Over the past few years, digitalization has emerged as one of the most important areas of state reform in the Republic of Moldova, accelerated by the country’s European integration process, recent crises, and the growing expectations of its citizens. The development of digital public services has aimed to reduce bureaucracy, increase the efficiency of public administration, facilitate access to services, and strengthen the resilience of the state.

This rapid transformation brings undeniable benefits, but it also generates significant risks for human rights. Digitalization is not neutral from this perspective:  the way technologies are designed, implemented, and governed can either strengthen fundamental rights or make them vulnerable.

Based on this reality, People’s Advocate Office, in partnership with the Danish Institute for Human Rights, has developed a study dedicated to analyzing the impact of digitalization on fundamental rights. The study provides an assessment of emerging risks and proposes concrete recommendations to ensure that technology serves the public interest and protects the dignity and rights of every person.

The study also supports decision-makers, public institutions, academia, civil society, the private sector, and international partners by providing a practical prevention tool that allows for the identification and management of human rights risks. This is all the more important as the Republic of Moldova does not currently have a formal mechanism for assessing the impact of digitalization, and the existing measures are fragmented and predominantly reactive; in the absence of a structured framework, systemic risks only become visible after the damage has been done.

The study was based on a mixed methodological design: analysis of the legislative framework and national policies, a multisectoral discussion group organized by the Ombudsman’s Office (March 28, 2025, 17 participants), a questionnaire administered to discussion group participants, and a public online survey ( March-April 2025; 66 complete responses) .

Main human rights-centered findings:

• Fragmentation of the legal framework: The lack of a unified and coherent legislative framework in the field of digital governance generates unequal guarantees and unclear responsibilities between institutions, affecting the predictability and application of fundamental rights, including the right to privacy and effective redress.
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• Affecting the right to privacy and data protection: The expansion of state registers, the exchange of data between institutions and the use of emerging technologies increase the risk of excessive surveillance, unauthorized access to data and disproportionate use of personal information.
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• Automated decisions without sufficient guarantees: Frequent use of artificial intelligence and automated decision-making without clear mechanism of human oversight, transparency and challenge can lead to opaque decisions, systemic errors and discrimination. In May 2025, ChatGPT owned 91.4% of the mobile chatbots market based on artificial intelligence in the Republic of Moldova, followed by Microsoft Copilot and Gemini.
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• Digital exclusion and indirect discrimination: Elderly people, persons with disabilities, linguistic minorities and rural communities risk being excluded from equal access to essential services, unless digitalization is accompanied by measures of accessibility, linguistic parity and equivalent offline alternatives.
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• Freedom of expression and online safety:  The insufficiently developed governance of digital platforms creates risks for freedom of expression, child protection, and combating hate speech without affecting pluralism and democratic debate.
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• Data protection: While progress has been made, enforcement capacity remains insufficient in sensitive sectors such as health, justice, social protection and education.

Key recommendations reflected in the Study:

• Adopt a coherent national vision for digital governance by harmonizing laws, policies, and fragmented strategies within a single regulatory framework. This could ensure greater clarity, coherence and accountability in the way digital reforms are designed and implemented.
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• Ensure inclusion and equality by integrating accessibility standards, multilingual parity and offline equivalence into all digital reforms. Essential services must remain available to everyone, including those who do not have digital access or face language and physical barriers.
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• Place human rights in the center of digital transformation, by introducing human rights and data protection impact assessments as a mandatory element of every major initiative. Integrating safeguard from the design stage can prevent rights violations and build public trust.
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• Strengthen institutional cooperation and accountability by promoting systematic coordination between Parliament, Government, supervisory bodies, local authorities, and civil society. Transparent reporting and open dialogue can ensure democratic control of digitalization processes.
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• Align Moldova’s digital reforms with European and international standards, including the GDPR, NIS2 Directive, AI Act, and Digital Services Act. This alignment would strengthen Moldova’s path towards EU integration while adopting internationally recognized best practices.
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• Invest in capacity building and public awareness so that institutions, businesses, and citizens have the knowledge, skills, and tools to navigate the digital space responsibly and safely. For children, this requires education on digital skills, accountability of online platforms, and capacity building of child protection institutions.

To support public institutions, the study includes in its annex a “Digitalization and human rights” checklist (Annex 1) – a tool that could be used to identify and manage risks throughout the technology lifecycle – and a stakeholder and impact matrix (Annex 2) for prioritizing interventions.

The study does not aim to be exhaustive assessment: the empirical basis has limitations in terms of time and sample size. Based on these limitations, the report recommends launching a comprehensive follow-up assessment program with broader sectoral coverage, extensive consultation, and technical audits for high-risk systems.

Approximately 60 stakeholders attended, including representatives from the Ministry of Economic Development and Digitalization, the Ministry of Internal Affairs, the Ministry of Education and Research, the Ministry of Justice, the Ministry of Labor and Social Protection, the Agency for Cybersecurity, the National Center for Personal Data Protection, the Council for Equality, the Audiovisual Council, the Agency for Digitalization in Justice and Judicial Administration, the General Police Inspectorate, the Information Technology and Cybersecurity Service, as well as civil society organizations (Promo-LEX, Amnesty International Moldova, IMS – International Media Support, Platform for Gender Equality), international organizations and institutions (European Union Delegation to the Republic of Moldova, Embassy of Denmark, UN OHCHR Moldova UNICEF Moldova, UN Women Moldova), the private sector (Moldcell SA) and academia (Moldova State University, Technical University of Moldova, Cybercor Institute, Academy of Economic Studies of Moldova) — demonstrates a shared commitment to this priority.

Present at the event, MR. Andrei Cusca, Head of the Information Technology and Digitalization Policy Department within the Ministry of Economic Development and Digitalization, presented the ministry’s initiatives and achievements in the field of digitization, and subsequently welcomed the launch of the study, noting its relevance in the context of digitization processes.

The Danish Institute’s senior advisor on human rights, business, and technology, praised the comprehensive and inclusive nature of the study’s development process, which involved a variety of relevant actors in the field of digitalization in the Republic of Moldova, expressing hope that this initiative will contribute to promoting digitalization based on respect for human rights at the national level.

“Digitization is not only an opportunity to modernize public services, but also a major responsibility: the way we adopt and govern digital technologies will determine whether the fundamental rights of every citizen are protected or exposed to risks.” – Ceslav Panico, Ombudsman.

In this regard, the study reinforces the position of the Ombudsman’s Office as a key player in risk prevention and the protection of fundamental rights in the era of artificial intelligence, in full compliance with emerging European standards and the Republic of Moldova’s international obligations in the field of human rights.

Following the launch of the Study, the People’s Advocate Office, in partnership with the Danish Institute for Human Rights, intends to initiate several measures aimed at strengthening the human rights-based approach in digitalization processes. These include the establishment of a Working Group or an intersectoral Council that can provide expertise in identifying areas of intervention and public policies that need improvement. At the same time, the Ombudsman aims to develop education and information platforms designed to raise awareness of the impact of digitalization on human rights.

Digitalization can be a catalyst for democratic progress only if it is designed and governed with respect for human dignity, equality, and the rule of law. Preventing the risks identified in the study requires a joint effort by public authorities, the private sector, civil society, academia, and international partners.

The elaboration of the study and the organization of the launch event of the study was carried out within the Memorandum of Understanding 2024-2025 between People’s Advocate Office and the Danish Institute for Human Rights.

The full study, including its annexes and the proposed instruments, is publicly available on the official website of the People’s Advocate Office: https://ombudsman.md/evaluation-study-impact-of-digitalization-on-human-rights-in-the-republic-of-moldova-2/