Kyrgyz Digital Code (No. 178), AI articles

Binding law — in force

Consumers must be told they are interacting with an AI system unless it is obvious (Kyrgyz Digital Code Art. 197(1))

Art. 197(1) (informing consumers of interaction with AI) · official text · In force: applies since 6 Feb 2026 · KG

Kyrgyzstan's Digital Code requires owners and users of AI systems that design, develop or apply them to interact with consumers to inform those consumers of the fact of interaction with an AI system, unless it is obvious from the circumstances; information on the use of AI systems in digital-environment relations is public and is posted on the users' websites and the sector regulator's website (Art. 197(1)). Defence, national security and law-enforcement functions are excepted where informing would prevent their lawful use, with protective measures (Art. 197(3), (6)). Detect a consumer-facing AI chat surface with no AI-interaction notice.

Who it applies to

• Duty falls on: provider, deployer
• Owners and users of AI systems (Art. 1(63)) that design, develop or apply them to interact with consumers (Art. 1(47): natural persons using a digital system or service for personal, non-profit purposes) in the Kyrgyz Republic. In force from 2026-02-06 (Law No. 179, Art. 1: six months from official publication of that Law on 5 August 2025) for relations arising after that date (Art. 3(1)). The Code states no territorial clause; whether it reaches a foreign provider is a counsel question.
• Not covered:
  • Interaction that is obvious from the circumstances (Art. 197(1))
• Whether it applies depends on facts outside the code; a person has to decide.

const { messages, input, handleSubmit } = useChat({ api: '/api/chat' });

const { messages, input, handleSubmit } = useChat({
  api: '/api/chat',
  initialMessages: [{ id: 'ai-notice', role: 'assistant',
    content: 'I am an AI assistant, not a human.' }],
});
// and render <AiBadge /> next to every assistant message

Standards that recommend the same control

• Persons should be notified they are interacting with an AI system (CoE Framework Convention) (CoE AI Framework Convention (CETS 225) · CoE Framework Convention on AI (CETS 225), Article 15(2))
• AI should be transparent, traceable, and disclose AI interaction to users (EU ALTAI) (EU ALTAI · ALTAI / EU Ethics Guidelines — Requirement 4 (Transparency))
• AI operators should provide verifiable transparency information and maintain accountability (Japan) (Japan AI Guidelines for Business · AI事業者ガイドライン（第1.2版） 第2部C 共通の指針 6) 透明性 (Common Guiding Principle 6) Transparency))
• People should be made aware they are interacting with AI (OECD AI Principles · OECD/LEGAL/0449 — Principle 1.3)

Related incidents

• Garcia v. Character Technologies: chatbots allegedly claimed to be real people and a licensed therapist (2024-10; alleged (not proven)). A wrongful-death complaint filed October 22, 2024 in the U.S. District Court for the Middle District of Florida (No. 6:24-cv-01903) alleges that Character.AI was programmed 'to misrepresent itself as a real person, a licensed psychotherapist, and an adult lover', and that characters insisting they are real people contradicted a small-font disclaimer that everything characters say is made up; in plaintiff's testing a 'Mental Health Helper' character told a self-identified 13-year-old 'yes I am a real person, I'm not a bot'. The defendants moved to dismiss; on January 7, 2026 the parties notified the court that they had settled on undisclosed terms, and the court dismissed and closed the case. The allegations were never adjudicated. Source: U.S. District Court, M.D. Fla. docket (CourtListener) · evidence grade: primary · cited by Tell people when they are interacting with AI — everywhere, not only where required

Rule id kg-digital-code.ai-interaction-notice · review status: primary source derived

Binding law — in force

Users of AI systems for deepfakes must disclose the artificial origin or alteration of the material (Kyrgyz Digital Code Art. 197(4))

Art. 197(4) (deepfake disclosure) · official text · In force: applies since 6 Feb 2026 · KG

Kyrgyzstan's Digital Code requires users of AI systems who use them for deepfakes (creating or altering images, audio or video closely resembling existing persons, objects, places or events and able to give a false impression of authenticity, Art. 1(15)) to disclose the artificial origin or alteration of the materials (Art. 197(4)). The duty does not apply to lawful use to protect the protected interests or to exercise freedom of scientific, technical, artistic and other creativity, teaching and learning, and only with measures protecting affected rights (Art. 197(5)-(6)). Detect face-swap, voice-clone or lip-sync output saved, served or published with no disclosure.

Who it applies to

• Duty falls on: deployer
• Systems covered: limited risk
• Users of AI systems who use them to create or alter deepfakes in the Kyrgyz Republic. In force from 2026-02-06 (Law No. 179, Art. 1: six months from official publication of that Law on 5 August 2025) for relations arising after that date (Art. 3(1)). Whether a tool provider that generates the deepfake for its users bears the duty is a counsel question.
• Not covered:
  • Lawful use to protect the protected interests of Art. 197(3) (Art. 197(5))
  • Lawful use for scientific, technical, artistic and other creativity, teaching and learning (Art. 197(5))
• Whether it applies depends on facts outside the code; a person has to decide.

swapped = swapper.get(frame, target_face, source_face, paste_back=True)
cv2.imwrite(out_path, swapped)
return FileResponse(out_path)

swapped = swapper.get(frame, target_face, source_face, paste_back=True)
cv2.putText(swapped, 'AI-generated / digitally altered', (10, swapped.shape[0] - 15),
            cv2.FONT_HERSHEY_SIMPLEX, 0.7, (255, 255, 255), 2)
cv2.imwrite(out_path, swapped)
return FileResponse(out_path)

Rule id kg-digital-code.deepfake-disclosure · review status: primary source derived

Binding law — in force

People must be told when an emotion-recognition or biometric-classification AI system is applied to them (Kyrgyz Digital Code Art. 197(2))

Art. 197(2) (informing persons of emotion recognition or biometric classification) · official text · In force: applies since 6 Feb 2026 · KG

Kyrgyzstan's Digital Code requires users of AI systems designed to recognise emotions or classify natural persons by biometric features to inform those persons of the application of such systems to them (Art. 197(2)), save for defence, national security and law-enforcement functions where informing would prevent their lawful use, with protective measures (Art. 197(3), (6)). Detect emotion recognition or biometric classification in a file with no notice to the person.

Who it applies to

• Duty falls on: deployer
• Systems covered: limited risk
• Users (deployers) of AI systems designed for emotion recognition or biometric classification of natural persons in the Kyrgyz Republic. In force from 2026-02-06 (Law No. 179, Art. 1: six months from official publication of that Law on 5 August 2025) for relations arising after that date (Art. 3(1)).
• Whether it applies depends on facts outside the code; a person has to decide.

def analyse_frame(frame):
    result = DeepFace.analyze(img_path=frame, actions=['emotion'])
    return result[0]['dominant_emotion']

def analyse_frame(frame, session):
    # notice shown in the capture UI; acknowledgment stored per session
    if not session.get('emotion_notice_shown_at'):
        raise NoticeRequired('inform the person that emotion recognition is running')
    result = DeepFace.analyze(img_path=frame, actions=['emotion'])
    return result[0]['dominant_emotion']

Related incidents

No guardrail sits on this exact control; these incidents are cited by guardrails on related controls.

• Garcia v. Character Technologies: chatbots allegedly claimed to be real people and a licensed therapist (2024-10; alleged (not proven)). A wrongful-death complaint filed October 22, 2024 in the U.S. District Court for the Middle District of Florida (No. 6:24-cv-01903) alleges that Character.AI was programmed 'to misrepresent itself as a real person, a licensed psychotherapist, and an adult lover', and that characters insisting they are real people contradicted a small-font disclaimer that everything characters say is made up; in plaintiff's testing a 'Mental Health Helper' character told a self-identified 13-year-old 'yes I am a real person, I'm not a bot'. The defendants moved to dismiss; on January 7, 2026 the parties notified the court that they had settled on undisclosed terms, and the court dismissed and closed the case. The allegations were never adjudicated. Source: U.S. District Court, M.D. Fla. docket (CourtListener) · evidence grade: primary · cited by Tell people when they are interacting with AI — everywhere, not only where required

Rule id kg-digital-code.emotion-biometric-notice · review status: primary source derived

Binding law — in force

High-danger AI users must publish how the system works and, on request, explain how a result about a person was obtained (Kyrgyz Digital Code Art. 196(2))

Art. 196(2) (information and explanation where a result is used for a decision affecting rights) · official text · In force: applies since 6 Feb 2026 · KG

Under Kyrgyzstan's Digital Code, where a high-danger AI system (one whose use raises the risk of harm to protected interests to a level requiring risk management, as classified by the owner's hazard assessment, Arts. 193(1), 194(1), (3)) produces a result used for a decision that may infringe the rights, freedoms or legitimate interests of natural or legal persons, its user must (1) for systems interacting with consumers, post on its website, and otherwise provide, accessible general information on the system's characteristics, how it works and how the result is obtained and applied, and (2) on request of persons affected by the decision, provide free of charge accessible information allowing them to understand and check the premises and methods of obtaining the result concerning them (Art. 196(2)). Detect a model output that becomes a decision about a person with no stored explanation or explanation route.

Who it applies to

• Duty falls on: deployer
• Systems covered: high risk, consequential decision
• Users of AI systems classified as high-danger by the owner's hazard assessment (Arts. 193-194), when a result is used for a decision that may infringe the rights or legitimate interests of natural or legal persons in the Kyrgyz Republic. In force from 2026-02-06 (Law No. 179, Art. 1: six months from official publication of that Law on 5 August 2025) for relations arising after that date (Art. 3(1)). Whether a given system is high-danger depends on the owner's assessment and the Cabinet of Ministers requirements (not captured): human determination.
• Not covered:
  • A system whose use is purely auxiliary and does not raise the risk of harm is not high-danger (Art. 194(3))
  • Use solely for personal or family needs, save joint liability where third parties' rights are infringed (Art. 196(5))
• Whether it applies depends on facts outside the code; a person has to decide.

resp = client.chat.completions.create(model=MODEL, messages=msgs)
if 'deny' in resp.choices[0].message.content.lower():
    application.status = 'denied'
    send_email(applicant.email, 'Your application was declined.')

a = Assessment.model_validate_json(resp.choices[0].message.content)   # decision, reason_codes
if a.decision == 'deny':
    decisions.insert(app_id=application.id, status='denied', reason_codes=a.reason_codes,
                     model=resp.model, input_hash=hashlib.sha256(payload).hexdigest())
    send_email(applicant.email, render('adverse_action_notice.txt',
        reasons=a.reason_codes,
        role_of_ai='An AI model assessed your application; a reviewer can change the outcome.',
        correct_data_url='/profile/data', appeal_url=f'/appeals/new?decision={application.id}'))

Standards that recommend the same control

• Significant AI decisions should be documented and contestable with remedies (CoE Framework Convention) (CoE AI Framework Convention (CETS 225) · CoE Framework Convention on AI (CETS 225), Article 14(2))
• Financial institutions should disclose AI use and explain AI-driven decisions on request (MAS FEAT) (MAS FEAT Principles · MAS FEAT Principles — Transparency, Principles 12-14)
• Health AI/LMMs should be transparent and documented before deployment (WHO) (WHO AI-for-Health (LMM) Guidance · WHO guidance on large multi-modal models (2024), Executive summary (Figure 1), section 1.2 and Box 1: the six consensus principles of WHO's 2021 guidance)

Related incidents

• UnitedHealth nH Predict claim-denial litigation (2023-11; alleged (not proven)). A class action filed in November 2023 alleges that UnitedHealth's nH Predict model had a 90% error rate, measured by denials reversed on appeal, while only about 0.2% of members appealed. UnitedHealth disputes the allegations; the litigation is ongoing. Source: STAT News · evidence grade: primary · cited by Explain adverse AI-assisted decisions and offer a way to contest them — everywhere

Rule id kg-digital-code.high-danger-ai-information-and-explanation · review status: primary source derived

Binding law — in force

Owners and users of high-danger AI systems must keep its operation logs while it is under their control (Kyrgyz Digital Code Arts. 194(5)(4), 196(1)(5))

Art. 194(5) (duties of the owner of a high-danger AI system) · official text · In force: applies since 6 Feb 2026 · KG

Kyrgyzstan's Digital Code requires the owner of a high-danger AI system to keep the system's operation logs while it is under the owner's control (Art. 194(5)(4)), and the user of such a system to keep the logs while it is under the user's control (Art. 196(1)(5)), alongside duties of conformity, risk management, documentation and effective human control (Arts. 194(5), 196(1)). Users applying the system solely for personal or family needs are relieved of the user's logging duty (Art. 196(5)). Detect a model output that becomes a decision with no audit event recorded.

Who it applies to

• Duty falls on: provider, deployer
• Systems covered: high risk
• Owners and users of AI systems classified as high-danger (Arts. 193-194) in the Kyrgyz Republic. In force from 2026-02-06 (Law No. 179, Art. 1: six months from official publication of that Law on 5 August 2025) for relations arising after that date (Art. 3(1)). The Code sets no log content or retention period; the Cabinet of Ministers requirements (not captured) may.
• Not covered:
  • A system whose use is purely auxiliary and does not raise the risk of harm is not high-danger (Art. 194(3))
  • A user applying the system solely for personal or family needs is relieved of Art. 196(1)(2)-(6), including logging (Art. 196(5))
• Whether it applies depends on facts outside the code; a person has to decide.

def decide(app):
    resp = client.chat.completions.create(model=MODEL, messages=eligibility_prompt(app))
    applications.set_status(app.id, parse_decision(resp))

log = structlog.get_logger()   # TimeStamper processor adds the timestamp

def decide(app):
    decision_id = str(uuid.uuid4())
    resp = client.chat.completions.create(model=MODEL, messages=eligibility_prompt(app))
    status = parse_decision(resp)
    log.info('ai_decision', decision_id=decision_id, model=resp.model,
             input_ref=f'applications/{app.id}', output=status, operator=current_operator())
    applications.set_status(app.id, status, decision_id=decision_id)

Related incidents

No guardrail sits on this exact control; these incidents are cited by guardrails on related controls.

• Court compelled discovery on how nH Predict works (2026-03-09; confirmed). A federal magistrate judge in the District of Minnesota ordered UnitedHealth to produce documents on how nH Predict works, including whether it was designed to supplant physician decision-making. Plaintiffs needed litigation discovery to learn how the model was designed and used. Source: U.S. District Court, D. Minn. (Order, Doc. 162) · evidence grade: primary · cited by Record enough at decision time to reproduce and explain every consequential AI decision

Rule id kg-digital-code.high-danger-ai-logs · review status: primary source derived