European Commission

On 19 May 2026, the European Commission published its long-awaited draft, non-binding guidelines on the classification of high-risk AI systems (“HRAIs”) under the EU AI Act (the “Guidelines”). Across three documents—covering general principles, high-risk classification in the context of regulated products (Annex I), and high-risk use cases (Annex III)—the Commission sets out its approach to one of the AI Act’s central questions: when does an AI system fall within the high-risk regime (and, just as importantly, when does it not)?

Rather than restating every aspect of the Guidelines, this post highlights a number of interpretative points likely to matter most in practice.

Continue Reading EU AI Act Update: The European Commission Publishes Draft Guidelines on HRAIs

On 7 May 2026, negotiators from the Council of the European Union, the European Parliament, and the European Commission reached a provisional agreement on the terms of the Digital Omnibus on AI, marking the first set of amendments to the EU AI Act since its adoption in June 2024. The final package of amendments reflects a mix of pragmatic timeline extensions, focused simplification measures, and a small number of substantive policy changes.

Continue Reading EU AI Act Update: Timeline Relief, Targeted Simplification, and New Prohibitions

The European Commission has set a clear timeline for rolling out age verification across the EU:

  • by June 30, 2026, Member States are encouraged to submit implementation plans; and
  • by December 31, 2026, at least one EU‑compliant age verification solution should be available in each Member State.

This timeline, set…

Continue Reading EU Sets the Clock on Age Verification: Rollout Urged by End‑2026

On November 12, 2025, the European Commission launched two public consultations that could significantly reshape EU product compliance rules. To participate, stakeholders – including businesses, consumer groups, and industry associations – are invited to complete the Commission’s online questionnaires, available until February 4, 2026.

Continue Reading Help Shape the Future of EU Product Compliance: Participate in the Public Consultations

Digital contracts and subscriptions have significantly increased, with the subscription economy tripling since 2017, according to the European Commission’s Digital Fairness Act Fitness Check. However, the Fitness Check points out that the number of issues with digital subscriptions, such as difficult cancellations, automatic renewals without reminders, and unclear subscription terms, have also increased. The Commission proposes to tackle these issues in its proposed Digital Fairness Act (“DFA”), which recently entered its consultation phase (see our blog post here).

This post briefly highlights certain issues with digital subscriptions identified in the Fitness Check, outlines how these issues are currently regulated in the EU, and considers the Fitness Check’s proposals to address these issues. It is the fourth post in our series on the upcoming DFA – previous posts covered influencer marketing, AI chatbots in consumer interactions, and personalised advertising and pricing.

Continue Reading Digital Fairness Act Series — Topic 4: Digital Subscriptions

On 15 July 2025, the European Commission adopted an adequacy decision for the European Patent Organisation (EPO).  This marks the first time such a decision has been granted to an international organisation.  From now on, personal data can be transferred from the EU to the EPO based on this decision, without the need for additional safeguards such as Standard Contractual Clauses (SCCs).

Continue Reading Adequacy Decision for the European Patent Organisation

On May 13, 2025, the European Commission issued its draft Guidelines on the protection of minors online under the DSA (“the Guidelines”).  The Guidelines aim to support providers of online platforms that are “accessible to minors” with meeting their obligation to ensure “a high level of privacy, safety, and security” for minors under Article 28(1) of the Digital Services Act (“DSA”).

Below we provide an overview of the Guidelines and key takeaways.

Continue Reading European Commission Publishes Draft Guidelines on the Protection of Minors under the DSA

The European Commission (“Commission”) is working on a new EU consumer protection law called the Digital Fairness Act (“DFA”) to better protect consumers in the digital space.  The DFA is expected to regulate, among other things, influencer marketing. 

With EU consumer protection watchdogs starting to bring cases against companies whose products or services are promoted by influencers (see for example here), the DFA’s provisions may apply not only to influencers, but also to companies that deploy or use influencers, to ensure that advertising practices are fair and transparent.  This blog post explores two key issues that the European Commission is expected to prioritize in its approach to influencer marketing.  It also provides a brief overview of the French legal framework in this area, which some expect to serve as a model for the EU’s forthcoming rules in this area.

Continue Reading Digital Fairness Act Series – Topic 1: Influencer Marketing

On March 13, 2025, the Commissioner for Democracy, Justice, the Rule of Law and Consumer Protection, Michael McGrath, confirmed that the Commission is considering simplifying the GDPR with a view to reducing the burden on smaller businesses.  This statement aligns with the Commission’s broader goal of simplifying the EU digital framework.

Continue Reading European Commission Confirms Plans to Simplify GDPR

On October 3, 2024, the European Commission published a report evaluating the effectiveness of existing EU consumer protection laws in protecting consumers in the digital space.  More specifically, the report assesses the effectiveness of the following three consumer protection laws: (i) the Unfair Commercial Practices Directive (“UCPD”); (ii) the Consumer Rights Directive (“CRD”); and (iii) the Unfair Contract Terms Directive (“UCTD”).  It also identifies and analyses the main provisions in the DSA, DMA, Data Act, and AI Act that are of particular relevance for protecting consumers in the digital environment.  The report is the result of the 2022 public consultation we mentioned in our previous blog post.

Continue Reading EU Commission Publishes Report Assessing EU Consumer Laws and Paves Way for New and Stronger EU Consumer Law for the Digital Space