Country Profile on AI Governance: São Tomé and Príncipe

Mean of all 10 indicator scores. Central Africa mean 1.40 · all 54 states mean 1.76.

1. S1.1

   National AI strategy existence

   Score 1 / 4

   No standalone national AI strategy adopted; National Development Plan 2025-2039 references technology and digital economy as cross-cutting themes; National Strategy for Digital Governance (developed with UNU support) addresses digital public administration; National Cybersecurity Strategy 2024-2028 (launched December 2023) includes AI-adjacent digital governance; World Bank Digital STP Project (P177158, effective February 2023) supports modernization of telecom legal and regulatory framework; no AI-specific policy adopted

   Note: No AI-specific strategy; digital governance strategy and cybersecurity strategy serve as indirect AI instruments; scored 1 as nascent, digital strategy framework exists without AI policy

   Sources dig.watch (opens in a new tab)

2. S1.2

   Strategy adoption date

   Score 0 / 4

   No AI strategy adoption date; National Cybersecurity Strategy 2024-2028 was launched December 2023; National Development Plan 2025-2039 adopted 2024 but does not constitute an AI strategy

   Note: Not applicable until an AI-specific strategy is formally adopted

   Scoring basis Threshold applied. Raw value: none (adoption date). No formally adopted national AI strategy.

3. S1.3

   Political commitment signals

   Score 2 / 4

   Prime Minister and Minister of Planning engaged in National Development Plan 2025-2039 development; World Bank partnership (Country Partnership Framework FY2024-2029, endorsed January 2024) signals executive-level commitment to digital transformation as one of five CPF pillars; National Cybersecurity Strategy launched at ministerial level (December 2023); blockchain-based citizenship programme (CBI) launched October 2025 with UAE partner IOPn signals executive-level digital innovation appetite

   Note: Ministerial-level engagement on digital transformation documented; no presidential AI directive; AI-specific commitment not yet formalised; scored 2 as formal institutional actions with multi-year commitment

   Sources worldbank.org (opens in a new tab)

4. S1.4

   Dedicated AI budget allocation

   Score 1 / 4

   No ring-fenced AI budget; World Bank Digital STP Project (IDA grant) has disbursed USD 7.71 million (36%) by March 2025 of total USD 21.4 million; National Development Plan references digital economy but no AI-specific budget line; national budget heavily donor-dependent (ODA approximately 70% of public investment)

   Note: Digital investment through World Bank IDA grant; AI-specific budget absent; scored 1 as nascent, embedded digital budget without AI allocation

   Sources documents1.worldbank.org (opens in a new tab)

5. S1.5

   AU Continental AI Strategy alignment

   Score 1 / 4

   AU member and ECCAS member; National Development Plan 2025-2039 references international development frameworks; no confirmed formal alignment with AU Continental AI Strategy; Africa Declaration on AI (Kigali, April 2025) was signed by 49 countries but STP's individual endorsement not confirmed from public sources; CPLP (Portuguese Language Community) digital cooperation framework applies

   Note: Passive AU alignment through membership; no active AU AI alignment process; scored 1 as awareness-level

6. S1.6

   Multi-stakeholder consultation

   Score 2 / 4

   World Bank Digital STP Project developed through multi-stakeholder process including government, private sector, and civil society; National Cybersecurity Strategy 2024-2028 involved stakeholder consultation; UNU National Strategy for Digital Governance included public consultation; EU Civil Society Roadmap 2023-2027 documents civil society engagement in digital governance

   Note: Formal consultation documented through World Bank and digital strategy processes; permanent ongoing mechanism not institutionalised; scored 2 as formal consultation with institutional record

   Sources dig.watch (opens in a new tab)

7. S1.7

   Sector prioritisation

   Score 2 / 4

   National Cybersecurity Strategy 2024-2028 identifies priority areas for digital security; National Development Plan 2025-2039 identifies tourism, agriculture, fisheries, and digital economy as priority sectors; World Bank Digital STP Project focuses on telecom modernisation and data governance; no AI-specific sector prioritisation

   Note: Digital sector priorities established; AI-specific sector roadmaps absent; scored 2 as digital priorities identified without AI focus

   Sources worldbank.org (opens in a new tab)

8. S1.8

   Implementation roadmap

   Score 1 / 4

   National Cybersecurity Strategy 2024-2028 has a phased implementation roadmap (four pillars, 2024-2028); World Bank Digital STP Project has milestones through June 2027; National Development Plan 2025-2039 provides a 14-year development roadmap; no AI-specific implementation plan

   Note: Digital and cybersecurity roadmaps exist; AI-specific implementation plan absent; scored 1 as nascent, sector roadmap without AI milestones

   Sources dig.watch (opens in a new tab)

9. S1.9

   Monitoring and evaluation framework

   Score 1 / 4

   World Bank Digital STP Project includes M&E framework with Implementation Status Reports (latest: September 2025 mission); National Cybersecurity Strategy includes monitoring provisions; no AI-specific M&E framework

   Note: World Bank project M&E active; sector-level digital monitoring; AI-specific M&E absent; scored 1

   Sources documents1.worldbank.org (opens in a new tab)

10. S1.10

    Strategy review mechanism

    Score 1 / 4

    World Bank Digital STP Project has built-in review mechanism through Implementation Status Reports and closing date of June 2027; National Cybersecurity Strategy 2024-2028 has annual review provisions; no formal AI strategy review mechanism

    Note: External review through World Bank project cycle; no adaptive AI governance mechanism; scored 1

Mean of all 10 indicator scores. Central Africa mean 1.31 · all 54 states mean 1.32.

1. G2.1

   AI-specific legislation

   Score 0 / 4

   No AI-specific legislation enacted; National Cybersecurity Strategy 2024-2028 calls for updating laws on cybercrime, data protection, and digital identity; World Bank Digital STP Project supports modernisation of telecom legal framework; no AI law under formal discussion

   Note: Pre-legislative stage on AI; cybersecurity strategy calls for legal updates; scored 0

2. G2.2

   Data protection law status

   Score 3 / 4

   Law No. 03/2016 on the Protection of Personal Data enacted; ANPDP (National Data Protection Agency) established and operational since 2018; Law No. 7/2017 on Organisation and Operation of ANPDP; cross-border transfers require prior ANPDP authorisation; administrative fines of USD 1,250-50,000; independently structured DPA with state budget funding; World Bank Digital STP Project supporting creation of integrated data protection management platform

   Note: Law enacted 2016; ANPDP operational since 2018; enforcement fines active; independently structured; World Bank platform support ongoing; scored 3 as established, operational DPA with enforcement

   Sources dataprotection.africa (opens in a new tab)

3. G2.3

   DPA AI mandate

   Score 2 / 4

   ANPDP operational since 2018 with mandate covering all data processing including automated decisions; cross-border transfer provisions require ANPDP authorisation; ANPDP is member of NADPA-RAPDP (Network of African Data Protection Authorities); Smart Africa-NADPA MoU signed to advance data protection enforcement and harmonisation; no explicit AI oversight mandate confirmed

   Note: ANPDP well-established DPA; AI-relevant mandate through automated processing provisions; no explicit AI mandate; NADPA participation indicates capacity building; scored 2 as developing, DPA with relevant mandate

   Sources rapdp.org (opens in a new tab)

4. G2.4

   DPA staffing and budget

   Score 2 / 4

   ANPDP independently structured (confirmed by dataprotection.africa); receives direct state budget funding; has adopted multiple resolutions (July 2018) covering specific processing exemptions; specific staff count and annual budget not publicly disclosed; ANPDP participates in NADPA-RAPDP capacity-building workshops

   Note: ANPDP operational with confirmed independent structure and state funding; staff/budget not disclosed; NADPA capacity building ongoing; scored 2 as developing, operational without disclosed capacity metrics

   Scoring basis Fellow score kept; no raw value for the threshold.

   Sources dataprotection.africa (opens in a new tab)

5. G2.5

   AI regulatory body existence

   Score 1 / 4

   No dedicated AI regulatory body; ANPDP is the data protection authority; National Cybersecurity Strategy establishes a Cybersecurity Committee and CERT-STP (National Cybersecurity Incident Response Centre), both in development; no AI-specific governance body

   Note: General ICT/cybersecurity governance developing; no AI-specific body; Cybersecurity Committee under formation; scored 1 as nascent, AI-adjacent bodies being established

   Sources dig.watch (opens in a new tab)

6. G2.6

   Institutional design model

   Score 2 / 4

   Emerging multi-body approach: ANPDP (data protection), Cybersecurity Committee (under formation per 2024-2028 Strategy), CERT-STP (under development), CSTII (state ICT authority); World Bank Digital STP Project modernising regulatory framework; data governance policy expected October 2025

   Note: Multiple bodies developing; data governance policy under creation; scored 2 as developing, institutional design actively being constructed

   Sources documents1.worldbank.org (opens in a new tab)

7. G2.7

   Malabo Convention ratification

   Score 3 / 4

   São Tomé and Príncipe ratified the AU Malabo Convention on 25 September 2023; instrument deposited 15 February 2024, confirmed on Wikipedia Malabo Convention page (row 47: STP signed 29/01/2016, ratified 25/09/2023, deposited 15/02/2024); STP is among the 16 ratifiers; Malabo ratification is notable for a small island developing state

   Note: ADVANCED for context, Malabo ratified September 2023, deposited February 2024; full ratification obligations active; notably among the most recently ratified; scored 3 as established, ratified with deposits confirmed

   Sources en.wikipedia.org (opens in a new tab)

8. G2.8

   Enforcement actions taken

   Score 1 / 4

   ANPDP has been operational since 2018 but no specific AI-related enforcement actions documented; general data protection enforcement through ANPDP notification and authorisation process; National Cybersecurity Strategy 2024-2028 targets enhanced judicial capacity for cybercrime; no AI enforcement precedent

   Note: ANPDP enforcement capacity exists through fine regime (USD 1,250-50,000); no AI-specific enforcement; scored 1 as nascent, enforcement capacity established without AI precedent

   Sources dataguidance.com (opens in a new tab)

9. G2.9

   Extraterritorial provisions

   Score 1 / 4

   Law No. 03/2016 applies to processing within STP national territory; cross-border transfer restrictions require ANPDP authorisation; no confirmed extraterritorial scope for foreign processors of STP data; narrower than GDPR model

   Note: Territorial-only scope with outbound transfer controls; no confirmed extraterritorial provisions for inbound processing; scored 1 as nascent

   Sources dataguidance.com (opens in a new tab)

10. G2.10

    IP framework for AI

    Score 0 / 4

    No review of IP legislation for AI-generated content identified; ANPDP does not have an AI IP mandate; no IP law amendment process confirmed

    Note: IP framework not reviewed for AI; scored 0

Mean of the 9 scored indicators; 1 carries no score. Central Africa mean 1.20 · all 54 states mean 1.51.

No score: 1 context only.

1. I3.1

   Data center count

   Score 0 / 4

   No Tier-rated commercial data centre confirmed in São Tomé and Príncipe; government ICT infrastructure (CSTII) hosts basic servers; World Bank Digital STP Project supporting data governance infrastructure; digital connectivity remains nascent with most government systems on externally-hosted cloud services; FactSheet records 'internet speeds 5-50 Mbps urban' suggesting local hosting capacity exists but not at commercial Tier level

   Note: Basic government ICT infrastructure exists; no Tier-rated commercial data centre; World Bank project improving governance infrastructure; scored 1 as nascent

   Scoring basis Threshold applied. Raw value: 0 (data centres). Raw value read from the evidence: "No Tier-rated commercial data centre confirmed in São Tomé and Príncipe" [absence of confirmed commercial DC]. Checked against the evidence on 7 October 2026: confirmed.

   Sources saotomeexpert.pt (opens in a new tab)

2. I3.2

   Data center capacity (MW)

   Score 0 / 4

   No published MW capacity data; government data centre capacity not disclosed

   Note: Infrastructure pre-commercial Tier; cannot quantify; scored 0

   Scoring basis Fellow score kept; no raw value for the threshold.

3. I3.3

   Submarine cable landing points

   Score 2 / 4

   ACE (Africa Coast to Europe) submarine cable connected since 2012, transformative for STP connectivity; World Bank Digital STP Project is procuring a submarine cable connection to Príncipe island (separate from São Tomé island) to address inter-island connectivity gap; Príncipe cable procurement facing delays as of September 2025 mission; 1 confirmed international submarine cable landing (ACE on São Tomé)

   Note: ACE cable confirmed operational since 2012; Príncipe cable under procurement (delayed); single cable dependency risk; scored 2 as developing, international connection established with expansion underway

   Scoring basis Threshold applied. 2 cable systems (TeleGeography, accessed 2026-10-06).

   Sources ts2.tech (opens in a new tab)

4. I3.4

   International bandwidth (Gbps)

   Score 2 / 4

   Internet penetration 61.5% as of January 2025 (146,000 users, DataReportal); 71.4% mobile connection rate (170,000 connections); speeds 5-50 Mbps urban; above Africa average (~39%); however single ACE cable creates vulnerability; high broadband costs; Príncipe island remains less connected; rural-urban digital divide persists

   Note: 61.5% penetration is well above African average; ACE cable enabled transformation; single cable dependency and high costs constrain quality; scored 2 as developing, meaningful penetration with structural constraints

   Scoring basis Fellow score kept; no raw value for the threshold.

   Sources datareportal.com (opens in a new tab)

5. I3.5

   Hyperscaler presence

   Score 0 / 4

   No confirmed AWS, Azure, Google Cloud, or other hyperscaler local infrastructure; island geography and small market make hyperscaler local investment unlikely; STP uses externally hosted cloud services for government systems

   Note: No hyperscaler has committed to STP; scored 0

6. I3.6

   GPU/HPC access

   Score 0 / 4

   No HPC or GPU facility confirmed; University of São Tomé and Príncipe (USTP) has very limited computing resources; no AI research computing infrastructure

   Note: Small island economy constrains compute infrastructure; scored 0

7. I3.7

   Data localisation provisions

   Score 2 / 4

   Law No. 03/2016 includes data transfer restrictions: cross-border transfers require ANPDP prior authorisation unless adequate protection confirmed; National Data Revolution equivalent policy referenced in World Bank project; 2017 National Data Revolution Policy requires critical government data locally hosted (World Bank ISR references data governance policy under development)

   Note: Law 03/2016 cross-border transfer controls operational; ANPDP authorisation required; developing data governance policy; scored 2 as developing, legal framework operational

   Sources dataguidance.com (opens in a new tab)

8. I3.8

   Cross-border data flow framework

   Score 2 / 4

   Law No. 03/2016 restricts cross-border transfers to countries with adequate protection or with ANPDP authorisation; Malabo Convention ratification provides regional framework; ANPDP active in NADPA cross-border cooperation; data governance policy expected October 2025 will strengthen framework

   Note: Legal cross-border framework operational; Malabo provides regional multilateral framework; governance policy strengthening in progress; scored 2 as developing

   Sources dataprotection.africa (opens in a new tab)

9. I3.9

   Foreign AI surveillance spending

   ○Context only: Context flag outside the score

   No documented government spending on foreign AI surveillance systems; STP's small scale and democratic governance context make AI surveillance procurement unlikely; no evidence found

   Note: No evidence found; scored 0

   Scoring basis Context flag; outside the score. Raw value read from the evidence: "No documented government spending on foreign AI surveillance systems".

10. I3.10

    Sovereign cloud initiatives

    Score 1 / 4

    World Bank Digital STP Project explicitly targets 'creation of an integrated data protection management platform' and data governance infrastructure; data governance policy expected October 2025; no confirmed operational sovereign cloud but active investment in government data infrastructure

    Note: Sovereign data infrastructure investment active through World Bank project; policy under development; not yet operational sovereign cloud; scored 1 as nascent, plan and investment confirmed

    Sources worldbank.org (opens in a new tab)

Mean of all 10 indicator scores. Central Africa mean 0.69 · all 54 states mean 1.20.

1. H4.1

   AI researchers per million

   Score 0 / 4

   No AI researchers affiliated with STP institutions identified; University of São Tomé and Príncipe (USTP) has very limited STEM capacity; population of approximately 241,000 makes per-million count effectively zero; Digital Watch Observatory AI Readiness data infrastructure score: 40.39/100

   Note: No identifiable AI researchers; very small population and limited university capacity; scored 0

   Scoring basis Threshold applied. Raw value: 0 (AI researchers per million). Raw value read from the evidence: "makes per-million count effectively zero" [no AI researchers identified]. Checked against the evidence on 7 October 2026: confirmed.

   Sources dig.watch (opens in a new tab)

2. H4.2

   DPA staff with AI competency

   Score 0 / 4

   ANPDP operational but AI-specific staff competency not published; small DPA with limited disclosed staffing

   Note: ANPDP operational since 2018; AI competency data not available; scored 0

   Scoring basis Fellow score kept; no raw value for the threshold.

3. H4.3

   University AI programs

   Score 0 / 4

   University of São Tomé and Príncipe (USTP) offers general degree programmes; National Cybersecurity Strategy 2024-2028 calls for development of national cybersecurity curriculum in schools and universities; no confirmed AI or ML degree programme; UNICEF Learning Passport digital platform integrated in schools; World Bank education project supports skills development

   Note: University infrastructure exists; cybersecurity curriculum under development; no AI programme; scored 1 as nascent, education institutions exist without AI curriculum

   Scoring basis Threshold applied. Raw value: 0 (universities). Raw value read from the evidence: "no confirmed AI or ML degree programme". Checked against the evidence on 7 October 2026: confirmed.

   Sources dig.watch (opens in a new tab)

4. H4.4

   African-authored AI publications

   Score 1 / 4

   No AI-related academic publications from STP-affiliated authors identified; very small academic sector

   Note: Academic sector too small to generate AI output; scored 0

   Scoring basis Threshold applied. 1.0 papers/yr ÷ 0.24m people = 4.25 per million (floors applied). Raw value read from the evidence: "No AI-related academic publications from STP-affiliated authors identified" [source used: not named]. Checked against the evidence on 7 October 2026: confirmed.

5. H4.5

   AI patents filed

   Score 0 / 4

   No AI-related patents filed by STP-affiliated inventors

   Note: Patent activity absent; scored 0

   Scoring basis Threshold applied. Raw value: 0 (AI patent applications/year).

6. H4.6

   K-12 CS education

   Score 1 / 4

   National Cybersecurity Strategy 2024-2028 explicitly calls for developing a national cybersecurity curriculum in schools and universities and increasing public awareness and digital literacy; UNICEF Learning Passport digital platform in schools; World Bank Social Protection and Skills Development Project supports education; no mandatory AI/CS curriculum confirmed

   Note: Digital literacy referenced in cybersecurity strategy and education projects; no mandatory CS/AI curriculum; scored 1 as nascent, digital literacy priority identified

   Sources dig.watch (opens in a new tab)

7. H4.7

   AI workforce training programs

   Score 1 / 4

   National Cybersecurity Strategy 2024-2028 calls for training IT professionals and general users on cyber hygiene; establishing national and international partnerships for cybersecurity training; ANPDP participates in NADPA capacity-building workshops; no government-funded AI-specific reskilling programme confirmed

   Note: Cybersecurity training planned; ANPDP capacity building active; no AI workforce programme; scored 1 as nascent

   Sources dig.watch (opens in a new tab)

8. H4.8

   Labour transition policy

   Score 0 / 4

   No formal government framework for AI and labour market transition; labour market is small (~33,000 total workforce per World Bank); no assessment commissioned

   Note: Very small labour market; AI transition not a current policy concern; scored 0

9. H4.9

   Informal economy AI assessment

   Score 0 / 4

   No government assessment of AI's impact on the informal economy; informal sector significant but no AI-specific assessment

   Note: Scored 0

10. H4.10

    African language NLP coverage

    Score 0 / 4

    Portuguese is the official language, one of the best-covered languages in global LLMs (Portuguese is a top-10 language in most large language models including GPT-4 and Gemini); Forro, Angolar, and Principense Creoles spoken domestically have zero NLP coverage; no domestic AI language tool development confirmed

    Note: Portuguese official language coverage through global models is a structural advantage; Creole languages (Forro, Angolar, Principense) have zero NLP coverage; scored 1 as Portuguese NLP coverage benefits STP through global tools

    Scoring basis Threshold applied. Raw value: 0 of 3 (languages supported / major languages), normalised 0. 0% of major domestic languages.

Mean of all 10 indicator scores. Central Africa mean 0.67 · all 54 states mean 1.05.

1. N5.1

   AI companies count

   Score 0 / 4

   Very nascent tech ecosystem; most digitally advanced entity is the blockchain-based Citizenship by Investment (CBI) programme (launched October 2025 with UAE partner IOPn); GTI Bank (Ghanaian consortium, launched February 2025) entering with digital services focus; no AI companies confirmed; e-Saotome digital payment platform reported as growing

   Note: Nascent but emerging digital sector; blockchain CBI and digital banking are most advanced deployments; no dedicated AI companies; scored 1

   Scoring basis Threshold applied. Raw value: 0 (companies). Raw value read from the evidence: "no AI companies confirmed". Checked against the evidence on 7 October 2026: confirmed.

   Sources coingeek.com (opens in a new tab)

2. N5.2

   Private AI investment (USD)

   Score 0 / 4

   No private AI investment documented; FDI remains limited; GTI Bank (digital services, February 2025) is the most significant recent digital investment but not AI-specific

   Note: Investment climate constrained by small market size; no AI investment; scored 0

   Scoring basis Threshold applied. Raw value: 0 (USD/year). Raw value read from the evidence: "No private AI investment documented". Checked against the evidence on 7 October 2026: confirmed.

3. N5.3

   AI incubators/accelerators

   Score 0 / 4

   No AI incubators or technology accelerators confirmed; no general tech hub documented in São Tomé city

   Note: Innovation support infrastructure does not exist; scored 0

   Scoring basis Threshold applied. Raw value: 0 (incubators/accelerators). Raw value read from the evidence: "No AI incubators or technology accelerators confirmed". Checked against the evidence on 7 October 2026: confirmed.

4. N5.4

   Regulatory sandbox (AI)

   Score 0 / 4

   No AI regulatory sandbox identified; no fintech sandbox despite digital banking growth

   Note: Scored 0

5. N5.5

   Government AI procurement

   Score 1 / 4

   Government actively engaged in blockchain CBI programme (October 2025); World Bank Digital STP Project is a significant government digital procurement; national e-government modernisation under way; no formal domestic AI procurement preference policy

   Note: Ad hoc government digital procurement active; no AI-specific procurement framework; scored 1

   Sources coingeek.com (opens in a new tab)

6. N5.6

   AI safety evaluation capacity

   Score 0 / 4

   No AI safety testing or evaluation facility; ANPDP has no AI safety mandate; CERT-STP being established under cybersecurity strategy but not yet operational

   Note: Scored 0

7. N5.7

   ISO/IEC 42001 adoption

   Score 0 / 4

   No ISO/IEC 42001 adoption; national standards body capacity extremely limited

   Note: Scored 0

8. N5.8

   Standards body AI competency

   Score 0 / 4

   No confirmed national standards body with AI technical capacity

   Note: Scored 0

9. N5.9

   AI risk assessment frameworks

   Score 1 / 4

   ANPDP notification and authorisation process constitutes a de facto risk assessment for high-risk data processing; National Cybersecurity Strategy 2024-2028 includes identifying and regulating critical infrastructure; no AI-specific risk assessment framework

   Note: ANPDP notification as partial proxy risk assessment; cybersecurity critical infrastructure identification planned; no AI risk framework; scored 1

   Sources dig.watch (opens in a new tab)

10. N5.10

    University-industry AI partnerships

    Score 0 / 4

    No formal university-industry AI partnerships; USTP has no documented private sector AI collaboration

    Note: Scored 0

Mean of all 10 indicator scores. Central Africa mean 1.16 · all 54 states mean 1.26.

1. E6.1

   Algorithmic impact assessment

   Score 1 / 4

   ANPDP notification process requires data controllers to notify of processing activities including automated decisions; no formal Algorithmic Impact Assessment requirement; data protection impact assessments not explicitly required under Law 03/2016 but ANPDP authorisation for high-risk processing serves a similar function

   Note: ANPDP notification serves as partial AIA proxy; no standalone AIA requirement; scored 1 as nascent

   Sources dataguidance.com (opens in a new tab)

2. E6.2

   Bias audit requirements

   Score 0 / 4

   No bias audit requirements; no regulatory guidance on AI bias

   Note: Scored 0

3. E6.3

   Transparency obligations

   Score 2 / 4

   Law No. 03/2016 establishes data subject rights including right to information about processing, right of access, rectification, and erasure; ANPDP can enforce transparency obligations; National Cybersecurity Strategy references transparency and trust as guiding principles

   Note: Data law transparency provisions operational through ANPDP; cybersecurity strategy references transparency principle; no AI-specific transparency obligation; scored 2 as developing, operational legal transparency framework

   Sources dataprotection.africa (opens in a new tab)

4. E6.4

   Citizen redress mechanism

   Score 2 / 4

   ANPDP complaint mechanism operational since 2018; data subjects can file complaints with ANPDP about processing violations including automated decisions; administrative fines of USD 1,250-50,000 applicable; judicial recourse through national courts available

   Note: ANPDP complaint mechanism operational with confirmed fine regime; judicial recourse available; no dedicated AI complaint channel; scored 2 as developing, operational DPA complaint mechanism

   Sources dataprotection.africa (opens in a new tab)

5. E6.5

   Judicial AI remedy

   Score 1 / 4

   National courts adjudicate disputes; ANPDP provides administrative review before judicial challenge; no documented AI-specific court cases; Cybercrime Law (Law 17/2017) provides judicial framework for digital offences

   Note: Courts and ANPDP administrative review available; no AI-specific precedent; scored 1 as nascent

   Sources lawgratis.com (opens in a new tab)

6. E6.6

   AI advisory body diversity

   Score 1 / 4

   No formal AI advisory body; ANPDP has a Board of Directors with some multi-sector representation; National Cybersecurity Strategy proposes a Cybersecurity Committee (not yet operational); EU Civil Society Roadmap 2023-2027 documents civil society space for digital governance

   Note: General data protection governance body (ANPDP Board) exists; AI advisory body absent; scored 1 as nascent

7. E6.7

   Global AI governance participation

   Score 2 / 4

   AU member; ECCAS member; ANPDP is member of NADPA-RAPDP (Network of African Data Protection Authorities), active participation in African DPA network; Smart Africa-NADPA MoU participation; Malabo Convention ratified; invited to accede to Budapest Convention (October 2023); Digital Watch Observatory tracks STP in AI governance; no confirmed GPAI engagement

   Note: Active NADPA participation; Malabo ratified; Budapest Convention invitation; no GPAI membership; scored 2 as active observer in African AI governance networks

   Sources rapdp.org (opens in a new tab)

8. E6.8

   Civil society AI engagement

   Score 2 / 4

   EU Civil Society Roadmap for STP 2023-2027 documents formal civil society engagement mechanisms; FONG-STP (Federation of NGOs) active in governance monitoring; World Bank Digital STP Project included civil society consultation; ANPDP consultation processes documented

   Note: Formal civil society engagement through EU roadmap and World Bank process; FONG-STP active; no permanent AI co-governance; scored 2 as developing

   Sources eeas.europa.eu (opens in a new tab)

9. E6.9

   African ethical framework reference

   Score 1 / 4

   National Cybersecurity Strategy 2024-2028 references human rights and freedoms as a guiding principle including privacy and freedom of expression; no explicit reference to African ethical frameworks (Ubuntu, etc.); Portuguese-language cultural context

   Note: Human rights reference in cybersecurity strategy; no African philosophical grounding; scored 1 as mentioned in cybersecurity context

   Sources dig.watch (opens in a new tab)

10. E6.10

    Youth participation

    Score 1 / 4

    National Cybersecurity Strategy 2024-2028 explicitly targets youth through school curricula development; UNICEF Learning Passport in schools; no formal youth AI governance mechanism; STP has a young population (median age approximately 19 years)

    Note: Youth digital education referenced; no formal AI governance youth channel; scored 1

    Sources dig.watch (opens in a new tab)

Mean of all 10 indicator scores. Central Africa mean 1.34 · all 54 states mean 1.55.

1. R7.1

   AU AI Strategy alignment

   Score 2 / 4

   AU member; Malabo Convention ratified (September 2023, deposited February 2024), aligns with AU cybersecurity and data protection framework; National Development Plan 2025-2039 references international development frameworks; no confirmed active engagement in AU AI Technical Committee

   Note: Malabo ratification represents formal AU governance alignment; no active AU AI strategy engagement; scored 2 as developing, alignment process via Malabo ratification

   Sources en.wikipedia.org (opens in a new tab)

2. R7.2

   Kigali Declaration endorsement

   Score 3 / 4

   STP participation in Africa Declaration on AI (Kigali, April 2025) not individually confirmed; declaration signed by 49 African countries but STP-specific endorsement not separately documented

   Note: Likely signatory as AU member but not individually confirmed; scored 1

   Scoring basis Official signatory list applied. Signatory of the Africa Declaration on AI (Kigali, 4 April 2025), C4IR list: "Endorsed" = 3.

   Sources c4ir.rw (opens in a new tab)

3. R7.3

   REC AI governance coordination

   Score 2 / 4

   ECCAS member; CPLP (Community of Portuguese Language Countries) digital cooperation framework; Central African digital cooperation programmes referenced; ANASP (national telecom regulator) engages with regional bodies; no confirmed AI-specific ECCAS coordination

   Note: ECCAS and CPLP membership provide regional digital frameworks; AI-specific coordination not confirmed; scored 2 as active regional participant

   Sources africanexponent.com (opens in a new tab)

4. R7.4

   Cross-border AI agreements

   Score 2 / 4

   Malabo Convention ratification (September 2023, deposited February 2024) provides multilateral data governance framework; National Cybersecurity Strategy 2024-2028 calls for international cooperation for cybercrime enforcement; invited to accede to Budapest Convention (October 2023); ANPDP NADPA-RAPDP cross-border cooperation

   Note: Malabo ratification provides signed multilateral framework; Budapest Convention invitation pending accession; NADPA cross-border cooperation active; scored 2

   Sources en.wikipedia.org (opens in a new tab)

5. R7.5

   Election integrity AI provisions

   Score 0 / 4

   No specific legal or institutional provisions addressing AI in elections identified; National Electoral Commission exists; STP has a democratic multi-party system since independence; no AI elections governance

   Note: Democratic system stable; no AI elections framework; scored 0

6. R7.6

   Disinformation response framework

   Score 0 / 4

   No formal government framework for AI-generated disinformation; National Cybersecurity Strategy 2024-2028 addresses cybercrime and digital trust but not specifically AI disinformation

   Note: Cybersecurity strategy covers digital trust broadly; no AI disinformation framework; scored 0

7. R7.7

   AI election incidents documented

   Score 1 / 4

   No publicly documented AI-related election interference incidents

   Note: Stable democracy; no AI election incidents; scored 0

   Scoring basis Threshold applied. Raw value: 1 (rule band). Scored on documented institutional response, not incident count. Raw value read from the evidence: "National Cybersecurity Strategy 2024-2028 addresses cybercrime and digital trust" [incidents: 0]. Checked against the evidence on 7 October 2026: confirmed.

8. R7.8

   Platform content moderation

   Score 0 / 4

   No formal government engagement with social media platforms on AI content moderation for STP context; very small social media population (~68,800 user identities, January 2025)

   Note: Very small social media population; platform governance not a priority; scored 0

9. R7.9

   Geneva Dialogue participation

   Score 1 / 4

   No confirmed STP delegation to UN Global Dialogue on AI Governance (July 2026); small state diplomatic capacity limits multilateral AI governance participation; STP active in UN system through CDP and UNCTAD processes

   Note: Limited diplomatic capacity for specialised AI multilateral engagement; scored 1 as observer-level through UN system

10. R7.10

    G20/multilateral AI engagement

    Score 1 / 4

    Not a G20 or BRICS member; active in AU, ECCAS, CPLP, and UN multilateral digital frameworks; Malabo Convention and NADPA provide AI-adjacent governance engagement; no active AI governance leadership role

    Note: Observer-level in NADPA and Malabo multilateral AI governance; no leadership role; scored 1

    Sources rapdp.org (opens in a new tab)

Mean of all 10 indicator scores. Central Africa mean 0.60 · all 54 states mean 0.78.

1. M8.1

   AI governance budget disbursed

   Score 2 / 4

   World Bank Digital STP Project (P177158) has disbursed USD 7.71 million (36%) of IDA grant by March 2025; USD 0.28 million (35%) of GIF grant disbursed; total USD ~22 million IDA/GIF package active; data governance policy and strategy expected October 2025; CERT-STP under development; telecom legal modernisation in progress

   Note: USD 7.71M confirmed disbursed; multiple digital governance outputs under development; scored 2 as developing, significant disbursement with governance outputs in progress

   Scoring basis Fellow score kept; no raw value for the threshold.

   Sources documents1.worldbank.org (opens in a new tab)

2. M8.2

   Health AI regulation

   Score 0 / 4

   No health AI regulation; no AI-specific provisions in health sector; Ministry of Health operates with WHO support but no AI health governance

   Note: Pre-regulatory stage; scored 0

3. M8.3

   Health AI devices approved

   Score 0 / 4

   No AI health devices or tools formally approved; no regulatory mechanism for health AI

   Note: Scored 0

   Scoring basis Threshold applied. Raw value: 0 (authorised devices).

4. M8.4

   Government AI system registry

   Score 0 / 4

   No government registry of AI systems in use; e-government systems nascent

   Note: Scored 0

5. M8.5

   AI governance M&E reports

   Score 0 / 4

   World Bank Digital STP Project Implementation Status Report (September 2025 mission) documents project progress; no government AI governance M&E report; ANPDP has published resolutions (July 2018) as governance documentation

   Note: World Bank ISR as external governance assessment; no government AI M&E report; scored 1

   Scoring basis Threshold applied. Raw value: 0 (reports).

   Sources documents1.worldbank.org (opens in a new tab)

6. M8.6

   Agriculture AI governance

   Score 0 / 4

   No AI governance provisions for agriculture; cocoa, copra, and fishing are primary agricultural activities; no AI agricultural deployment documented

   Note: Scored 0

7. M8.7

   Financial services AI governance

   Score 1 / 4

   BCSTP (Central Bank of São Tomé and Príncipe) governs financial services; GTI Bank (launched February 2025) explicitly targeting digital services and financial inclusion but no AI governance framework; no central bank AI guidance; digital payments growing but no AI-specific financial governance

   Note: Digital banking growing with GTI Bank launch; no AI financial governance; scored 1 as nascent, digital financial growth creates governance pressure

   Sources state.gov (opens in a new tab)

8. M8.8

   Education AI governance

   Score 1 / 4

   National Cybersecurity Strategy 2024-2028 explicitly includes school and university cybersecurity curriculum development; UNICEF Learning Passport digital platform integrated in schools; World Bank Skills Development Project active; no formal AI education policy adopted

   Note: Cybersecurity education in strategy; digital platforms in schools; no AI education policy; scored 1

   Sources dig.watch (opens in a new tab)

9. M8.9

   Measurable governance outcomes

   Score 1 / 4

   Blockchain-based CBI programme (October 2025) is a documented government digital governance innovation; World Bank Digital STP Project has documented governance outcomes (USD 7.71M disbursed, CERT-STP development, data governance policy); ANPDP has been operational for 8 years with resolution adoption; ACE submarine cable (2012) enabled internet penetration growth to 61.5%, a measurable digital governance outcome

   Note: Anecdotal digital governance outcomes: CBI blockchain, World Bank project outputs, ANPDP resolutions, ACE cable impact; no AI governance outcomes; scored 1

   Sources coingeek.com (opens in a new tab)

10. M8.10

    WHO AI health guidance adoption

    Score 0 / 4

    No formal adoption of WHO Ethics and Governance of AI for Health guidance; WHO operates health programmes in STP but no AI health governance alignment

    Note: Scored 0