Comoros
AI behavior law: bot and agent disclosure, crawler and training-data rules, automated-agent transactions, and algorithmic decision-making.
Summary
The Union of Comoros enacted two digital laws on the same day in June 2021: Law No. 21-012/AU of June 29, 2021 on the Protection of Personal Data (the DPA), and Law No. 21-012 of June 25, 2021 on Cyber Security and the Fight against Cybercrime (the cybercrime law, promulgated by Decree No. 22-003/PR). The Penal Code (Chapter IV, Arts. 449-505) addresses cybercriminality and supplements the 2021 cybercrime law. The cybercrime law designates ANADEN (Agence Nationale pour le Développement du Numérique) cybersecurity department as competent authority under Article 6. The National Authority for the Protection of Personal Data (established by the DPA) had not been formally constituted or made operational as of mid-2024, severely limiting DPA enforcement. No specific scraping statute, no TDM exception, no sui generis database right. Primary sources in French. Confidence raised to medium: the two 2021 laws are well-documented across multiple secondary sources (Tech Hive Advisory, DataProtection.africa, Internews/ARISA) with consistent law numbers; the main residual gap is the unenforced DPA (regulator not yet constituted).
Automated-access legality
Carried forward from the crawler-law index. Governs whether automated clients may access public websites in this jurisdiction.
| Dimension | Value |
|---|---|
| Authorization test | unsettled |
| Public-page carve-out | unsettled |
| Terms-of-service browsewrap enforceable | unsettled |
| Terms-of-service clickwrap enforceable | unsettled |
| Copyright exception model | closed list |
| Text and data mining — commercial status | unsettled |
| Text and data mining — opt-out mechanism | none |
| robots.txt legal weight | non binding notice |
| AI training-specific law | none |
| Privacy regime | Personal Data Protection Law 21-012/AU of June 29, 2021 (National Authority not yet constituted as of mid-2024) |
| Trespass to chattels | not recognized |
Last reviewed: 2026-05-24. Confidence: medium. Not legal advice.