Governance

Digital sandbox

Controlled environment for experimentation with AI systems.

How the laws define this

Regulators converge on viewing a digital sandbox as a controlled, monitored environment for testing, evaluating, and developing artificial intelligence technologies under regulatory oversight. Both frameworks emphasize iterative innovation, technical evaluation, and monitoring to assess performance and compliance. However, they diverge on legal flexibility and deployment scope. Under the Policy for the Development of Artificial Intelligence in Poland from 2020, the sandbox is a supervised experimental setting with predefined conditions and mitigations to trial AI systems before broader deployment. In contrast, the Federal Law "On conducting an experiment to establish special regulation for the purpose of creating necessary conditions for the development and implementation of artificial intelligence technologies in the subject of the Russian Federation - the federal city of Moscow and amending Articles 6 and 10 of the Federal Law "On Personal Data" of April 24, 2020 N 123-FZ" creates a regime within Moscow where legislative requirements are relaxed or adapted to allow real-world observation and deployment.

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
Moscow, Russia	Federal Law No. 123-FZ of April 24, 2020 "On carrying out experiment on establishment of special regulation for the purpose of creation of necessary conditions for development and deployment of technologies of artificial intelligence in the subject of the Russian Federation - the federal city of Moscow, about features of processing of personal data when forming regional structures of data and provisions of access to regional structures of data and introduction of amendments to articles 6 and 10 of the Federal law 'About Personal Data'"	In Force (Amended)	This definition specifies a legal regime in Moscow, Russia, with relaxed legislative requirements and modified personal data processing rules for AI development, testing, and deployment.
Poland	Policy for the Development of Artificial Intelligence in Poland from 2020	In Force	This definition emphasizes supervised trials by firms and public bodies under regulatory oversight to evaluate performance, risks, and compliance before broader deployment.

What it triggers

In Moscow under Federal Law No. 123-FZ, AI technologies may be developed, tested, and deployed under a special legal regime with relaxed or adapted legislative requirements and modified personal data processing.source
Under the Policy for the Development of Artificial Intelligence in Poland from 2020, the supervised experimental environment supports innovation with mitigations in place.source

Definitions (2)

A supervised experimental environment established to allow firms and public bodies to trial AI systems and data-driven innovations under regulatory oversight and predefined conditions, enabling evaluation of technical performance, risks and compliance before broader deployment and supporting innovation with mitigations in place.

Policy for the Development of Artificial Intelligence in Poland from 2020 (Polityka dla rozwoju sztucznej inteligencji w Polsce od roku 2020) – Polityka rozwoju sztucznej inteligencji w Polsce na lata 2019–2027Definition 1 of 2

A controlled technical and legal environment within Moscow where AI technologies may be developed, tested, and deployed under the ELR, allowing certain legislative requirements to be relaxed or adapted to enable real-world observation and iterative innovation while subject to monitoring and evaluation.

Federal Law "On conducting an experiment to establish special regulation for the purpose of creating necessary conditions for the development and implementation of artificial intelligence technologies in the subject of the Russian Federation - the federal city of Moscow and amending Articles 6 and 10 of the Federal Law "On Personal Data" of April 24, 2020 N 123-FZDefinition 2 of 2

Not to be confused with

AI Regulatory Sandbox

AI Regulatory Sandbox highlights regulatory supervision during development, whereas digital sandbox encompasses broader testing and deployment under adapted rules.

Sandboxes/Testbeds

Sandboxes/Testbeds are general controlled environments for safe AI experimentation, but digital sandbox adds legal adaptations or policy frameworks for specific jurisdictions.

Questions and answers

What is the legal basis for the digital sandbox in Moscow?

Federal Law No. 123-FZ of April 24, 2020 establishes a five-year experimental legal regime in Moscow for AI developers and deployers. It sets special regulatory conditions for AI testing and modifies personal data processing.

How does Poland's AI policy use digital sandboxes?

The Policy for the Development of Artificial Intelligence in Poland from 2020 establishes supervised experimental environments for trialing AI systems. It enables evaluation of technical performance, risks, and compliance before broader deployment.

What distinguishes these digital sandboxes from general AI test environments?

Moscow's sandbox provides a controlled technical and legal environment with relaxed legislative requirements. Poland's focuses on supervised trials by firms and public bodies under predefined conditions.