AI, Apps, And Algorithms: The Law Commission's Plan To Overhaul Product Liability

On October 8, 2026, the Law Commission published a consultation paper proposing a wholesale reform of the U.K. product liability framework. The reform is partly justified by the fact that the current law, the Consumer Protection Act 1987 (CPA), predates smartphones, apps, social media, and AI. The proposals aim to bring U.K. product liability law into the digital age, extending strict liability to software, data, and AI-driven harms, and imposing liability on a wider range of actors in the digital economy.

The Law Commission has also used the opportunity to tackle perceived hurdles faced by claimants in product liability claims. If implemented, these changes would reach a much broader range of defendants, including producers of medical devices and pharmaceuticals.