MODEL REGULATORY
FRAMEWORK ON AI &
MACHINE LEARNING
IN SOUTHERN AFRICA
PREAMBLE
States should be committed to proportionate regulation of the risks of digital technologies. They can do so by
exploring a range of mechanisms, including improving the policymaking process. These regulatory measures
include norms, self-regulation, statutory codes of conduct, and rules in primary legislation.
Given how digital technologies can quickly outpace law-making, States should also adopt non-regulatory tools
to complement or provide alternatives to ‘traditional’ regulation, including industry-led technical standards.
As digital technologies accumulate vast amount of data, they demand a distinct regulatory approach. They are
a complex system whose creation and use relies on critical elements such as algorithms, access to data, and
sufficient computing resources.
To respond to these distinct challenges, States should take holistic, flexible, adaptable, transparent, and objective regulatory approaches that bring clarity by balancing the competing multi-stakeholders interests, including industry and civil society, as well as international commitments and obligations.
This guidance focuses on the right to freedom of expression enshrined in Article 9 of the African Charter on
Human and Peoples Rights, Article 19 of the Universal Declaration of Human Rights, and Article 19 of the International Covenant on Civil and Political Rights (ICCPR) and the right to privacy in Article 12 of the Universal
Declaration of Human Rights and Article 17 of the ICCPR.

1. ETHICS AND LAW TO ENSURE THAT
AI SERVES THE PUBLIC GOOD.
States should firmly centre regulation on universal
ethical principles and human rights as ultimate benchmarks for assessing the social acceptability of AI systems developed and deployed in and out of the African Union.

2. APPLICATION OF INTERNATIONAL
HUMAN RIGHTS LAW.
States have a three-fold obligation to respect, protect,
and fulfil human rights and fundamental freedoms.

3. FREEDOM OF EXPRESSION

The states shall take into account the preceding guidelines in adhering to the following principles in international law:
a.
Respect and protect everyone’s right to “seek,
receive and impart information and ideas of all kinds,
regardless of frontiers”.
b.
Whenever free speech is restricted through
content moderation or otherwise, it must be provided
by law and necessary for respecting the rights or reputation of others and protecting national security, public
order, public health, or morals, for example, incitement
and hate speech.
c.
In categorising hate speech and incitement
speeches, intermediaries and states may find the following helpful categorisation: At the top is incitement
to genocide, incitement to violence, and possibly to
terrorism, and incitement to discrimination. This is followed by other forms of hate speech, including vilification, glorification, promotion, and justification, which
are part of the pyramid below incitement. At the bot-

Select target paragraph3