Prospects for the Use of Artificial Intelligence by Financial Institutions in Ukraine (Financial and credit systems prospects for development)

Summary

• The National Bank of Ukraine publishes a discussion paper on the ethical and responsible use of AI by financial services market participants.p.1
• Ukraine currently has no adequate legislative framework for AI regulation, including no dedicated AI law.p.3
• The paper aims to start an open expert discussion on current and future AI use in the financial sector and to collect input for a future White Paper on AI.p.4
• The regulatory framework for AI in finance is described as fragmentary and evolving, with approaches based on proportionality, risk orientation and technological neutrality.p.6
• Clients should have the right to know when AI plays a significant role in decisions about them, to receive explanations and to demand review of automated decisions.p.9
• The central bank expects AI systems to be treated as part of operational infrastructure, consistent with the EU Digital Operational Resilience Act (DORA).p.16
• Work will proceed in stages: publication of the discussion paper, consolidated conclusions, then a White Paper for market participants.p.20

Key insights

1. Use of AI in Ukrainian finance is regulated only indirectly, through general financial, civil, information and regulatory law.p.6
2. AI governance systems should cover the full life cycle of AI systems, from the decision to use AI through to decommissioning and retention of decision history.p.10
3. AI systems should be classified by risk level, and the paper asks whether an EU AI Act style risk categorisation is appropriate for the financial sector.p.11
4. Consumers should be informed about AI use where it affects their rights, the terms of a service or access to it, or where it processes personal data.p.12
5. Decisions with legal, financial or social consequences should be subject to human oversight and the possibility of human intervention.p.9
6. Data used for AI should be sufficient, relevant and regularly reviewed, with bias risks from unrepresentative samples, proxy variables and historical distortions tested for.p.14
7. Firms should include AI-related incidents in their general IT incident management and align AI use with business continuity plans.p.16
8. The central bank encourages staff training and management involvement to build a culture of responsible AI use.p.18