SENEGAL Law and Practice Contributed by: Khaled Abou El Houda, Malick Lo, Chadi Safieddine and Mohamed Kamil, SCP Houda & Associés
7. Environmental, Social and Governance 7.1 ESG Requirements
8. Artificial Intelligence 8.1 Board Oversight of AI
As of today, Senegalese law does not contain specific legal or regulatory requirements relating to board over - sight of artificial intelligence. There are no mandatory rules on AI-specific board composition, AI committee mandates, AI-related risk frameworks or AI controls. In the absence of an AI-specific regime, board over - sight of AI-related activities is governed by the general provisions of the AUSCGIE on board duties and by sector-specific frameworks. Directors remain bound by their general duty to identify and supervise material risks affecting the company, which, in practice, may include AI-related risks when AI systems are deployed at scale. 8.2 AI Use-Related Risks There is currently no cross-sectoral AI governance framework in Senegal. Companies operating in Sen - egal generally rely on internal policies, contractual safeguards and sector-specific regulations to address AI-use-related risks. 8.3 Liability Exposures Arising From AI Use In the absence of a dedicated AI liability regime in Sen - egal, liability exposures for boards and officers arising from AI use are governed by the general framework applicable to directors’ and officers’ duties, combined with sector-specific rules. 8.4 Key Disclosure Requirements for AI Use Senegalese law does not currently impose specific disclosure requirements on companies with regard to AI use, strategy, governance, risks, incidents or controls. There is no dedicated reporting framework for AI in annual reports, sustainability reports or pro - spectuses.
There are no regulations on ESG issues in OHADA law. These provisions will, for example, be set by the board of directors or by internal regulations on a case-by- case basis for companies that can draw on interna - tional regulations in this area. In specific sectors such as extractive industries, the most recent legislation imposes transparency obliga - tions with regard to revenues paid to the state. 7.2 ESG Developments Senegalese legislators have not yet adopted a cross- sectoral ESG reporting obligation. Sector-Specific Transparency Reinforcement In the extractive industries, the reform of the Beneficial Ownership Register through Decree No 2025-1354 of 27 August 2025 consecrates free public access to certain key data on beneficial owners, in line with EITI Law No 2022-08 of 19 April 2022 on the parapublic sector introduces a modern governance framework for state-owned enterprises and entities benefiting from public financial support. The law imposes inde - pendent directors, mandatory audit and remunera - tion committees and a Corporate Governance Code applicable to all parapublic entities. While not framed as ESG legislation, this strengthens the governance component applicable to entities that represent a sig - nificant share of the Senegalese economy. Standard 2023 requirements. Parapublic Sector Governance
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