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ARTICLE · 27 JANUARY 2026

The Future Of Agentic AI And Its Data Protection Implications: The UK ICO's Initial Assessment

A&O Shearman
A&O Shearman
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A&O Shearman

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As the democratisation of AI continues apace, organisational deployment of AI agents is rapidly becoming a reality.

United KingdomTechnology
Steve Wood
Steve Wood
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Agentic AI heads towards the mainstream

As the democratisation of AI continues apace, organisational deployment of AI agents is rapidly becoming a reality. To take one example, in September last year OpenAI announced the launch of Instant Checkout and the Agentic Commerce Protocol, (developed with Stripe), which will enable integration for AI chat engagement and purchasing within a single application. This is an early development in what we expect will define future paradigms of AI shopping experiences, and AI agents will have similarly transformative effects in many other sectors.

Agentic AI will pose challenges across many legal spheres, including liability, IP and contractual law. In addition, it will be key to address questions about data protection when looking to mitigate risks to individuals, and to enable responsible innovation and benefits the technology will offer. A&O Shearman is advising many of the world's largest businesses on the pioneering

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