What regulatory changes in AI should Ukraine prepare for?
Ukraine's artificial intelligence market is estimated at nearly $420 million in 2025. The country is home to more than 240 AI companies, and the number of AI/ML specialists exceeds 6,100.
A significant share of the sector already relies on exports or is planning to do so.
Read more about how Ukrainian AI-based products can enter the EU market and what "homework" Ukraine itself needs to complete in the column by Stanislav Yukhymenko of the Institute for Economic Research and Policy Consulting (IER): Oversight of artificial intelligence: Which EU rules Ukraine needs to implement.
The author notes that for AI-based products, the key framework governing the export of services to the EU is the AI Act (EU Regulation 2024/1689), which follows a risk-based approach: the higher the risk to human rights and security, the stricter the requirements.
The regulation enters into force in stages and follows a defined timetable.
However, as Stanislav Yukhymenko writes, the European Union is not keeping to its original schedule. Brussels has acknowledged that the timeline was overly optimistic.
"This opens up an opportunity for Ukraine to implement the AI Act without haste, taking business needs into account," the IER research fellow emphasises.
Under the AI Act, the EU is building a two-tier institutional architecture: a central level and national authorities responsible for supervision and enforcement.
Ukraine will also need to designate such national bodies and define how they will interact with businesses.
According to the author, for most AI solutions that do not fall under the AI Act’s high-risk criteria, compliance costs will be primarily organisational and legal, rather than related to formal certification.
"For many companies, this is less about money and more about discipline and time," Yukhymenko writes.
For high-risk systems, however, the requirements are significantly stricter.
"If we assume that 10–15% of Ukrainian AI companies will develop high-risk AI models, total business costs for complying with all AI Act requirements could amount to tens of millions of euros over the next three to five years," the IER research fellow notes.
For Ukraine, which has obtained EU candidate status and begun accession negotiations, alignment with the AI Act is a matter of timing, not choice. Its implementation is inevitable.
"Ukrainian companies find themselves in a unique situation: the EU itself is preparing to postpone deadlines, acknowledging the complexity of implementation. This provides an opportunity to prepare more carefully, without haste or excessive pressure on business," the author points out.
In his view, the key challenge for Ukraine now is to avoid extremes. On the one hand, premature and overly strict implementation could stifle a domestic AI sector that is gaining momentum. On the other hand, ignoring European standards would block access to one of the world’s largest technology markets.
"Harmonisation with the AI Act for Ukraine is not just about meeting formal requirements on the path to EU membership. It is a chance to build trust in Ukrainian technologies internationally, attract investment into the sector, and position Ukraine as a reliable partner in AI development," the IER research fellow concludes.