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ARTICLE · 03 JUNE 2026

Bots, Borders And Brussels: The EU AI Act And Gibraltar

ISOLAS LLP
ISOLAS LLP
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ISOLAS LLP

ISOLAS LLP

ISOLAS is a leading international law firm with its headquarters in Gibraltar. Established in 1892,...

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The EU's Artificial Intelligence Act came into force in August 2024, establishing a comprehensive regulatory framework for AI systems with extraterritorial reach similar to GDPR. Gibraltar businesses must assess whether their AI operations trigger Market, Use, or Output Jurisdiction under the Act, while navigating existing data protection obligations that already govern AI deployment in the territory.

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In today’s world finding wide spread consensus is rare. One notable exception, however, appears to be the rise and use of artificial intelligence (“AI”). Since the widespread adoption of LLM based AI (such as Chat GPT, Claude or Gemini), and their steady adoption into everyday tools and services, one conclusion is difficult to escape. AI is no longer a future concept, but an established and seemingly permanent feature of modern life.

Against that backdrop, regulatory intervention was inevitable. As AI capabilities have expanded, so too has the need for oversight. Legislators and regulators are now grappling with how best to manage both the risks and opportunities presented by these technologies. Within the European Union, this has culminated in the introduction of the Artificial Intelligence Act, which came into force on 1 August 2024 (the “AI Act”) with most obligations for High Risk AI coming into force on 2 August 2026. The legislation represents the EU’s attempt to create

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