In late 2024, the Government launched the National Artificial Intelligence Strategy 2024–2026, positioning Zambia to transition from merely consuming foreign AI tools to building, adapting, and applying local solutions. From predictive agriculture and healthcare diagnostics to mineral exploration and digital content creation, the ambition is clear. But as with any major policy initiative, the critical question remains: How is Zambia translating strategic ambition into enforceable law, operational institutions, and real-world results?
WHERE DOES IMPLEMENTATION STAND?
A strategy on paper must lead to measurable institutional action. Over the past two years, key developments highlight where momentum is building—and where work remains:
- Healthcare Pilots: The Ministry of Technology and Science reported the initial rollout of AI-driven systems across 20 health centers under international bilateral cooperation.
- UNESCO Readiness Assessment: In mid-2026, Zambia served as the Southern African pilot for UNESCO’s AI Readiness Assessment Methodology (RAM 2.0), evaluating domestic readiness across ethics, infrastructure, and institutional capacity.
- Regional Integration: Sensitization workshops through COMESA have targeted cross-border regulatory alignment, critical for digital trade and shared regional data ecosystems.
DOES ZAMBIA HAVE A DEDICATED AI LAW?
No.
Zambia currently relies on its existing broader digital and communications legislative architecture rather than a standalone AI Act:
- Data Protection Act No. 3 of 2021: Governs personal data processing, automated profiling, and data subject rights (Cabinet approved in principle the introduction of a broader Data Protection Repeal Bill to encompass non-personal and machine-learning data, though statutory enactment remains pending).
- Cyber Security & Cyber Crimes Frameworks (2025): Critical for mitigating AI-enabled fraud, cyber threats, and critical infrastructure protection.
- ECT Act No. 4 of 2021 & ICT Act No. 15 of 2009: Provide the legal basis for electronic transactions, digital verification, and underlying communications infrastructure.
CORE LEGAL & COMMERCIAL HURDLES
For businesses, tech founders, and public bodies adopting AI, key legal exposures must be addressed proactively:
- Liability for Algorithmic Harm: When an automated credit assessment fails, an AI diagnostic errs, or an automated screening tool discriminates, where does legal accountability rest—developer, vendor, or deploying institution?
- Intellectual Property & the Creative Sector: Who owns content produced by generative AI? Under the Copyright and Performance Rights Act, using local creative works to train models without permission remains an unresolved legal frontier.
- Institutional Clarity: The Strategy proposed a National AI Council and sector-specific Technical Working Groups; bringing these bodies into confirmed, transparent operation is vital to avoid regulatory fragmentation.
DAC VIEW
A national strategy sets direction, but commercial certainty requires operational governance, clear statutory boundaries, and enforceable rights. Organizations deploying automated systems cannot wait for bespoke AI legislation—compliance starts today under existing data protection, consumer protection, and cybersecurity laws.
DAC Legal Insights is published by Dzekedzeke & Co. Legal Practitioners for general public legal education and informational purposes only. It does not constitute formal legal advice.
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