Ukraine - AI Development Strategy (Order No. 1556-р)

Overview

The Concept of Artificial Intelligence Development in Ukraine was approved by the Cabinet of Ministers of Ukraine on December 2, 2020, through Order No. 1556-р, establishing Ukraine's first comprehensive strategic framework for artificial intelligence development spanning the period 2020-2030. This landmark document was presented by Vice Prime Minister and Minister of Digital Transformation Mykhailo Fedorov and emerged after a year of extensive public consultation involving civil society organizations, activists, and industry stakeholders. The concept addresses critical concerns about human rights, privacy, and ethics in AI deployment while positioning Ukraine as a regional leader in artificial intelligence development. At the time of approval, Ukraine had approximately 150 experienced AI development companies, representing the largest concentration in Eastern Europe, demonstrating the country's significant existing capabilities in this field. The strategic document aims to increase Ukraine's global competitiveness through systematic AI deployment across socio-economic, scientific-technical, defense, environmental, and national-cultural spheres. The Ministry of Digital Transformation received the mandate to develop a detailed implementation plan within three months, coordinating with the Expert Committee on the Development of Artificial Intelligence in Ukraine to execute the strategy's objectives.

Definitions

The Concept establishes foundational terminology for artificial intelligence within the Ukrainian legal and regulatory context. Artificial Intelligence (AI) is understood as a set of technological solutions enabling the simulation of cognitive functions typically associated with the human mind, including perception, learning, reasoning, problem-solving, interaction with the environment, and creative activity. AI Development encompasses research, design, creation, testing, and deployment of AI systems and technologies within Ukraine. AI Application refers to the domestic use of artificial intelligence technologies across various sectors of national importance. AI Export includes the transfer of AI technologies, systems, and expertise to international markets. Competitiveness in AI means Ukraine's ability to develop, deploy, and commercialize artificial intelligence technologies at levels comparable to or exceeding international standards. The concept emphasizes alignment with International Regulations, particularly European Union standards and OECD AI Principles, ensuring Ukrainian AI development follows globally recognized frameworks. Fundamental Rights and Freedoms in the AI context include the protection of human dignity, privacy, non-discrimination, and democratic participation in decisions affecting citizens through automated systems.

Governance and Institutional Framework

The governance structure for implementing the Concept of Artificial Intelligence Development is centered on the Ministry of Digital Transformation of Ukraine, which serves as the primary coordinating body for all AI-related initiatives. The Ministry operates in conjunction with the Expert Committee on the Development of Artificial Intelligence in Ukraine, established on December 21, 2019, specifically to increase Ukraine's competitiveness in the artificial intelligence field. This Expert Committee is chaired by Oleksiy Molchanovskyi, with Timofiy Milovanov serving as Co-Chairman for Regulation and Deputy Minister Oleksandr Bornyakov representing the Ministry. The Committee operates through four specialized working groups: AI + Public Administration (headed by Andriy Zablovskyi), AI + Education/Science (headed by Dmytro Chumachenko), AI + Security/Defense, and AI + Regulation (co-chaired by Timofiy Milovanov). Each working group focuses on sector-specific implementation challenges and opportunities. The Cabinet of Ministers of Ukraine provides overall strategic direction and approves major policy decisions related to AI development. Implementation coordination involves multiple government agencies depending on sector-specific applications, including the Ministry of Education and Science for educational initiatives, the Ministry of Defense for security applications, and various regulatory bodies for sector-specific oversight. The governance framework emphasizes multi-stakeholder participation, including civil society organizations, academic institutions, and private sector representatives, ensuring that AI development proceeds with broad societal input and oversight.

Key Focus Areas

• Socio-Economic Development: represents a primary focus, with AI technologies intended to enhance productivity, create new economic opportunities, and improve public services. The concept emphasizes.
• Scientific and Technical Advancement: , promoting AI research capabilities, strengthening academic institutions, and fostering innovation ecosystems that can compete internationally.
• Defense and Security: constitutes a critical focus area, with AI applications aimed at enhancing Ukraine's defense capabilities, improving cybersecurity, and supporting national security objectives—a priority that gained even greater significance following Russia's full-scale invasion in 2022.
• Environmental Protection: represents another key area, with AI technologies deployed for environmental monitoring, resource management, climate change adaptation, and sustainable development initiatives.
• National-Cultural Preservation: includes using AI to digitize and preserve cultural heritage, support Ukrainian language technologies, and promote national identity in the digital age.
• Legislative Harmonization: focuses on aligning Ukrainian AI regulations with international standards, particularly EU frameworks and OECD principles, facilitating Ukraine's European integration objectives.
• Research and Development: emphasizes building Ukraine's AI research infrastructure, promoting academic excellence, and creating pathways from research to commercial application.
• Database Access: involves creating frameworks for appropriate data sharing to support AI development while respecting privacy and security requirements.
• Global Market Competitiveness: aims to position Ukrainian AI companies and professionals as world-class competitors, expanding export opportunities and attracting international investment.
• Education and Training: focuses on developing AI literacy across society, training AI specialists, and preparing the workforce for AI-driven economic transformation.
• Ethical AI Development: emphasizes human rights protection, transparency, accountability, and democratic values in all AI applications.

Implementation Framework

The implementation of the Concept operates through a phased approach spanning 2020-2030, with the Ministry of Digital Transformation responsible for developing detailed action plans within three-month intervals following approval. The framework emphasizes a bottom-up approach that evolved into the 2023 Roadmap and 2024 White Paper, prioritizing voluntary industry self-regulation before introducing mandatory legislative requirements. Implementation proceeds through several parallel tracks: Legislative Development involves drafting and enacting laws to regulate AI development, application, and export in accordance with international standards; Regulatory Framework Creation establishes sector-specific guidelines and oversight mechanisms; Infrastructure Development builds the technical foundation necessary for AI deployment, including computing resources, data infrastructure, and connectivity; Research Capacity Building strengthens academic institutions, funds research initiatives, and creates centers of excellence in AI; Industry Support provides resources, incentives, and regulatory clarity to private sector AI developers; International Cooperation establishes partnerships with leading AI nations, participates in international AI governance initiatives, and aligns with European standards; Public Awareness and Education promotes understanding of AI benefits and risks across society; and Multi-Stakeholder Engagement ensures ongoing dialogue between government, industry, academia, and civil society. The Expert Committee on the Development of Artificial Intelligence coordinates implementation across these tracks, with specialized working groups addressing sector-specific challenges. Quarterly progress reviews and annual assessments track implementation against established objectives, allowing for adaptive management as the AI landscape evolves. The framework deliberately maintains flexibility to respond to rapid technological changes while maintaining core commitments to human rights and democratic values.

Monitoring and Evaluation

The monitoring and evaluation mechanisms for the Concept involve regular assessment processes coordinated by the Ministry of Digital Transformation in collaboration with the Expert Committee on the Development of Artificial Intelligence in Ukraine. Progress Tracking occurs through quarterly reports from implementing agencies detailing achievements, challenges, and resource allocation across the concept's various focus areas. Annual Reviews provide comprehensive assessments of implementation status, measuring progress against established objectives and identifying necessary adjustments to strategies or timelines. Stakeholder Consultations involve regular engagement with civil society organizations, industry representatives, and academic institutions to gather feedback on implementation effectiveness and emerging concerns. International Benchmarking compares Ukraine's AI development progress with international peers, particularly EU member states, identifying gaps and opportunities for improvement. Sectoral Assessments evaluate AI deployment and impact within specific domains such as public administration, education, defense, and economic sectors. Research Impact Evaluation measures the growth of Ukraine's AI research capabilities, publication output, patent filings, and international collaboration. Market Competitiveness Indicators track the growth of Ukrainian AI companies, export revenues, international investment, and workforce development. Ethical Compliance Monitoring assesses whether AI deployments adhere to principles of human rights protection, privacy preservation, and democratic values. The Expert Committee's four working groups provide specialized monitoring within their respective domains, reporting to the Committee leadership and Ministry of Digital Transformation. Public Reporting ensures transparency through regular publication of implementation progress, challenges encountered, and strategic adjustments. The monitoring framework recognizes the dynamic nature of AI technology and maintains flexibility to incorporate new evaluation criteria as the field evolves and new challenges or opportunities emerge.

Penalties, Liability, and Appeals

The Concept of Artificial Intelligence Development in Ukraine establishes principles for accountability but as a strategic framework rather than legislation, it does not directly impose penalties. Instead, it sets the foundation for future legislative instruments that will define specific liability regimes, enforcement mechanisms, and appeals processes. The concept emphasizes that AI development and deployment must occur within frameworks of legal accountability, where developers, deployers, and operators of AI systems can be held responsible for harms caused by their technologies. Compliance with Rule of Law represents a core principle, requiring all AI activities to adhere to existing Ukrainian legislation and international obligations. The concept anticipates future legislation will establish liability frameworks addressing questions of responsibility when AI systems cause harm, whether through malfunction, bias, privacy violations, or other negative impacts. Rights Protection Mechanisms will enable individuals to seek redress when their fundamental rights are violated by AI systems. Regulatory Oversight will involve sector-specific agencies empowered to investigate complaints, conduct audits, and enforce compliance with AI regulations once enacted. Appeals Processes will provide pathways for contesting decisions made by or involving AI systems, particularly in high-stakes domains such as criminal justice, employment, and social benefits. Developer Responsibilities include obligations to design AI systems with appropriate safeguards, conduct risk assessments, and provide transparency about system capabilities and limitations. Deployer Obligations cover responsibilities for organizations implementing AI systems, including proper training, monitoring, and human oversight. The concept recognizes that effective liability regimes must balance encouraging innovation with protecting rights and providing meaningful remedies for harms. Subsequent regulatory instruments, including the 2023 Roadmap and 2024 White Paper, further develop these principles while maintaining the approach of voluntary compliance before mandatory enforcement during Ukraine's initial implementation phase.

Relationship to Other Instruments

The Concept of Artificial Intelligence Development in Ukraine serves as the foundational strategic document for Ukraine's AI regulatory framework, establishing principles and objectives that subsequent instruments build upon. The concept directly informed the Roadmap for the Regulation of Artificial Intelligence in Ukraine presented in October 2023, which translates the concept's strategic vision into specific regulatory approaches and timelines. The 2023 Roadmap elaborates the concept's implementation through a two-stage approach: an initial phase emphasizing voluntary industry self-regulation and a subsequent phase introducing legislation aligned with the EU AI Act. The concept's principles also underpin the White Paper on Artificial Intelligence Regulation in Ukraine published in June 2024, which provides detailed guidance on the bottom-up regulatory approach, sectoral guidelines, and preparatory tools for businesses. The concept aligns with Ukraine's broader digital transformation strategy, complementing initiatives in e-governance, digital infrastructure development, and IT sector growth championed by the Ministry of Digital Transformation. It supports Ukraine-EU Association Agreement commitments, particularly obligations related to digital market integration and regulatory approximation with European standards. The concept creates a foundation for sector-specific AI guidelines developed for media, marketing, education, and other domains, providing overarching principles that these sectoral instruments operationalize. The concept acknowledges and seeks to harmonize with international AI frameworks, including OECD AI Principles, UNESCO Recommendations on the Ethics of AI, and Council of Europe standards. Following Ukraine's signature of the Council of Europe Framework Convention on AI, Human Rights, Democracy, and Rule of Law in May 2025, the concept's emphasis on fundamental rights protection and democratic values provides domestic policy alignment with this international treaty. The concept also relates to data protection legislation, particularly Draft Law No. 8153 on Personal Data Protection, which addresses AI-relevant issues of automated decision-making and profiling. The concept's defense and security focus areas connect with Ukraine's national security strategies, particularly as AI applications in defense gained prominence following Russia's 2022 invasion.

International Alignment

The Concept of Artificial Intelligence Development in Ukraine explicitly prioritizes alignment with international AI governance frameworks, particularly European Union standards, reflecting Ukraine's broader European integration objectives. The concept commits to harmonizing Ukrainian AI legislation with international regulations, recognizing that regulatory alignment facilitates market access, international cooperation, and technology transfer. EU AI Act Alignment represents a central pillar of Ukraine's approach, with the concept anticipating eventual adoption of legislation mirroring the European Union's comprehensive AI regulatory framework, ensuring Ukrainian companies can operate seamlessly in European markets. The concept incorporates OECD AI Principles, adopted by OECD member countries in 2019, which emphasize human-centered values, transparency, robustness, accountability, and respect for human rights—principles explicitly reflected in the concept's core commitments. UNESCO Recommendations on the Ethics of AI inform the concept's emphasis on ethical AI development, particularly protections for human dignity, privacy, and democratic participation. Ukraine's participation in Council of Europe AI initiatives culminated in signing the Framework Convention on AI, Human Rights, Democracy, and Rule of Law in May 2025, operationalizing the concept's commitment to rights-based AI governance. The concept supports international research collaboration, encouraging Ukrainian AI researchers and institutions to participate in global research networks, joint projects, and knowledge exchange programs. Standards Harmonization involves adopting international technical standards for AI systems, facilitating interoperability and reducing barriers to international trade in AI technologies and services. The concept recognizes global market integration as essential for Ukrainian AI sector growth, positioning alignment with international standards as enabling access to markets, investment, and partnerships beyond Ukraine's borders. Multi-lateral AI governance forums provide venues for Ukraine to contribute to evolving international AI norms, share experiences, and learn from other countries' approaches. The concept's international orientation gained additional strategic significance following Russia's 2022 invasion, as Ukraine deepened partnerships with Western democracies and accelerated European integration processes, including in the digital and AI domains.

Implementation Timeline

Sources and References