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  HomeCollaboration on International ICT Policy for East and Southern Africa (CIPESA)  /  Uganda
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10Jun

Overview of CIPESA Policy Submissions to International Bodies and Governments

Author CIPESA Posted on

By CIPESA Writer |

Africa’s digital rights landscape is evolving rapidly, shaped by new legislation, emerging technologies, and recurring threats to civic space. CIPESA has remained actively engaged in documenting these developments, including through the annual State of Internet Freedom in Africa reports and through broader programming.

Over the last few months, we have made submissions to various international bodies and national governments, filed legal interventions, and provided expert commentary to advance internet freedom, digital inclusion, and democratic governance.

Below is an overview of our key submissions and commentaries in recent months.

Engaging Global Bodies on Technology Governance

Submission on How the WHO Digital Health Strategy Should Govern Data, Artificial Intelligence (AI) and Digital Public Infrastructure (DPI): In March 2026, CIPESA submitted recommendations to the World Health Organization (WHO) Regional Office for Africa on the development of the Global Digital Health Strategy for 2028–2033, urging that the strategy be anchored on human rights, equity, and accountability. CIPESA warned that most AI systems used in African healthcare are trained on non-African datasets, increasing risks of inaccurate diagnoses and exclusions, and called for mandatory “explainability” standards, equity impact assessments, and domestic investment in digital health infrastructure.

Recommendations to the OHCHR: Also in March, CIPESA submitted to the UN Human Rights Council under Resolution 58/23 on the risks digital technologies pose to human rights defenders in Africa. The submission examined legal and policy developments, tech-facilitated attacks including against women HRDs, AI-related risks, and challenges facing civil society and companies, while recommending stronger corporate measures to identify, assess, and prevent harm to HRDs. CIPESA submitted comments and recommendations on due diligence and improved responses to digital technology-related risks faced by human rights defenders.

Engaging National Governments on Digital Legislation Commentary on Zimbabwe National AI Strategy: The Southern African state recently adopted its National AI Strategy 2026–2030 (AI strategy)  to guide its digital technology and transformation. 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 also 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. Find our commentary here.

Submission on the Uganda AI and Emerging Technologies Strategy: In March 2026, CIPESA submitted recommendations to Uganda’s National AI and Emerging Technologies Strategy Taskforce, welcoming the country’s ambition to harness AI for development while cautioning that innovation must be matched with legal, institutional, and ethical safeguards. Find a commentary here.

CIPESA called for a rights-by-design approach including mandatory Human Rights Impact Assessments for high-risk AI systems, algorithmic transparency, local data representation, and meaningful civil society participation in shaping Uganda’s AI strategy.

Outpaced by Its Own Ambition: Can Kenya Bridge Its AI Regulation Gap? This commentary highlighted the raw paradox at the heart of Kenya’s AI, noting that the country is simultaneously sprinting ahead in AI adoption while grappling with a shrinking space for the very digital voices that AI empowers. A key remains between ambition and readiness as the country ranks 93rd in the 2025 Government AI Readiness Index, due to persistent weaknesses in infrastructure, implementation, and institutional capacity. Find a commentary here.

Submission to the White Paper on ICT Tax Reduction in Uganda: A year ago, CIPESA submitted a position paper to the National Task Team on Enhancement of Government Revenue from the ICT Sector at the Uganda Ministry of ICT and National Guidance. The paper benchmarked Uganda’s ICT sector tax policies, licensing fees, and regulatory regimes against those of Kenya, Rwanda, and Tanzania. Since then various developments have emerged which inform the ICT tax regime in Uganda including the April 2026 passing of the Value Added Tax (Amendment) Bill, 2026, which rejected the controversial government proposal to impose an 18 percent tax on imported software after lawmakers warned it would undermine the country’s digital transformation agenda.

Engaging the African Commission on Human and Peoples’ Rights (ACHPR)

ACHPR Resolution 630 on Monitoring Technology Companies: In March 2025, the ACHPR adopted Resolution 630, a timely step toward holding technology companies accountable for information integrity in Africa. CIPESA welcomed the move, contributed recommendations across key regional forums, and looks forward to strengthening the newly developed guidelines through the review process.

Prioritising Human Rights Defenders: CIPESA reviewed the Draft Declaration on the Promotion and Protection of Human Rights Defenders in Africa, which seeks to help restore civic space for the effective protection of human rights. In its submission to the Special Rapporteur on Human Rights Defenders and Focal Point on Reprisals in Africa, CIPESA highlighted the draft’s strengths, weaknesses, and gaps, and offered practical recommendations to align it with continental and global standards, particularly the 1998 UN Declaration on Human Rights Defenders. Find the submission here

Supporting the Ratification of the AU Disability Protocol: CIPESA has consistently called upon African Union member states to ratify the Protocol to the African Charter on Human and Peoples’ Rights on the Rights of Persons with Disabilities in Africa. Our submission to the ACHPR Working Group on the Rights of Older Persons and People with Disabilities in Africa (April 2022) argued that ratification is a matter of utmost priority and that without it, the digital rights of persons with disabilities across the continent remain inadequately protected.

Contributing to the Universal Periodic Review (UPR)

Joint Stakeholder Submission on Tanzania’s Digital Rights Record: Ahead of Tanzania’s fourth cycle UPR before the UN Human Rights Council set to take place in November 2026, CIPESA, alongside the Pan African Lawyers Union (PALU) and JamiiAfrica, submitted a joint stakeholder report documenting the state of digital rights in the country.

While acknowledging positive developments including the enactment of the Personal Data Protection Act, 2022, and reforms to the Media Services Act, the submission highlighted persistent concerns: the use of vague laws to suppress online expression, the blocking of platforms including Clubhouse, X, and JamiiForums, a nationwide internet shutdown during the 2025 general elections, and the escalating threat of Technology-Facilitated Gender-Based Violence (TFGBV) against women journalists and activists.

The submission called on Tanzania to repeal or amend vague and overly broad laws, comply with international human rights standards on internet access, establish judicial oversight over surveillance, and invest in digital rights literacy.

Rwanda’s fourth cycle UPR review: Rwanda had its UPR review in January 2026 where following the November 2025 pre-session in Geneva, several permanent missions expressed eagerness to advance strong recommendations for Rwanda, and CIPESA’s evidence and recommendations were expected to inform their engagement during the formal review.

A joint submission by CIPESA and the Association for Progressive Communications (APC) noted that digital technologies have expanded the avenues through which women are targeted, often enabling harm that is faster, more pervasive, and harder to remedy.

Rwanda’s UPR presented a timely opportunity to adopt meaningful, future-focused reforms that uphold human rights, ensure accountability, and create a digital environment where all citizens, especially women, can participate safely, freely, and equally.

Since the review, the Rwandan government has noted they would undertake national consultations with relevant stakeholders to assess the recommendations and determine its position.

Liberia’s fourth cycle UPR review: CIPESA, in collaboration with the West Africa ICT Action Network (WAICTANET), submitted a joint stakeholder submission for Liberia’s consideration during the 50th session of the UPR. The joint submission observed that, although Liberia has taken preliminary steps towards aligning its domestic legal and policy framework with applicable regional and international human rights standards, substantial legal, institutional, and enforcement gaps persist. It called for the Government to adopt comprehensive data protection and cybersecurity legislation; safeguard the right to freedom of expression online; ensure accountability for violations against journalists, human rights defenders, and online actors; strengthen transparency and effective access to information; and implement targeted measures to bridge the digital divide.

Malawi’s fourth cycle UPR review: A joint submission was made by CIPESA alongside the The Centre for Human Rights and Rehabilitation (CHRR), the International Press Institute (IPI), the University of Birmingham, and Small Media, on digital rights in Malawi. The submission recommended law reform, full implementation of the Access to Information Act, affordable and inclusive internet access, independent oversight for digital rights violations, operationalisation of the Data Protection Act, protection of encryption, and safeguards against unlawful spyware use.

Looking Ahead

Across these engagements with the ACHPR, the Universal Periodic Review of the UN Human Rights Council, the WHO, and national governments in Uganda, Kenya, Tanzania, and Zambia, CIPESA’s work reflects a consistent commitment to promoting inclusive and effective use of ICT in Africa for improved governance and livelihoods.As the digital governance landscape continues to shift, our submissions serve as a continued resource for policymakers, civil society, the media and other entities committed to advancing internet freedom in Africa.

Peter G. Mwesige, Ph.D., giving opening remarks
08Jun

Stakeholders Call for Digital Transformation That Bridges Business and Digital Rights in Uganda

Author CIPESA Posted on

By Doreen Namuyanja |

Uganda is embracing the opportunities offered by Artificial Intelligence (AI) and Digital Public Infrastructure (DPI) as drivers of national development. Both promise efficiency, improved service delivery, financial inclusion, and economic growth. However, as the country advances its digital transformation interests, questions linger on the adequacy of safeguards for citizens especially where business and rights intersect.

These questions were at the centre of a  High-Level Multi-Stakeholder Dialogue on Business and Digital Rights convened by the Collaboration on International ICT Policy for East and Southern Africa (CIPESA)  on May 7, 2026, under the Advancing Respect for Human Rights by Businesses in Uganda (ARBHR) project, supported by Enabel and the European Union (EU). The dialogue brought together 81 individuals representing government officials, civil society actors, private sector representatives, researchers, and digital innovators to reflect on the growing recognition that digital transformation is not simply a technical process, but also a governance and human rights issue that demands transparency and accountability.

The discussions at the dialogue revealed a tension between innovation and human rights. Systems such as digital identity (ID), payment platforms, and data-sharing frameworks   centralise enormous amounts of personal data and are reshaping power relationships between citizens, the government, and corporations.

Participants noted that in the absence of strong governance frameworks, these systems can enable exclusion, surveillance, and misuse of personal information. Further,  concerns were raised about fragmented systems across government agencies, weak interoperability, and limited public awareness regarding how personal data is collected, stored, and shared.

Meanwhile, as emerging technologies such AI take hold in the country,  the Uganda National AI Landscape Assessment positions  AI as a key digital technology driver to drive economic growth.

However, the Assessment documents the absence of a dedicated AI policy and regulatory framework, a shortage of AI skills, and insufficient collaboration between academia and the technology sector. Similarly, like its counterpart governments across Africa, Uganda is increasingly investing in DPI systems including digital ID and payment systems,  as well as data exchange frameworks. DPI is being positioned as a key pillar of digital transformation strategies across Africa. However, DPI  systems remain heavily reliant on public data and algorithmic decision-making. Thus, if   designed and deployed without sufficient citizen participation, independent oversight, legal safeguards, and alignment with the public interest, they risk becoming tools of exclusion, exploitation, and foreign dependency.

Various efforts related to the adoption of emerging technologies are underway.  Ambrose Ruyooka, the Assistant Commissioner at the Ministry of ICT and National Guidance, Uganda noted that the Ministry is taking a cautious approach to regulation by prioritising standards, policy guidance, and institutional learning before introducing binding laws. This includes efforts to domesticate the UNESCO Recommendations on the Ethics of AI and a Readiness Assessment process. The dialogue also came on the heels of the Ministry’s call for stakeholder input to the National AI and Emerging Technologies Strategy – signaling a growing policy focus on responsible digital transformation.

Further he stressed that in the midst of AI, stakeholders should not be “passive consumers” of the digital economy but actively “participate in shaping it” while pointing out that participation requires local technical capacity to “build, operate and audit” systems such as AI and DPI systems independently.While government efforts are laying the foundation for AI governance, businesses also have an obligation to innovate responsibly and adopt robust human rights due diligence processes to support regulatory compliance and foster trust and sustainability.

At a broader level, the dialogue demonstrated how digital rights are increasingly intertwined with economic rights and social justice. As a result, corporate responsibility can no longer be limited to traditional labour or environmental concerns. Companies are now expected to consider how their digital operations affect privacy, equality, freedom of expression, and access to information.

This shift is especially significant for Uganda’s small and medium enterprises (SMEs), many of which are digitising rapidly but often lack the resources and expertise needed to manage cybersecurity and data effectively.

Presentations from implementing partners, including the Private Sector Foundation Uganda (PSFU), Evidence and Methods Lab (EML), Wakiso District Human Rights Committee (WDHRC), Boundless Minds, and Girls for Climate Action (G4CA), highlighted both the scale of the challenge and the potential for practical intervention. Partner interventions on digital rights and cybersecurity are strengthening awareness and practices among entities – both rural and urban.

The European Union’s (EU) Commitment to Human Rights in Business

Laurianne Comard, Programme Officer at the EU Delegation to Uganda,  noted that the EU and its member states are currently among Uganda’s largest investors in the private sector, with over 1.4 billion euros deployed to foster sustainable economic growth and high-value exports. Specifically, she stated that the EU supports Uganda’s National Action Plan (NAP) on Business and Human Rights with over 20 billion Uganda Shillings, with a specific focus on strengthening human rights practices in business operations, particularly around labour standards and women’s rights.

Course-Correcting on Inclusion

Participants also noted that public participation in digital governance remains limited. Several civil society actors argued that consultations around national AI strategy have not been broad enough, particularly for rural communities, labour unions, youth groups and persons with disabilities. Frameworks developed without broad public engagement risk lacking legitimacy and failing to address the lived realities of those most affected.

The dialogue also reflected on the NAP on Business and Human Rights and the consultative processes underpinning its evaluation and development of NAP II. Lydia Nabiryo, Assistant Commissioner at the Ministry of Gender, Labour and Social Development, acknowledged that the government is actively working to broaden participation in the NAP’s revision.

Her remarks were a candid recognition that the first NAP, while a significant milestone, left representational gaps, and that those gaps are now being deliberately addressed. She noted, “If you have noticed this time round, we are having a more inclusive dialogue with stakeholders that were not necessarily represented in the first NAP. So, not only is the government evaluating, but we’re also course correcting.”   

Participation should not only be limited to policy processes. Shane Ssenyonga, an innovator, pointed out the need for collaborative spaces that support entrepreneurs and businesses to build scalable solutions that are responsive to social, cultural, and economic realities.

Recommendations for Action

The dialogue called for stronger human rights safeguards and access to remedy within digital transformation strategies and business operations. The strategies should be in harmony with existing digital laws and policies and strengthen oversight and enforcement by relevant institutions. For businesses, adoption of forward looking internal policies and risk management practices was emphasised to ensure trusted deployments and reduce barriers to uptake. Advocacy, documentation, and digital literacy interventions remain critical to public education and compliance monitoring.

08Jun

CIPESA Annual Report 2025 Highlights Agility in A Changing Funding and Policy Landscape

Author CIPESA Posted on

By CIPESA Writer |

The Collaboration on International ICT Policy for East and Southern Africa (CIPESA) is pleased to present its 2025 Annual Report. Made possible by a wide network of collaborators across Africa and beyond, our work reflects a year marked by agility, resilience, and responsiveness amid rapid shifts in technology, policy, and governance.

Across Africa, governments rapidly expanded the use of artificial intelligence (AI) and Digital Public Infrastructure (DPI), including national digital ID systems, surveillance tools, and e-government platforms, reshaping how power is exercised, services are delivered, and citizens engage with the state. At the same time, digital platforms remained central to political and civic life, amplifying both civic participation and manipulation.

Through our research, advocacy, and partnerships, the report highlights how digital transformation is reshaping everyday life and why protecting civic space and digital rights remains more important than ever.

Over the year, our work moved beyond who participates in digital governance across Africa to strengthening the quality and influence of that participation. We are deeply grateful to all our Network of allies whose support made our 2025 work possible.

In a year marked by significant shifts in the global funding landscape, their continued trust and commitment to digital rights in Africa was both enabling and affirming.

We remain committed to advancing an open, inclusive, and rights-respecting digital ecosystem in Africa, confident that when evidence, advocacy, and collective action come together, meaningful change is possible. Read more on the report below.

CIPESA Annual Report 2025
14May

Rethinking Platform Design and Accountability to Combat TFGBV in Africa

Author CIPESA Posted on

By Alice Aparo |

Africa’s rapid digitalisation, spanning e-commerce, online services, and digital infrastructure, has been accompanied by a persistent rise of Technology-Facilitated Gender-Based Violence (TFGBV). African women and girls are exposed to several forms of TFGBV, including online harassment, algorithmic discrimination, and deepfakes that prevent equal participation in online spaces.

To commemorate this year’s International Women’s Day, the Collaboration on International ICT Policy for East and Southern Africa (CIPESA) convened a webinar themed Advancing platform accountability for women’s online safety in Africa to discuss efforts to enhance women’s online safety and hold digital platforms accountable.

A key insight from the discussion was that the rise of TFGBV in Africa is amplified by platform design, limited legal enforcement, weak moderation of content by digital platforms, and a poor system for reporting abuse and harmful content. The low levels of digital literacy, poor redress and appeals mechanisms, and lack of awareness among policymakers were also cited. Many of those who experience online abuse struggle to obtain justice and, in most cases, turn to self-censorship instead. This ultimately shrinks women’s voices in public discourse.

Further, online harm is often misframed as an individual responsibility, whereas it is largely enabled by platform design features such as anonymity and algorithm-driven content amplification that support harmful behaviour and accelerate the spread of harmful content. In her remarks, Barbra Okafor, founder and Lead Strategist at The Agency Lab, said major digital platforms prioritise “profit and scale over user safety”, adding that features like reposting and seamless sharing are built for viral amplification, not user protection.

Okafor added that when content that qualifies as harassment is posted, algorithms interpret the resulting engagement as “interest” and accelerate the distribution of the abuse rather than introducing safeguards. She described these platforms as “mini-gods” that have assumed regulatory power without corresponding accountability, making online user safety secondary to profit.

Gaps in content moderation, the limited inclusion of African linguistic expertise, and weaknesses in platform design and legal frameworks raise serious concerns about technology companies’ capacity to respond to harmful content in a timely and context-sensitive manner.

The increasing reliance on Artificial Intelligence (AI) for content moderation, yet it is largely trained on Western datasets, means it continues to struggle to detect harassment expressed in African languages or to interpret culturally specific slurs. This leaves women participating in public discourse exposed to unchecked, gendered insults and coordinated digital attacks.  

While AI-based features such as deepfake detection, content filters, and automated tools such as Safety Mode and Limits exist, their effectiveness is uneven across African contexts. These measures are further constrained by structural challenges, including limited investment in local content moderation and weak legal enforcement systems.

Marie-Simone Kadurira, an independent feminist researcher and panelist, noted that digital violence often mirrors and amplifies offline abuse, reinforcing patriarchal norms through technology. This perpetuates existing gender power imbalances and harmful social norms. She added that African women, particularly those in public-facing roles such as journalism, activism, or politics, face heightened, systemic harassment.

Despite the existence of cybersecurity and data protection laws in many African countries supported by regional instruments such as the African Commission on Human and Peoples’ Rights (ACHPR) Resolutions on developing Guidelines to assist States monitor technology companies in respect of their duty to maintain information integrity through independent fact-checking (ACHPR/Res. 630 (LXXXII) 2025) and the Resolution on the protection of women against digital violence in Africa (ACHPR/Res. 522 (LXXII) 2022) – addressing TFGBV remains a persistent problem across the continent. The two resolutions emphasise the obligation of African states to protect individuals, particularly women and girls, from digital harms, including online harassment, cyberstalking, non-consensual sharing of intimate images, and other forms of abuse.

Dr. Abudu Sallam Waiswa, Head Litigation, Prosecution and Legal Advisory at the Uganda Communications Commission (UCC), said effective legal enforcement remains challenging because most major platforms, such as Meta, Google, and X, are neither based nor registered on the African continent. This creates significant jurisdictional gaps that hinder thorough investigations and accountability.

Several recommendations emerged at the discussion:

  1. Platforms must hire and train African local content moderators with linguistic and cultural expertise across African contexts.
  2. Governments must shift from reactive legislation to forward-looking, preventive frameworks. This includes mandating that platforms provide transparency on their algorithmic moderation and establishing a local physical presence to facilitate legal accountability.
  3. Civil society and policymakers need to deepen their understanding of how algorithmic systems work in order to effectively monitor and govern them.
  4. Fund women’s rights organisations to continue to provide survivor support, document abuse, advocate for policy reform, and hold both governments and tech companies accountable in the fight against TFGBV.
  5. Strengthen the ability of users to recognise, respond to, and recover from online harm.
11May

CIPESA Urges Rights-Centred Approach to Uganda’s AI Strategy

Author CIPESA Posted on

By CIPESA Writer |

The Collaboration on International ICT Policy for East and Southern Africa (CIPESA) has submitted recommendations to Uganda’s Artificial Intelligence (AI) and Emerging Technologies Strategy national taskforce, calling for a human rights-centred approach to the governance of these technologies.

The submission, made in response to the Ministry of ICT and National Guidance’s ongoing process to develop a National AI and Emerging Technologies Strategy, welcomes Uganda’s ambition to harness AI for development. At the same time, CIPESA cautions that innovation must be matched with the legal, institutional, and ethical safeguards needed to protect people from harms.

Discussions on Uganda’s AI policy come at a moment when AI technologies are already being deployed in both public and private sectors. The submission states that AI-enhanced tools are currently employed in customs risk profiling at the Uganda Revenue Authority, customer service functions, digital financial services, research organisations, and environmental monitoring initiatives.

In agriculture, AI-powered tools can support weather forecasting, pest detection, control and prevention, and tailored advice for farmers, whereas in healthcare, they can enhance disease detection, diagnostics, prescription and help address shortages in medical personnel. These applications highlight the transformative potential of AI, yet there are also concerns around surveillance, exclusion, discrimination, and misuse of personal data.

The submission is informed by CIPESA’s broader work on digital rights in Africa, including the Navigating the Implications of AI on Digital Democracy in Uganda report, which emphasises the growing impact of AI-driven technologies on online expression, political communication, surveillance practices, and civic participation.

The recommendations also build on CIPESA’s earlier work on developing an inclusive AI ecosystem for Uganda. According to the policy brief, An Artificial Intelligence Eco-System for Uganda, the country’s existing legal and policy frameworks provide a fragmented foundation for regulating AI and responding to emerging risks such as algorithmic bias, automated discrimination, opaque decision-making, and AI-enabled surveillance.

Accordingly, CIPESA calls for a rights-by-design approach to AI governance. High-risk AI systems used by both public and private actors should be transparent, auditable, and subject to independent oversight. It also calls for mandatory Human Rights Impact Assessments for AI systems used in sensitive sectors such as healthcare, agriculture, education, taxation, law enforcement, and social protection.

The submission further recommends dedicated legal and policy measures that address algorithmic transparency, automated decision-making, public-sector AI procurement, safeguards against discriminatory outcomes, and mechanisms for redress where harm occurs.

CIPESA also raises concerns about the growing use of automated systems in areas such as digital lending and mobile money services, where millions of Ugandans are already subjected to algorithmic profiling and automated credit scoring with limited transparency or accountability. The submission recommends that Uganda’s AI strategy should establish clear safeguards and oversight standards for both existing and future AI systems.

While AI presents significant opportunities for improving public service delivery and supporting development priorities, CIPESA stresses that such systems must be built using representative local datasets, and designed in ways that minimise bias, exclusion, and discriminatory outcomes.

The organisation further stresses that AI governance must be inclusive and participatory. The submission calls for meaningful involvement of civil society organisations, academia, technical experts, and affected communities in shaping Uganda’s AI strategy. It also recommends multilingual and accessible AI-enabled platforms that support citizen participation through channels that are accessible to underserved and low-literacy communities.

Beyond governance safeguards, CIPESA urges the government to invest in local AI research, innovation, and infrastructure development. It recommends support for universities, innovation hubs, and local startups, alongside the establishment of national AI research centres and dedicated funding mechanisms. Earlier recommendations by CIPESA also proposed the creation of a national AI Research Fund and citizen awareness programmes to improve public understanding of AI technologies and their societal implications.

Without deliberate investment in local capacity, Uganda risks becoming merely a supplier of raw data to foreign technology companies while deriving limited economic value from AI technologies. This would also deepen dependence on externally developed systems that may not fully reflect local contexts, needs, or priorities.

CIPESA additionally calls for alignment between Uganda’s strategy and broader regional initiatives, including the African Union Continental AI Strategy and wider African efforts on digital governance, data protection, and platform accountability.

Ultimately, CIPESA argues that Uganda’s AI and Emerging Technologies Strategy should put people first, ensuring that innovation and emerging technologies are matched with clear safeguards and meaningful oversight.

Read the full submission here: CIPESA Submissions on Uganda AI and Emerging Technology Strategy

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