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Without much fanfare, the department of communication & digital technologies released a National Artificial Intelligence (AI) Policy Framework in mid-August. Described as the “first step” in creating a national AI policy, this framework aims to lay the groundwork for future AI regulations and possibly an AI Act in SA. 

The framework serves as a strategic blueprint for harnessing AI, with a focus on ethical guidelines to promote economic growth, technological advancement and societal wellbeing in line with SA’s values and priorities. Notably, it allows for the development of tailored strategies that leverage AI to drive innovation and efficiency in each sector, ensuring that the unique challenges and opportunities of each industry are considered. 

At just 13 pages the framework is relatively concise for a policy document. It outlines 12 strategic pillars for SA’s AI policy — talent development & capacity building, digital infrastructure, research & innovation, public sector implementation, ethical AI guidelines, privacy & data protection, safety & security, transparency & explainability, fairness & mitigating bias, a human-centred approach, professional responsibility, and the promotion of cultural & human values. 

The AI policy framework can be evaluated from a content and procedural perspective. Substantively, the framework’s high-level themes and focus areas are ambitious but comprehensive and logical. The focus extends beyond the technology and its value to consider its socioeconomic and ethical impact. The document acknowledges both the benefits and risks of AI, and notes SA’s marginal position in the global AI landscape.

It wisely accepts that a one-size-fits-all approach is not feasible, advocating for sector-specific requirements. However, much work remains to flesh out the framework into actionable steps, timelines and key performance indicators, which are likely to be detailed in the final national policy. Only then can the feasibility of the framework’s strategic pillars be properly assessed. 

Little information

However, the more pressing issue lies in the procedural shortcomings of the framework.  First, it lacks a clear methodology and offers no attribution beyond the department of communication & digital technologies. There is no explanation of how the document was developed or how the strategic pillars were chosen. While these choices are not necessarily problematic, a robust policy document should include an open and understandable methodology, a basic requirement of any piece of academic, scientific or evidence-based writing.

Additionally, the document provides little information about the authors or the consultation process, leaving readers in the dark about the expertise, credibility, biases or motivations of those who drafted it. The reference list is also relatively outdated, with two-thirds of the sources from 2020 or earlier, a shortcoming in a field that progresses rapidly. 

Second, it is unclear how the department plans to solicit and incorporate feedback from a broad range of stakeholders. By August 26 the AI framework was not available on the department’s website or social media accounts, and there is no publicly available plan for how the document will be shared with citizens, academia, civil society or businesses, nor is there a timeline.

The document was released only by media and appears to be a top-down initiative imposed on key stakeholders, contrasting with research suggesting that a national AI policy should, at least partly, be developed through a bottom-up approach to ensure it reflects the issues of major stakeholders and gains wide legitimacy. 

Fragmented

Lastly, the framework does not seem to align with previous domestic or international policy efforts. Notably, it makes no mention of the department’s AI planning document released earlier in 2024 that outlined various activities and timelines for developing an AI policy. It is unclear what the status of this document is, if any.

The framework also overlooks the former minister’s announcement that an AI Expert Advisory Council and the AI Institute of SA would drive the policy forward. This omission makes government’s AI policy initiative seem fragmented and disjointed. Furthermore, there is no effort to harmonise SA’s policy with international efforts, such as the AU’s AI strategy or Unesco’s recommendations on the ethics of AI. 

While the framework is a commendable milestone towards an AI strategy, its procedural aspects need greater clarity and robustness. Moreover, there is a need to speed up the process and ensure it is inclusive. Unlike previous general purpose technologies such as the internal combustion engine, electricity and the internet, which took decades to diffuse across the economy, AI will not give society much time to adapt. 

South Africans, including labour, business and civil society, should seize the opportunity to provide input on the framework to ensure the final AI policy reflects the considerations and values of all sectors of society. The government should ensure the final policy captures AI’s benefits while mitigating risks, for all segments of society. 

• Ormond has a PhD in AI ethics risk governance and two decades of experience in policy analysis. He writes in his personal capacity.

Picture: 123RF/NICOELNINO
Picture: 123RF/NICOELNINO
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