Artificial Intelligence (AI)

AI agents have arrived. Although the technology is not new, agents are rapidly becoming more sophisticated—capable of operating with greater autonomy, executing multi-step tasks, and interacting with other agents in ways that were largely theoretical just a few years ago. Organizations are already deploying agentic AI across software development, workflow automation, customer service, and e-commerce, with more ambitious applications on the horizon. As these systems grow in capability and prevalence, a pressing question has emerged: can existing legal frameworks—generally designed with human decision-makers in mind—be applied coherently to machines that operate with significant independence?

In January 2026, as part of its Tech Futures series, the UK Information Commissioner’s Office (“ICO”) published a report setting out its early thinking on the data protection implications of agentic AI. The report explicitly states that it is not intended to constitute “guidance” or “formal regulatory expectations.” Nevertheless, it provides meaningful insight into the ICO’s emerging view of agentic AI and its approach to applying data protection obligations to this context—insight that may foreshadow the regulator’s direction of travel.

The full report is lengthy and worth the read. This blog focuses on the data protection and privacy risks identified by the ICO, with the aim of helping product and legal teams anticipate potential regulatory issues early in the development process.Continue Reading ICO Shares Early Views on Agentic AI & Data Protection

On December 16, 2025, the U.S. National Institute of Standards and Technology (“NIST”) published a preliminary draft of the Cybersecurity Framework Profile for Artificial Intelligence (“Cyber AI Profile” or “Profile”).  According to the draft, the Cyber AI Profile is intended to “provide guidelines for managing cybersecurity risk related to AI…

Continue Reading NIST Publishes Preliminary Draft of Cybersecurity Framework Profile for Artificial Intelligence for Public Comment

The European Commission (“Commission”) recently launched two stakeholder consultations under the EU AI Act. The first (see here), closing on 9 January 2026, relates to the copyright-related obligations for General Purpose AI (“GPAI”) providers under the AI Act and GPAI Code of Practice. The second (see here)…

Continue Reading European Commission Launches Consultations on the EU AI Act’s Copyright Provisions and AI Regulatory Sandboxes

In December 2025, the Spanish Agency for the Supervision of Artificial Intelligence (AESIA) published a set of detailed guidance documents and templates aimed at helping providers and deployers of high-risk AI systems under the EU AI Act comply with the relevant requirements of the law. All materials are currently available in Spanish only.Continue Reading Spain Issues Guidance Under the EU AI Act

On November 19, 2025, the European Commission (“Commission”) officially presented its Digital Omnibus Package (see here and here). In our previous blog post (see here), we explained that this initiative, which represents a comprehensive update to the EU’s digital regulatory landscape, consisted of two proposed regulations: a “Digital…

Continue Reading Digital Omnibus Package Series: European Commission’s Proposal to Revise the EU’s AI Rules

On 19 November 2025, the European Commission (“Commission”) officially presented its Digital Omnibus Package (see here and here). The initiative represents a comprehensive update to the EU’s digital regulatory landscape, which the Commission frames as a competitiveness and simplification initiative aimed at reducing administrative burdens and enhancing legal certainty for businesses. Although the final text is likely to evolve during negotiations with the European Parliament and the Council of the EU (“Council”), the package, if adopted in its present form, would introduce significant changes to data protection obligations, cookie rules, cybersecurity regulations and the EU AI Act.

The Digital Omnibus Package consists of two proposed regulations: a “Digital Omnibus” that would amend, amongst other legislation, the General Data Protection Regulation (GDPR), ePrivacy Directive, NIS2 Directive and Data Act, and a “Digital Omnibus on AI” that would amend the EU AI Act. We outline below key proposals from the Digital Omnibus that have particular significance for organizations operating in the EU.

A summary of amendments affecting the Data Act and the key proposals in the Digital Omnibus on AI will be addressed in subsequent blog posts.Continue Reading European Commission Proposes Revisions to GDPR and Other Digital Rules Under Digital Omnibus Package

On 8 October 2025, the European Commission published its Apply AI Strategy (the “Strategy”), a comprehensive policy framework aimed at accelerating the adoption and integration of artificial intelligence (“AI”) across strategic industrial sectors and the public sector in the EU.

The Strategy is structured around three pillars: (1) introducing sectoral flagships to boost AI use in key industrial sectors; (2) addressing cross-cutting challenges; and (3) establishing a single governance mechanism to provide sectoral stakeholders a way to participate in AI policymaking.

The Apply AI Strategy is accompanied by the AI in Science Strategy, and it will be complemented by the Data Union Strategy (which is anticipated later this year).Continue Reading European Commission Publishes Apply AI Strategy to Accelerate Sectoral AI Adoption Across the EU

On September 23, 2025, the Italian law on artificial intelligence (hereinafter, “Italian AI Law”) was signed into law, after receiving final approval by the Italian Senate on September 17, 2025. 

The law consists of varied provisions, including general principles and targeted sectoral rules in certain areas not covered by the EU AI Act.  The Italian AI Law will enter into force on October 10, 2025. We provide below an overview of key aspects of the final text of the Italian AI Law.  For full detail, please see our previous blogpost here.Continue Reading Italy Adopts Artificial Intelligence Law

The California Civil Rights Council and the California Privacy Protection Agency have recently passed regulations that impose requirements on employers who use “automated-decision systems” or “automated decisionmaking technology,” respectively, in employment decisions or certain HR processes. On the legislative side, the California Legislature passed SB 7, which would impose…

Continue Reading Navigating California’s New and Emerging AI Employment Regulations