Sandbox for AI and Blockchain Startups
Ukraine · Framework · Ministry of Digital Transformation of Ukraine, Ukrainian Startup Fund
Our summary
This sandbox program provides consultations, audits and expert recommendations to Ukrainian teams developing artificial intelligence and blockchain products. Participants receive legal, technology and business expertise across sectors including public services, healthcare, defense and digital economy. The program runs until October 2026 and is operated by the Ministry of Digital Transformation in partnership with the Ukrainian Startup Fund.
Written by the Index in our own words. It is not legal advice; the official text is the authority.
Inside this policy
Every section of this policy in order. Our notes summarise each one in plain language and do not quote the official text, which is the authority.
Drafted by the Index An automated summary of the official text, not yet reviewed by a person.Reviewed Checked by a person against the official text.
11 sections
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Pilot and scale high-tech products with government support
Your company operates in the following types of economic activities
Defines economic activities in IT, data processing, research and development, and cultural heritage management that are eligible for the sandbox. Participants must complete application parts, develop a research plan, undergo product audit, receive expert consultations and recommendations, and submit a research report.
The conclusions may include
Expert conclusions assess product safety, legal compliance and standards adherence, evaluate market demand and identified vulnerabilities or non-compliance, suggest risk mitigation methods, assess improvement measures, and provide recommendations for product implementation.
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Why can participation in the Sandbox be terminated?
Participants may voluntarily terminate their sandbox participation or face involuntary termination by the organizer if regulatory changes prohibit their product, they breach participation requirements, or adverse company information emerges. The sandbox program itself expires in October 2026.
Who is not eligible to participate in Sandbox?
Companies and individuals registered in occupied territories, linked to Russia or Belarus, under sanctions, or with beneficial owners from those countries are ineligible. Products for fintech, gambling, or those prohibited by law cannot be tested in the sandbox.
How to prepare for participation in the Sandbox?
Applicants should identify required expertise scope, provide detailed product descriptions including technology and target market, and prepare technical documentation demonstrating innovation. Bankruptcy and debt certificates are recommended.
Can a company participate in Sandbox if its product is aimed at the international market?
Companies may participate with products aimed at international markets, as the sandbox considers international standards and regulations including the AI Act to support market entry into the EU and other jurisdictions.
What happens if serious risks are identified during the assessment?
Experts help identify risks and their severity while recommending mitigation or remediation approaches without rejecting products or imposing penalties.
Can you apply to Sandbox again?
Companies and individuals may reapply to the sandbox with a different product or an improved version of a previously submitted solution.
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Controls
What this policy requires, forbids, grants or penalises, one control at a time and in our own words. Each control links to the official text, which is the authority. This is not legal advice.
Drafted by the Index Drafted automatically from the official text, not yet reviewed by a person.Reviewed Checked by a person against the official text.
Themes covered 11 of 35
Choose a theme to see only its controls. About the themes
Risk and scope 2 of 4
- Risk classification, not covered
- Impact assessment, not covered
Data and privacy 1 of 4
- Data governance and quality, not covered
- Data subject rights and consent, not covered
- Copyright and training data, not covered
Transparency and records 1 of 4
- Transparency and disclosure to users, not covered
- Labelling of synthetic content, not covered
- Record keeping and logging, not covered
Technical safeguards 2 of 4
- Human oversight, not covered
- Bias and non-discrimination, not covered
Assurance and lifecycle 2 of 4
- Registration and notification, not covered
- Incident and breach reporting, not covered
Rights and protected groups 0 of 4
- Automated decision-making rights, not covered
- Children and vulnerable groups, not covered
- Biometric identification and surveillance, not covered
- Whistleblowing, complaints and redress, not covered
Roles and organisation 2 of 6
- Supply chain and provider-deployer duties, not covered
- General purpose and foundation models, not covered
- Accountability and governance roles, not covered
- Public sector use and procurement, not covered
Enforcement and sectors 1 of 5
- Enforcement, penalties and regulators, not covered
- Sector rules: health, not covered
- Sector rules: employment, not covered
- Sector rules: education, not covered
The full list of controls could not be loaded, so only the first 31 are shown.
Pilot and scale high-tech products with government support 5 controls
- ObligationApplies to: Public authorityDrafted by the Index
The Ministry of Digital Transformation and Ukrainian Startup Fund should operate a program enabling Ukrainian developers to test high-tech products in digital economy, infrastructure, public services, healthcare, biotechnology, education, agriculture, energy, culture and defense sectors.
- Applies to: ProviderDrafted by the Index
Ukrainian-registered companies or individual entrepreneurs developing AI or blockchain products may participate in sandbox testing across various development stages.
- ObligationApplies to: Public authorityDrafted by the Index
Sandbox operators should provide legal, technology and business expertise to participant teams.
- ObligationApplies to: Public authorityDrafted by the Index
Sandbox operators should conduct legal audits covering data protection, intellectual property, and compliance with the EU AI Act.
- ObligationApplies to: Public authorityDrafted by the Index
Sandbox operators should perform technological assessment of AI products across their design, operation and deactivation, plus blockchain and cybersecurity evaluations.
Your company operates in the following types of economic activities 3 controls
- ObligationApplies to: ProviderDrafted by the Index
Sandbox participants working in computer programming, IT consulting, data processing, research, engineering and cultural heritage management should complete application sections, develop a research plan, undergo product audit, obtain expert consultations and submit a final report.
Applies when: IT, data processing, research and development, or cultural heritage sectors
- ObligationApplies to: ProviderDrafted by the Index
Applicants should provide company details and contact information in the first part of the sandbox application.
- ObligationApplies to: ProviderDrafted by the Index
Applicants should describe their product, obtain electronic signature authorization and submit the second part of the application.
The conclusions may include 4 controls
- ObligationApplies to: Public authorityDrafted by the Index
Expert conclusions for sandbox products should assess safety, legal compliance, standards adherence and market demand.
- ObligationApplies to: Public authorityDrafted by the Index
Expert conclusions should identify defects, vulnerabilities, risks and non-compliance through applied research methods.
- ObligationApplies to: Public authorityDrafted by the Index
Expert conclusions should suggest methods to address identified risks and resolve discovered issues.
- ObligationApplies to: Public authorityDrafted by the Index
Expert conclusions should evaluate improvement measures and provide recommendations for product implementation.
Why can participation in the Sandbox be terminated? 4 controls
- Applies to: OthersDrafted by the Index
Participants may voluntarily exit their sandbox participation at any time.
- Applies to: Public authorityDrafted by the Index
The organizer may terminate a participant's sandbox participation involuntarily if a new law directly prohibits the product being tested.
- Applies to: Public authorityDrafted by the Index
The organizer may terminate a participant's sandbox participation involuntarily if company information emerges that would have made the applicant ineligible.
- Applies to: Public authorityDrafted by the Index
The organizer may terminate a participant's sandbox participation involuntarily if the participant fails to meet their agreed research plan.
Who is not eligible to participate in Sandbox? 8 controls
- ProhibitionApplies to: Public authorityDrafted by the Index
Companies or entrepreneurs registered in temporarily occupied Ukrainian territories are ineligible for sandbox participation, unless they relocate their tax address elsewhere in Ukraine.
- ProhibitionApplies to: Public authorityDrafted by the Index
Companies or entrepreneurs that are founders or participants in other entities registered in Russia or Belarus are ineligible for sandbox participation.
- ProhibitionApplies to: Public authorityDrafted by the Index
Companies or entrepreneurs with subsidiaries or separate units in Russia or Belarus are ineligible for sandbox participation.
- ProhibitionApplies to: Public authorityDrafted by the Index
Companies or entrepreneurs under sanctions, or with founders or participants subject to sanctions, are ineligible for sandbox participation.
- ProhibitionApplies to: Public authorityDrafted by the Index
Companies or entrepreneurs with ultimate beneficial owners who are citizens of Russia or Belarus are ineligible for sandbox participation, unless those owners legally reside in Ukraine.
- ProhibitionApplies to: Public authorityDrafted by the Index
Products for use in the fintech sector cannot be tested in the sandbox.
- ProhibitionApplies to: Public authorityDrafted by the Index
Products for organizing or conducting gambling activities cannot be tested in the sandbox.
- ProhibitionApplies to: Public authorityDrafted by the Index
Products that are prohibited by law cannot be tested in the sandbox.
How to prepare for participation in the Sandbox? 4 controls
- Applies to: OthersDrafted by the Index
Applicants should identify what expertise they require to develop their product.
- Applies to: OthersDrafted by the Index
Applicants should prepare a detailed product description covering application area, technology, target consumers and business model.
- Applies to: OthersDrafted by the Index
Applicants may, but are not required to, provide technical documentation and a justification of how their product is innovative.
- Applies to: OthersDrafted by the Index
Applicants should prepare certificates showing that their company is not undergoing bankruptcy or has outstanding debts.
Can a company participate in Sandbox if its product is aimed at the international market? 1 control
- Applies to: OthersDrafted by the Index
Companies may participate in the sandbox with products aimed at international markets.
What happens if serious risks are identified during the assessment? 1 control
- Applies to: OthersDrafted by the Index
Sandbox experts should help identify risks in assessed systems, evaluate their severity, and recommend mitigation or remediation approaches without penalising or blocking products.
Can you apply to Sandbox again? 1 control
- Applies to: AnyoneDrafted by the Index
Companies and individual entrepreneurs may reapply to the sandbox with a different product or an improved version of a previously submitted solution.
Change history
No changes recorded since we began monitoring this policy.