Data Law | UK Regulatory Outlook July 2024

The General Data Protection Regulation ("GDPR") will enter into force 25 May 2018, and will provide new general data protection standards.

The UK's Information Commissioner's Office has completed its supervision of major AI foundation model developers, revealing significant gaps in data protection practices and setting new expectations for legitimate interests assessments, transparency, and special category data handling. The regulator has now turned its attention to agentic AI systems, warning that autonomy is not an excuse for poor compliance and launching a call for evidence that will shape future regulatory guidance.

The European Data Protection Board has published draft guidelines proposing a fundamental shift in GDPR enforcement: a presumption that fines should be imposed for non-minor infringements, with a deliberately low bar for establishing negligence. Organizations will need to demonstrate robust compliance programs and documented decision-making to potentially avoid penalties, as regulators move from asking "should we fine?" to "can we justify not fining?"

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The UK Information Commissioner's Office has finalized its guidance on storage and access technologies, expanding compliance requirements beyond traditional cookies to include tracking pixels, device fingerprinting, and web storage. Organizations must now navigate stricter consent standards and three new narrow exceptions introduced by the Data (Use and Access) Act 2025, while facing significantly increased enforcement penalties of up to £17.5 million or 4% of annual worldwide turnover.

On 30 September 2026, the Information Commissioner's Office formally becomes the Information Commission. It is the most significant structural change to the UK's data protection regulator in its history, and yet, many organisations are wondering what practical implications this change will have. Here's what you need to know.

From 2 August 2026, the EU AI Act requires businesses to disclose when people are interacting with AI systems, mark synthetic content for detection, label deepfakes, and inform individuals...

The Data (Use and Access) Act 2025 (the DUAA) officially became law in June 2025, with a phased enforcement model under which different provisions take effect at different times.

Domestic surveillance technology has evolved from simple security cameras to sophisticated smart systems that may inadvertently create legal obligations for homeowners. When does a Ring doorbell or CCTV system transform an ordinary citizen into a data controller subject to UK GDPR, and what are the implications of millions of private cameras forming an unregulated surveillance network?

The European Commission has announced that EU AI Act transparency rules take effect August 2, 2026, requiring chatbots to identify themselves, deepfakes to be labeled, and AI-generated content to be marked. Organizations must assess whether their AI systems trigger disclosure, labeling, or content-marking requirements, with limited exceptions and penalties reaching €15 million or 3% of global turnover for noncompliance.

Who are online marketplace providers and what should they be aware of before the new regulation becomes applicable later this year?

The Court of Justice of the European Union (CJEU) has clarified that a supplier must actively agree with its other distributors that a territory is exclusively reserved if it wants to appoint exclusively a distributor for that territory.

A draft bill promotes minors' positive use of digital environments in areas such as education or social interaction

The Alternative Investment Fund Managers Directive (AIFMD II) was published in November 2023 and one area of evolution is an increased emphasis on open-ended alternative...

The Belgian federal government is looking to implement a new tax on capital gains realised on financial assets that is due to enter into force on 1 January 2026.

National Grid has announced that 203 clean energy projects, with a combined capacity of 7.8GW, have had their connection offer dates brought forward by up to 10 years. The new connection dates were secured...

AI offers many opportunities to businesses, though there are specific risks to be managed in relation to its use in the workplace...

When the Civil Procedure Rule provisions on contempt were entirely replaced in 2020 by a simplified and reduced rule (Part 81), one of the changes was the removal...

Both employers and employees are increasingly using AI, but there are particular risks to manage in an international HR context...

Up until the introduction of MiCAR, the offering of crypto-assets in Spain was mainly unregulated. The CNMV issued warnings to investors about the risks associated with unregulated crypto-assets offering.