Compliance

AI System Labeling

Mechanisms to identify products or services powered by AI.

How the laws define this

Both instruments establish AI system labeling as a set of mechanisms designed to help consumers and end users identify AI-powered products and services through transparency regarding automated decision-making and the presence of AI. Where the texts diverge is in their operational detail and regulatory posture. The Roadmap for the Regulation of Artificial Intelligence in Ukraine frames labeling around disclosing the role, capabilities, limitations, and degree of automation of AI components to directly inform user choice and oversight. In contrast, the White Paper on Artificial Intelligence Regulation in Ukraine expands these mechanisms to include pilot programs, emphasizes balancing clarity against user burden, and explicitly presents labeling as a voluntary initiative implemented during a preparatory phase to foster consumer trust and awareness.

Synthesised from the 2 statutory definitions below. Each one is quoted in full, with its source.

How jurisdictions differ

What is distinctive in each definition, binding law in force first.

Jurisdiction	Instrument	Status	What is distinctive
Ukraine	Roadmap for the Regulation of Artificial Intelligence in Ukraine	In Force	Emphasizes disclosing presence and role of automated decision-making or AI components to inform user choice and oversight about system capabilities and limitations.
Ukraine	White Paper on Artificial Intelligence Regulation in Ukraine	In Force	Adds pilot programs and voluntary implementation during preparatory phase to build consumer awareness and trust while balancing clarity with user burden.

What it triggers

In the Roadmap for the Regulation of Artificial Intelligence in Ukraine, sets out voluntary mechanisms to guide domestic tech enterprises through phased AI governance.source
In the White Paper on Artificial Intelligence Regulation in Ukraine, describes voluntary tools including mechanisms and pilot programs during Stage One implementation.source

Definitions (2)

Mechanisms enabling consumers and users to identify AI-powered products and services by disclosing the presence and role of automated decision-making or AI components, thereby promoting transparency about system capabilities, limitations, and degree of automation to inform user choice and oversight.

Roadmap for the Regulation of Artificial Intelligence in UkraineDefinition 1 of 2

Mechanisms and pilot programs intended to identify AI‑powered products and services for end users, promoting transparency about automated decision‑making and the presence of AI while balancing clarity with user burden; implemented voluntarily during the preparatory phase to build consumer awareness and trust.

White Paper on Artificial Intelligence Regulation in UkraineDefinition 2 of 2

Not to be confused with

AI-Generated Content Labeling

Focuses on labeling AI-powered products and services overall, whereas AI-Generated Content Labeling specifically discloses when ads are created or modified by AI.

Algorithmic Explainability

Covers mechanisms to identify AI products and services through disclosure, while algorithmic explainability concerns the ability to understand how an AI system reaches decisions.

Questions and answers

What is required for AI system labeling in Ukraine?

Both definitions describe voluntary mechanisms. The Roadmap sets out phased governance guidance, while the White Paper elaborates Stage One tools.

How does the Ukrainian Roadmap define AI labeling?

It defines mechanisms enabling consumers to identify AI-powered products by disclosing automated decision-making or AI components to promote transparency on capabilities and limitations.

What pilot programs exist for AI labeling in Ukraine?

The White Paper includes pilot programs to identify AI-powered products for end users, implemented voluntarily to build awareness and trust while balancing clarity.