AI’ could support a distributed network of AI research centers coordinated by a central hub and provide access to innovators and researchers from developing countries.

The current trajectory of AI innovation is not working for the majority. The Global Dialogue on AI Governance must move the needle with conviction and courage towards people’s participation, planetary wellbeing, and public value. Anything less will not do justice to the people of the South.

Please find the links to prior submissions from GDJF and GSA to official consultations of the Global Dialogue below:
GDJF’s April 2026 submission
GSA’s April 2026 submission

Accelerating Digital Accessibility and Solutions for Africa’s Future

By Raylenne Kambua |

More than 150 million persons with disabilities across Africa navigate a digital landscape not designed for them, with inaccessible websites, unusable mobile applications, unreachable government services, and educational platforms that often lock them out. This exclusion carries a direct economic cost, which the World Bank estimates at 3–7% of countries’ Gross Domestic Product.

Increasingly, connectivity for persons with disabilities has become less a question of infrastructure coverage and more about accessibility and meaningful usage. While internet services are available to 85% of Africa’s population, 64% of those within coverage do not use them, with persons with disabilities among the most excluded groups. The exclusion has been reinforced by the high costs of devices, with some markets taxing entry-level smartphones up to 50%, making them unaffordable for low-income households.

Figures from the Assistive Technology Landscape in Africa Report show that only one in ten people who need assistive technologies across the continent have access to them, while 85% of mobility devices are still imported. This is a reflection of weak local production systems and heavy reliance on external supply chains.

At the seventh Inclusive Africa Conference, convened by inABLE in Nairobi from June 2–4, 2026, conversations examined whether Africa’s fast-expanding digital economy works for everyone or reproduces recurring forms of exclusion.

As Irene Mbari-Kirika, Executive Director of inABLE, noted, many technologies continue to fail because they are not developed with persons with disabilities in mind. This means that such devices can not be used by millions of potential users, and it has direct consequences for several users’ financial autonomy, privacy, and safety, especially in digital financial services such as mobile money.

Africa’s challenge is therefore not only access to assistive technologies, but the absence of a coherent local ecosystem for their design, production, distribution, and implementation. Building a sustainable assistive technologies value chain grounded in local materials, regional manufacturing, and culturally and linguistically relevant design is increasingly central to closing this gap.

The structural barriers to inclusion are deeply embedded across sectors, including in the education sector, where teacher training often excludes digital accessibility, curricula are rarely tested with assistive technologies, and assessment methods continue to assume uniform modes of learning and expression. These gaps, including digital literacy gaps, are compounded by the limited availability of African-language datasets, particularly for learners with communication disabilities, which constrains the development of inclusive digital and artificial intelligence (AI)-enabled learning tools.

Notably, AI presents both opportunity and risk for digital inclusion. The outcome depends on whether inclusion is embedded in design, data, and deployment. On the upside, AI-enabled tools have expanded access for blind and low-vision users, while applications in healthcare are widening access to psychosocial support on a continent with less than two mental health professionals per 100,000 people. Real-time sign language translation and voice-to-text tools are also creating new pathways for participation.

At the same time, without targeted upskilling and bias audits, AI risks simultaneously opening one door for persons with disabilities while closing others. For example, AI systems are automating roles such as data entry, transcription, and customer service, which have historically provided key employment pathways for persons with disabilities. Yet, AI models trained on biased or unrepresentative datasets and automated decision-making processes risk excluding persons with disabilities from recruitment systems.

Mercy Ndegwa, Director of Public Policy for Africa at Meta, stressed this point, noting that AI systems can only reflect communities whose data and voices are included in their design and training. This makes the inclusion of organisations of persons with disabilities in AI governance not only a rights imperative but also a technical requirement for building functional systems.

However, African-language datasets remain severely underdeveloped,  and the cost of building them at scale is prohibitive for most actors.

The launch at the summit of the development of Africa’s first Harmonised Digital Accessibility Standard for ICT Products and Services marks an important step toward continent-wide alignment. The 24-month participatory process targets adoption across all 45 African Organisation for Standardisation (ARSO) member countries. The regional standard will be adapted to African languages, culture, and infrastructural realities, changing the procurement baseline for governments while setting a compliance reference for private technology developers across the continent. Fourteen countries have reportedly confirmed participation.

Throughout the discussions, the principle “Nothing about us without us” remained central, with an acknowledgement that persons with disabilities are contributors, decision-makers, and leaders in designing systems that affect them, and not merely end-users or research subjects to be consulted only after decisions are made. Design consultant Rama Gheerawo framed this through three registers: designing for, designing by, and designing with persons with disabilities as co-creators throughout all processes.

CIPESA has been emphatic that governments, regulators, and telecommunication operators bear the greatest responsibility for digital inclusion for persons with disabilities. Civil society efforts cannot substitute for enforceable action and measurable implementation. Limited capacity to engage in technical standard-setting also continues to hinder progress on digital rights for persons with disabilities. At the same time, fragmented approaches and shifting donor priorities are placing increasing strain on the sustainability of this work.

The European Union (EU) AI Act sets a benchmark for how regulation can protect marginalised groups, while the African Union (AU) Continental AI Strategy provides guiding principles on how AI should be developed, governed, and used across the continent. However, no African has developed definitive AI legislation, although several are developing policies or strategies. As CIPESA has emphasised, AI policy frameworks across Africa must include persons with disabilities from the outset.

More specifically, efforts must be geared toward fixing AI at the source by including representatives of persons with disabilities in training data, ensuring algorithmic accountability, and making AI-powered public services accessible to all. Moreover, all AI regulations and policies must have explicit disability provisions.

Additionally, governments must reduce sector-specific taxes on entry-level assistive devices and assistive technology hardware, and mandate that Universal Service Access Fund disbursements include explicit, measurable targets for connectivity for persons with disabilities.

Zimbabwe’s National AI Strategy: Policy Lessons for Africa

By Edrine Wanyama |

Zimbabwe recently adopted its National Artificial Intelligence (AI) Strategy 2026–2030 (AI strategy)  to guide digital technology and transformation in the country. The strategy aims to accelerate development, enhance industrialisation, and improve service delivery in sectors such as health, finance, agriculture, education and public administration. The strategy emphasises building local data infrastructure as opposed to relying on foreign data storage infrastructure while promoting an AI governance approach grounded in Ubuntu, human rights, accountability, transparency and inclusivity.

However, an important question is whether Zimbabwe’s approach offers useful lessons for other African countries developing national AI strategies.

Lessons for Other African Countries

The country’s AI strategy is organised around six pillars that together map a practical path for AI adoption and deployment. First, AI talent and capacity development is essential for ensuring that institutions have the skills needed to implement AI effectively. Second, AI infrastructure and computational sovereignty are necessary for ensuring digital and data sovereignty. Third, AI adoption and service transformation are critical for supporting the integration of AI across public and private sectors to improve their productivity, accountability and transparency.

The fourth pillar, AI governance, ethics and regulation, is essential for building public trust and creating a framework that supports responsible innovation. The fifth pillar, AI research, development, and innovation, can drive investments, expand knowledge production and strengthen academic output. The sixth pillar, strategic international collaboration, presents an opportunity for global partnerships with key players and stakeholders, technology exchange, and potentially greater investment.  

Consequently, these pillars offer useful lessons for other countries seeking to harness AI for socio-economic transformation while protecting data rights and data sovereignty.

Alignment with the African Union (AU) AI Strategy

Zimbabwe’s AI Strategy reflects several priorities contained in the AU Continental Artificial Intelligence Strategy, particularly the emphasis on coordinated AI governance, digital sovereignty, and sectoral innovation. Zimbabwe’s strategy aims to harmonise the deployment and use of AI across sectors such as health, finance, agriculture, education and public administration through common governance benchmarks for AI governance. If implemented effectively, these goals could help to address digital neo-colonialism, an issue that has been dominant in Africa’s technological space.

The Strategy also places strong emphasis on AI as a tool for socio-economic development, aligning with Agenda 2063 and the Sustainable Development Goals (SDGs), particularly in sectors such as health, agriculture, and education. The Strategy promotes the deployment of AI to improve agriculture through crop disease prevention, as well as mining and mineral development, which is consistent with the AU AI strategy’s priorities on resource optimisation and climate resilience.

However, Zimbabwe faces significant governance and implementation challenges. The country scored 0 in the 2024 Global Index on Responsible AI Governance, highlighting the gap between policy ambition and institutional readiness. This means it requires major actions to implement the strategy, such as the establishment of robust legal safeguards, accountability mechanisms, oversight institutions, and rights-based governance frameworks, which are also emphasised within the AU strategy.  Other African countries can draw lessons from Zimbabwe’s approach, such as the need to complement AI strategies with stronger governance capacity, clearer regulatory safeguards, and more coherent data governance frameworks to support responsible and accountable AI deployment.

UNESCO Guidance on AI

The UNESCO Recommendations on Ethics of Artificial Intelligence, adopted in 2021, is a global normative framework that promotes human rights, including human dignity, transparency, fairness, human oversight in AI systems, and democratic participation. It also provides practical policy action areas covering issues such as data governance, gender, education and research, health, and social wellbeing.

While the UNESCO Guidance is emphatic on ethical and privacy considerations, Zimbabwe’s strategy falls short. Ambitions to integrate AI into public service delivery sectors such as education, health, and public administration will require stronger safeguards to ensure alignment with the human-centric principles articulated in the UNESCO framework. In the age of AI, data security concerns, intellectual property rights, algorithmic bias, and institutional accountability are central to responsible deployment of AI and require clearer policy and regulatory attention.

Similarly, the UNESCO Guidance warns against the use of AI in a manner that undermines democratic participation, civic engagement, and collective decision-making. This is especially important in contexts where surveillance technologies such as facial recognition, drone monitoring, communication tracking, and social media surveillance are deployed without clear safeguards or independent oversight. Zimbabwe, like several other African countries, has invested in AI-enabled infrastructures, such as the “smart city” systems to monitor and surveil citizens in ways that are opaque and lack clear accountability mechanisms.

As African countries continue developing national AI strategies and governance frameworks, they must strive to ensure that the deployment of AI is transparent, publicly accountable, and pays close attention to ethical and human rights standards. Without these safeguards, AI risks reinforcing exclusion, surveillance, and digital authoritarianism rather than advancing development.

Conclusion

Zimbabwe’s adoption of an AI Strategy is an important step toward advancing tech-enabled digital and socio-economic transformation. It also reflects the country’s intent to align national priorities with the African Union’s vision for AI-driven development across the entire continent. However, for such strategies to be effective and legitimate, they must be grounded in ethical and human rights standards laid down in regional and international benchmarks.