On May 27, the Connecticut governor signed into law a comprehensive artificial intelligence (“AI”) bill that regulates safety, transparency, and consumer protection, including subscription marketing (“SB 5”). Alongside key provisions on Employee Reporting Protections, AI Companions, and Automated Employment-Related Decision Technology (discussed in more detail here), SB 5 also sets…

Continue Reading Connecticut Extends AI Regulation to Subscriptions

The Office of Management and Budget (“OMB”) has released its 2026 Unified Agenda, which identifies regulatory actions that federal agencies expect to propose or finalize during the remainder of the year.  Below, we highlight several notable health privacy, interoperability, and data exchange rules that the Department of Health and Human Services (“HHS”) has listed for proposed or final action in 2026.  The descriptions and target dates below reflect only the agency’s stated intentions and are subject to change.

Continue Reading OMB Publishes 2026 Unified Agenda Signaling Upcoming Health Privacy and Interoperability Updates from HHS

On July 10, 2026, New York City Mayor Zohran Mamdani and Department of Consumer and Worker Protection (“DCWP”) Commissioner Samuel Levine announced the adoption of a new “Click to Cancel” rule governing how businesses disclose, bill, and cancel subscriptions. The rule takes effect October 1, 2026.

Continue Reading New York City Adopts ‘Click to Cancel’ Rule

On July 9, 2026, the Court of Justice of the European Union (“CJEU” or “Court”) delivered its judgment in Sky Österreich Fernsehen (C-234/25), deciding that a streaming offering constitutes a digital service under the Consumer Rights Directive (Directive 2011/83/EU), rather than digital content, where the trader’s offering is of a dynamic nature and goes beyond the stable or continuous provision of specific content. As a result, providers of such streaming offerings cannot rely on the Consumer Rights Directive’s exception to the right of withdrawal for digital content.

The judgment has broad implications for providers of personalised digital services, as it affects whether consumers can cancel a subscription during the 14-day withdrawal period and, if they do, how much providers may charge for use of the service during that period.

Continue Reading CJEU Decides When Streaming Subscriptions Are Subject to the Right of Withdrawal

On July 16, 2026, the Court of Justice of the European Union (“CJEU”) issued a decision clarifying that EU law does not, as a rule, prevent a national competition authority from seizing business emails stored on a company’s systems without prior authorisation from a court. However, strict legal safeguards and effective ex post judicial review must be implemented.

This blog post provides an overview of the decision.

Continue Reading CJEU Clarifies the Conditions for Seizure of Business Emails During Competition Inspections

On 3 June 2026, the European Commission published several legislative and policy measures wrapped up in one “tech sovereignty” package (see our posts summarising the package as a whole here, and diving deeper into the Cloud and AI Development Act here). But the EU’s tech sovereignty drive has a long history, and is by no means limited to this package.

In this post, we take a closer look at the current and forthcoming EU legislative measures aimed at increasing the resilience of services provided in the EU against external, malicious influence, a key aspect of tech sovereignty. Relevant legislation falls into two broad categories: (1) laws promoting cyber resilience generally, to prevent malicious actors from disrupting services and critical infrastructure; and (2) laws focused on building supply chain resilience and reducing dependencies on certain external actors by building European industrial capacity in key tech sectors.

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Continue Reading Looking beyond the tech sovereignty package: how the EU is moving to ensure tech sector resilience

On July 2, 2026, the Federal Trade Commission (“FTC”) announced that Hopper (USA), Inc. and its Canadian parent, Hopper Inc., agreed to a $35 million settlement resolving allegations that Hopper engaged in unfair and deceptive fee practices in violation of Section 5 of the FTC Act and the Trade Regulation…

Continue Reading FTC Settles with Hopper Over Hidden Fee Practices

On June 16, 2026, the Delaware General Assembly passed HB 380, which would amend the Delaware Personal Data Privacy Act (DPDPA). The bill is currently awaiting the Delaware governor’s signature, and if signed, the amendments would take effect on January 1, 2027. The amendment would impose the following:

Continue Reading Delaware General Assembly Passes HB 380, an Amendment to the Delaware Personal Data Privacy Act

On July 7, 2026, the Irish National Cyber Security Centre (“NCSC”) published guidance for management boards and senior executives of organizations subject to the EU’s Network and Information Security Directive (“NIS2”). Reflecting a central theme of NIS2, the Guidance makes it clear that cybersecurity is no longer solely a technical issue, but a governance and risk-management matter that requires active oversight at “the highest levels of executive management.”  It is a helpful document for organizations that are likely to be subject to NIS2, expect to be supervised in Ireland, and that are considering their governance structures and board-level oversight mechanisms.

Continue Reading Irish NCSC Issues Cyber Governance Guidance for Management Boards Ahead of NIS2 Implementation

On July 1, 2026, the Federal Trade Commission (“FTC”) issued a proposed policy statement addressing what it describes as the “suppression of accuracy” in artificial intelligence (“AI”) systems and is seeking public comment through July 31, 2026. The proposal was issued pursuant to Executive Order 14365, Ensuring a National Policy Framework for Artificial Intelligence, which directed the FTC to explain how Section 5 of the FTC Act applies when AI developers alter model outputs in response to state law requirements.[1]

Continue Reading FTC Seeks Comment on Proposed Policy Statement Addressing AI Accuracy and Output Steering