AI Made in Africa: Why Refugee-Led SMEs Must Be Part of Africa’s AI Future

Artificial Intelligence is rapidly becoming part of Africa’s economic transformation. Across the continent, governments, businesses, entrepreneurs, civil society and development partners are exploring how AI can improve productivity, expand digital services, create new markets and support innovation.

But an important question remains insufficiently addressed:

Who gets to participate in Africa’s AI economy?

My policy paper, “AI Made in Africa: Removing Policy Barriers for Refugee-Led SMEs in East Africa and the Great Lakes Region” examines this question from the perspective of refugee entrepreneurs and refugee-led small and medium-sized enterprises (SMEs).

The paper argues that refugee entrepreneurs should not be viewed only through a humanitarian lens. They are also business owners, innovators, employers, consumers, digital users and participants in regional markets. Yet many remain excluded from the formal systems that increasingly determine access to digital commerce and AI-enabled business opportunities.

The research shows that the central challenge is not simply whether refugee entrepreneurs have the skills to use AI. Rather, it is whether the legal, financial, digital and infrastructure systems around them allow them to turn technology into sustainable economic opportunities.

From AI access to AI participation

The distinction between access to technology and meaningful participation is important.

A refugee entrepreneur may have a smartphone, an internet connection and an AI application. They may use AI to translate information, create marketing content, communicate with customers or manage aspects of their business.

But what happens when that entrepreneur tries to scale?

They may be unable to open a bank account, access credit, verify a business account on a global platform, receive international payments, register a business easily, or maintain reliable connectivity.

In that situation, the technology is technically available, but the economic opportunity remains inaccessible.

This is what I describe in the paper as a “digital exclusion loop”:

Identity restrictions → financial exclusion → platform barriers → limited market participation → reduced AI adoption.

The problem therefore extends beyond digital literacy. It concerns the architecture of economic and digital participation.

What the research found

The paper combines policy analysis, literature review and primary field evidence. The primary research was conducted between April and May 2026 through an exploratory survey involving 12 respondents and eight semi-structured interviews with refugee entrepreneurs, refugee-led organizations, digital inclusion practitioners and organizations supporting refugee economic participation.

The research was primarily focused on Uganda, with representation from the Democratic Republic of the Congo and Rwanda and participants originating from Burundi, the DRC and Uganda.

The study is exploratory rather than statistically representative of all refugee-led SMEs in the region. Its value lies in identifying recurring patterns and policy barriers through field-based evidence and practitioner perspectives.

Several findings are particularly significant.

Refugee entrepreneurs are already using digital technologies

More than 83% of respondents reported using digital tools, while 42% were already using AI tools such as ChatGPT, translation services and automation applications.

At the same time, 67% had experimented with AI either regularly or occasionally, while 92% reported using mobile money services.

The applications reported included translation, marketing, content creation, customer communication, social media engagement and business administration.

These findings challenge the assumption that refugee entrepreneurs are simply waiting to be introduced to digital technology.

They are already participating.

The policy question is how to help them move from experimentation to meaningful and scalable business integration.

The verification problem: when legal identity becomes a digital barrier

One of the most important findings concerns identity and verification.

Modern digital economies increasingly depend on verified identities. Banks, fintech companies, payment providers, online marketplaces and technology platforms use Know Your Customer (KYC) and identity verification systems to determine who can access their services.

However, these systems are frequently designed around conventional national identity documents and permanent residence arrangements.

For displaced entrepreneurs, this can create a major barrier.

In the study, 42% of respondents reported having been denied access to digital or financial services or were uncertain whether their refugee status had affected access, while 67% reported barriers when using global digital platforms such as Google, Meta, X, PayPal and Stripe.

Account verification failures, payment restrictions and difficulties meeting platform identity requirements were among the frequently reported challenges.

One interview participant captured the issue particularly clearly:

“I can create content using AI tools, but I cannot monetize my business online because I cannot verify my account using refugee documentation.”

This illustrates an important policy contradiction.

An entrepreneur can possess the skills to use AI but still be unable to participate in the economic ecosystem surrounding it.

Connectivity is also an economic policy issue

AI adoption cannot be separated from infrastructure.

Across the countries examined in the paper, refugee-led SMEs operate in environments affected by expensive mobile data, unreliable electricity, slow or unstable internet connections and limited access to capable devices.

In the survey, 92% identified the high cost of internet connectivity as a major constraint, while the interviews highlighted unstable electricity and unreliable internet as significant obstacles to sustained AI use.

This creates what the paper describes as a Cost–Connectivity–Capability Trap:

High costs → reduced internet access → weaker productivity → disrupted digital operations → limited ability to integrate AI.

For an entrepreneur, this is not merely a technical inconvenience. It can mean missed customers, interrupted transactions, lost business opportunities and an inability to compete in digital markets.

The missed opportunity for Africa

The implications go beyond refugee communities.

Refugee entrepreneurs participate in local markets, regional trade networks and emerging digital economies. When they are excluded from formal digital systems, Africa loses potential contributions to entrepreneurship, innovation, employment, digital trade and regional economic integration.

The research found that 83% of respondents reported having missed business opportunities because of limited digital or AI access, including opportunities related to funding, partnerships, online markets and cross-border business.

This suggests that refugee economic inclusion should not be treated solely as a social protection or humanitarian concern.

It is also a question of digital economic policy and regional competitiveness.

If Africa is building an AI economy, then the people already operating businesses within African communities should be able to participate in that economy.

What should policymakers do?

The paper proposes a practical set of recommendations for governments, regional institutions, technology companies and development partners.

1. Governments: make economic participation possible

National governments can reduce administrative barriers by improving refugee documentation systems and ensuring that legally recognized refugee identification documents can be used consistently for business registration, banking, mobile money and eligible digital platform verification.

The paper also recommends one-stop business registration services, improved access to digital registration systems and greater inclusion of refugee entrepreneurs in national AI and digital economy programmes.

Importantly, refugee-led businesses should have access to existing SME digitalisation and AI programmes rather than being placed into completely separate systems.

2. AU and EAC: build interoperability into regional digital transformation

At the regional level, the African Union and East African Community have an opportunity to connect digital transformation, AI governance, digital trade and refugee economic inclusion.

The paper recommends greater interoperability of digital identity systems, harmonisation of relevant KYC and data-protection approaches, recognition of refugee documentation across borders and stronger integration of refugee entrepreneurship into implementation of the AfCFTA Digital Trade Protocol.

This is particularly important for entrepreneurs whose businesses depend on cross-border customers, suppliers, payments and markets.

3. Technology companies: design verification systems for real-world Africa

Technology companies and digital platforms also have a role.

Verification systems should better reflect the realities of displaced populations who may possess legitimate refugee documentation but lack conventional national identity documents.

The paper recommends alternative risk-based verification pathways, clearer explanations of verification requirements, dedicated support channels and meaningful appeal mechanisms for documentation-related account restrictions.

AI products should also become more accessible in low-resource environments through mobile-optimised and low-bandwidth solutions, offline or synchronised functionality, appropriate pricing models and interfaces that support widely spoken African languages.

4. Development partners: move from digital literacy to applied AI

Training remains important, but training alone is not enough.

Development partners should support refugee-led SMEs to integrate AI into actual business processes, including financial management, inventory control, customer relationship management, logistics and e-commerce.

The paper recommends AI business accelerators, community digital innovation hubs, peer-learning networks and the integration of AI advisory services into existing entrepreneurship and livelihood programmes.

This represents a shift from asking:

“How do we teach refugees to use AI?”

to asking:

“What prevents refugee entrepreneurs who already use technology from turning AI into sustainable business growth?”

Why the AI Made in Africa initiative matters

This research was developed as part of the AI Made in Africa initiative, a partnership between GIZ and the African Observatory on Responsible AI (AORAI), a flagship project of the Global Center on AI Governance (GCG).

The initiative provides an important platform for African researchers and practitioners to examine AI governance from perspectives grounded in African realities.

For me, participation in this initiative was particularly important because it created an opportunity to bring the experiences of refugee-led enterprises into conversations about Africa’s AI future.

The contribution of GIZ and GCG through the AI Made in Africa initiative demonstrates the value of supporting African-led research that connects emerging technology policy with the realities of communities and economic actors who are often underrepresented in mainstream technology discussions.

The research also contributes to a broader conversation: responsible AI governance must consider not only how AI systems are developed, but also who is able to access, use and benefit from them.

From research to policy action

Publishing this paper is not intended to conclude the conversation.

It is intended to help advance it.

For governments developing AI and digital economy strategies, regional institutions working on digital integration, financial institutions reviewing KYC systems, technology companies designing verification processes, development partners supporting entrepreneurship, and organizations working with displaced communities, the findings provide a basis for further discussion and practical experimentation.

The evidence points toward several areas where policy dialogue and pilot interventions could be developed:

• inclusive digital identity and verification;
• refugee-friendly KYC and financial access;
• digital payments and cross-border commerce;
• affordable connectivity in refugee-hosting areas;
• applied AI entrepreneurship programmes;
• digital innovation hubs;
• inclusive AI governance;
• evidence-based monitoring of refugee participation in digital economies.

These are areas where collaboration between governments, regional institutions, refugee-led organizations, technology companies, financial institutions, researchers and development partners can translate policy discussions into practical solutions.

A call for decision-makers and partners

Africa’s AI transformation is still being shaped.

This presents an opportunity to ensure that inclusion is designed into emerging systems rather than addressed after exclusion has already become embedded.

My research suggests that refugee entrepreneurs are not asking to be treated as exceptional beneficiaries of technology. They are seeking the opportunity to participate in economic systems in which they are already active.

The policy challenge is therefore not simply AI access.

It is AI participation.

And participation depends on the systems surrounding the technology: identity, finance, connectivity, regulation, digital platforms and regional market integration.

As I conclude in the paper:

“The future of Africa’s AI economy will depend not only on technological advancement, but also on who is permitted to participate in it.”

Continuing the conversation

As the author of this research and as a technology practitioner working directly with refugee communities and civil society actors in Africa and beyond, I welcome engagement with policymakers, researchers, technology companies, financial institutions, development partners and organizations interested in exploring these issues further.

Through my work with the Integrated Refugee Organization (IRO), I am particularly interested in connecting policy research with practical approaches to digital inclusion, technology, protection and refugee-led innovation.

I welcome opportunities to discuss the findings, explore partnerships, contribute to policy consultations, or support further research and pilot initiatives related to inclusive AI and digital economic participation.

For policy discussions, research collaboration, speaking engagements or potential partnerships related to this research; please contact me through the Integrated Refugee Organization.

About the author

Donatien Niyongendako is a Burundian human rights defender and technology practitioner living in exile in Uganda. He is the Founder and Executive Director of the Integrated Refugee Organization (IRO), a civil society organization advancing digital resilience, protection and socio-economic inclusion for refugees, journalists and human rights defenders across Africa and beyond.

Download the full policy paper

AI Made in Africa: Removing Policy Barriers for Refugee-Led SMEs in East Africa and the Great Lakes Region

By Donatien Niyongendako | August 2026

[Download the full policy paper] or via Global Center on AI Governance website: https://www.globalcenter.ai/research/ai-made-in-africa-removing-policy-barriers-for-refugee-led-smes-in-east-africa-and-the-great  and youtube record: https://www.youtube.com/watch?v=xeMjyu_PJx4 

This research was published under the AI Made in Africa initiative, a joint partnership between GIZ and the African Observatory on Responsible AI, a flagship project of the Global Center on AI Governance.