Artificial Intelligence (AI) in Tanzania: Emerging Legal Challenges as the Case for Coherent Regulatory Framework

Technology is advancing at an unprecedented pace. In the last two decades, we have witnessed tremendous growth in digital communications, computer networking, and most recently, the adoption of Artificial Intelligence (AI) tools.

We are in the midst of an AI boom. As of 2026, large frontier models have been released by OpenAI, Anthropic, Google DeepMind, Meta Superintelligence Labs, SpaceXAI and others. AI tools are now used extensively in arts, entertainment, academia, research, and professional services.

The Emerging Risk: AI Hallucinations

This rapid adoption has exposed serious risks. Professionals and firms, among others, both in Tanzania and abroad, have fallen into error by relying on AI-generated reports that were later proven to be erroneous or entirely fabricated. In Australia, for example, on 07th October 2025, Fortune reported that a leading accounting firm was required to partially refund AU$290,000 for a report containing alleged AI-generated errors, including references to non-existent academic papers and a fabricated quote from a federal court judgment. Another firm had to withdraw a global report on AI after multiple case studies were found to be inaccurate and apparently the product of AI hallucinations.

Again, just recently, in Australia, the BBC reported that OpenAI was criticised for failures around when and how it notified the government that an autonomous agent gained unauthorised access to Medicare statistics hosted on an old Services Australia online portal. This was an unprecedented breach of a government website by a rogue OpenAI agent. As a response to this incident, a taskforce is now undertaking a rapid review of the OpenAI incident to examine legal gaps and inform new AI national standards, governing how the technology operates in Australia.

On September 25, 2026, Reuters reported about fraudsters using AI to impersonate senior executives and stole €95,000,000 (US$ 108,000,000) from Fideuram, the private banking arm of Italy’s biggest lender ​Intesa Sanpaolo.  It is reported that the scheme began in February, 2026 when Fideuram Chairman received what appeared to be a WhatsApp message from ​Intesa Sanpaolo CEO seeking urgent help with an overseas ⁠transaction. The fraudsters followed up with a phone call that appeared to come ​from a senior partner at a prominent law firm, confirming the instruction. According ​to the sources, the callers used AI technology to replicate the lawyer’s voice.

Tanzania is not spared. The most recent example is the decision of the High Court of Tanzania in Registered Trustees of AGGCI v. Registrar of Societies & 5 Others, Misc. Civil Application No. 9407 of 2026 delivered on September 03rd 2026. The Court suspended an advocate from practice for six months for citing non-existent judicial authorities in his submissions. The fabrication only came to light after the Court ordered the advocate to produce the decisions or face disciplinary action. As per the Court’s decision, the advocate failed to produce the authorities as they were no-existent, having conceded to have cited non-existent judicial authorities based on his on-line search, which the Court referred to them as non-existent and potentially Al-generated cases of the Court of Appeal.

In the absence of a readily available comprehensive legal and regulatory framework for artificial intelligence, given the pace at which technology is moving, the door is left open for a vast number of such hallucinations which are now cross-cutting and with far-reaching consequences. 

Current Position in Tanzania

Currently, in Tanzania, while we hope that the authorities are working on it, as at the date of this updater, we have not come across a published single comprehensive legal and regulatory framework that addresses AI-related challenges. However, one may be tempted to rely on a patchwork of existing laws, rather than a single framework, some of which predate the current AI boom. These include the Personal Data Protection Act, the Cybercrimes Act, the Electronic Transactions Act, and intellectual property laws, to name a few. Given the current pace of technological advancement, it is high time a comprehensive framework was put in place. This is not about banning AI. It is about a regulatory gap.

The Need for a Regulatory Framework

These challenges call for a comprehensive legal and regulatory framework. In the Tanzanian case, the High Court had to rely on its general disciplinary powers and the Advocates Act and the Advocates (Professional Conduct and Etiquette) Regulations. Perhaps, there could have been more to this, had there been a single, coherent AI-specific legal and regulatory framework to address such conduct.

The potential impact is far-reaching: authenticity of judicial authorities, documents and evidence in legal proceedings, law enforcement, plagiarism in literary and academic works, intellectual property rights, identity theft, fraudulent transactions, and human dignity, unauthorised data accesses and breaches, among others.

The global response is growing. On 25th May 2026, Pope Leo XIV issued his first encyclical, Magnifica Humanitas, concerned with safeguarding the human person in the age of artificial intelligence. As of the date of this updater, the European Union has enacted the Artificial Intelligence Act (effective 1st August 2024), establishing a common regulatory framework for AI across the Union, with limited exemptions for military, national security, research, or non-professional use. The United States appears to be moving in a similar direction.

Under Article 1, the EU Act aims to improve the functioning of the internal market and promote the uptake of human-centric and trustworthy AI, while ensuring a high level of protection of health, safety, and fundamental rights enshrined in the Charter, including democracy, the rule of law and environmental protection, against the harmful effects of AI systems. Its scope covers providers placing AI systems or general-purpose AI models on the market in the Union, irrespective of whether those providers are established within the Union or in a third country. established or located within the Union or in a third country.

Way Forward

In the event such a framework is considered, it should:

    1. Recognize that Tanzania cannot escape the AI boom and therefore needs to have a single comprehensive framework that regulates AI-relevant activities, despite the existing laws on data protection, electronic transactions, cybercrime, and electronic communications, among others;
    2. Address the regulatory gap, to have in place a coherent, cross-sector AI governance framework that allocates responsibility according to the risk posed by different AI applications and systems; and
    3. Complement and harmonize, rather than unnecessarily duplicate or conflict with, existing sectoral legislation and regulations.
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