Mongolia: Laying the Foundations for Digital Governance and Data Protection

Mongolia is building its AI governance framework from an emerging but ambitious position, anchored by the National AI and Big Data Strategy finalized in early 2025 and currently awaiting parliamentary adoption. The country's approach combines digital government transformation with data protection foundations laid by the Law on Personal Data Protection enacted in December 2021. Led by the Ministry of Digital Development, Innovation, and Communications in partnership with UNDP, Mongolia's strategy prioritizes inclusive infrastructure reaching rural and nomadic populations, AI applications in mining, healthcare, and education, and ethical governance principles. Mongolia ranks 98th on the Oxford Insight Government AI Readiness Index but has climbed significantly, gaining 11 positions in the latest assessment. The country's e-government performance is notably strong at 46th globally in the UN E-Government Development Index, providing a solid digital foundation for AI adoption.

The National AI and Big Data Strategy, developed jointly by the Ministry of Digital Development, Innovation, and Communications and UNDP, was finalized in early 2025 and presented at the World Economic Forum in Davos in February 2025. The strategy was formally submitted to government leadership by Minister Baatarkhuu Tsend in May 2025 and is now before the State Great Khural (Parliament) for adoption. A new Data Protection Law announced for 2025 rollout will establish guidelines for ethical AI use, ensure transparency in algorithmic decision-making, and provide protections against algorithmic bias. The government is developing plans for a National Council on Artificial Intelligence, a GPU cluster-based AI Center, and a National Data Repository. The National Initiative for Developing AI Knowledge and Skills (2026-2028) targets training 60,000 public servants, 10,000 workers in vulnerable sectors, and 1,000 designated AI Ambassadors. The AI Academy Asia National Campaign, launched in April 2025, aims to train 250 AI engineers and 2,250 teachers across all 21 aimags (provinces) by 2029.

Government agencies across all ministries face transformation as the National AI and Big Data Strategy mandates AI integration in public service delivery through the e-Mongolia digital government platform. Public servants are directly impacted by the skills initiative targeting 60,000 government workers for AI training by 2028. The mining and energy sectors are prioritized for AI development given their outsized role in Mongolia's economy, with companies expected to adopt AI for exploration, environmental monitoring, and operational efficiency. Educational institutions are central to the strategy, with plans for graduate scholarship programs, funding for 100 AI research topics, and training of 300 master's and doctoral students. Rural and nomadic communities are specifically targeted through inclusive infrastructure provisions designed to bridge the digital divide across Mongolia's vast territory. Healthcare providers will benefit from AI applications in telemedicine and diagnostic support, particularly important given Mongolia's geographic challenges in delivering medical services. Financial institutions processing personal data must comply with the existing Law on Personal Data Protection and anticipated AI-specific requirements under the forthcoming data protection law.

Mongolia's AI governance approach is built on several foundational principles reflecting the country's unique circumstances and development priorities. Inclusivity and accessibility are paramount, with explicit commitments to ensuring AI benefits reach nomadic and rural populations across the country's dispersed geography. Ethical governance and algorithmic accountability feature prominently in both the National AI Strategy and the forthcoming data protection legislation, emphasizing transparency in automated decision-making and protections against bias. The strategy prioritizes human capital investment, recognizing that Mongolia's relatively small population of 3.4 million requires targeted approaches to building AI expertise, including the AI Ambassadors program and international scholarship partnerships. Data sovereignty and security underpin the planned National Data Repository and cybersecurity infrastructure investments. Innovation and economic diversification drive the strategy's focus on using AI to reduce dependence on mining by fostering technology exports and positioning Mongolia as a Central Asian digital data hub by 2030. International cooperation is embedded through partnerships with UNDP, Oracle, Cambridge University, and the AI Academy Asia initiative, reflecting Mongolia's pragmatic approach to accessing global AI expertise while building domestic capacity.

Businesses operating in Mongolia should prepare for a gradually evolving regulatory environment as the National AI and Big Data Strategy moves through parliamentary adoption. Companies processing personal data must already comply with the Law on Personal Data Protection (effective May 2022), which requires written consent before data collection and restricts cross-border data transfers without consent or legal basis. The forthcoming data protection law will introduce additional requirements specifically addressing AI systems, including algorithmic transparency and bias prevention obligations. Mining and energy companies should actively engage with AI adoption programs, as these sectors are first-priority targets for the strategy's implementation. Technology firms and AI developers will find opportunities in government digitalization projects through the e-Mongolia platform and planned AI Center infrastructure. International businesses can leverage Mongolia's innovation-friendly regulatory approach, with the government explicitly aiming to create a supportive environment for technology companies through flexible regulations and planned regulatory sandboxes. Oracle's three-year AI and big data skills partnership provides a model for corporate engagement in Mongolia's AI ecosystem. The planned National Data Repository and international data center ambitions signal emerging opportunities in data infrastructure and cloud services.

The most critical near-term development is parliamentary consideration of the National AI and Big Data Strategy, which will formalize Mongolia's AI governance direction and unlock implementation funding. The establishment of the National Council on Artificial Intelligence and the GPU cluster-based AI Center will signal the transition from planning to operational capacity building. The new Data Protection Law expected in 2025-2026 will be the first legislation directly addressing AI governance, and its scope and enforcement mechanisms will set the regulatory tone. Progress on the National Initiative for Developing AI Knowledge and Skills (2026-2028) will determine whether Mongolia can build sufficient domestic AI talent to sustain its ambitions. The AI Academy Asia National Campaign's expansion across all 21 provinces through 2029 will test the viability of inclusive AI education in a geographically challenging environment. Mongolia's e-government performance and the e-Mongolia platform's evolution will serve as a practical testbed for AI in public services. International partnerships, particularly with UNDP and Oracle, will influence the pace and direction of implementation. The government's ambitious target of exporting AI products and establishing Central Asian digital data hub status by 2030 will require significant infrastructure investment, making data center development and connectivity improvements important indicators of progress.