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Lisa Peets

Lisa Peets leads the Technology Regulatory and Policy practice in the London office and is a member of the firm's Management Committee. Lisa divides her time between London and Brussels, and her practice embraces regulatory counsel and legislative advocacy. In this context, she has worked closely with leading multinationals in a number of sectors, including many of the world’s best-known technology companies.

Lisa counsels clients on a range of EU law issues, including data protection and related regimes, copyright, e-commerce and consumer protection, and the rapidly expanding universe of EU rules applicable to existing and emerging technologies. Lisa also routinely advises clients in and outside of the technology sector on trade related matters, including EU trade controls rules.

According to the latest edition of Chambers UK (2022), "Lisa is able to make an incredibly quick legal assessment whereby she perfectly distils the essential matters from the less relevant elements." "Lisa has subject matter expertise but is also able to think like a generalist and prioritise. She brings a strategic lens to matters."

On February 13, 2024, the European Parliament’s Committee on Internal Market and Consumer Protection and its Committee on Civil Liberties, Justice and Home Affairs (the “Parliament Committees”) voted overwhelmingly to adopt the EU’s proposed AI Act. This follows a vote to approve the text earlier this month by the Council of Ministers’ Permanent Representatives Committee (“Coreper“). This brings the Act closer to final; the last step in the legislative process is a vote by the full European Parliament, currently scheduled to take place in April 2024.

The compromise text approved by Coreper and the Parliament Committees includes a number of significant changes as compared to earlier drafts. In this blog post, we set out some key takeaways.Continue Reading EU AI Act: Key Takeaways from the Compromise Text

On January 24, 2024, the European Commission (“Commission”) announced that, following the political agreement reached in December 2023 on the EU AI Act (“AI Act”) (see our previous blog here), the Commission intends to proceed with a package of measures (“AI Innovation Strategy”) to support AI startups and small and medium-size enterprises (“SMEs”) in the EU.

Alongside these measures, the Commission also announced the creation of the European AI Office (“AI Office”), which is due to begin formal operations on February 21, 2024.

This blog post provides a high-level summary of these two announcements, in addition to some takeaways to bear in mind as we draw closer to the adoption of the AI Act.Continue Reading European Commission Announces New Package of AI Measures

From February 17, 2024, the Digital Services Act (“DSA”) will apply to providers of intermediary services (e.g., cloud services, file-sharing services, search engines, social networks and online marketplaces). These entities will be required to comply with a number of obligations, including implementing notice-and-action mechanisms, complying with detailed rules on terms and conditions, and publishing transparency reports on content moderation practices, among others. For more information on the DSA, see our previous blog posts here and here.

As part of its powers conferred under the DSA, the European Commission is empowered to adopt delegated and implementing acts* on certain aspects of implementation and enforcement of the DSA. In 2023, the Commission adopted one delegated act on supervisory fees to be paid by very large online platforms and very large online search engines (“VLOPs” and “VLOSEs” respectively), and one implementing act on procedural matters relating to the Commission’s enforcement powers. The Commission has proposed several other delegated and implementing acts, which we set out below. The consultation period for these draft acts have now passed, and we anticipate that they will be adopted in the coming months.Continue Reading Draft Delegated and Implementing Acts Pursuant to the Digital Services Act

On 15 January 2024, the UK’s Information Commissioner’s Office (“ICO”) announced the launch of a consultation series (“Consultation”) on how elements of data protection law apply to the development and use of generative AI (“GenAI”). For the purposes of the Consultation, GenAI refers to “AI models that can create new content e.g., text, computer code, audio, music, images, and videos”.

As part of the Consultation, the ICO will publish a series of chapters over the coming months outlining their thinking on how the UK GDPR and Part 2 of the Data Protection Act 2018 apply to the development and use of GenAI. The first chapter, published in tandem with the Consultation’s announcement, covers the lawful basis, under UK data protection law, for web scraping of personal data to train GenAI models. Interested stakeholders are invited to provide feedback to the ICO by 1 March 2024.Continue Reading ICO Launches Consultation Series on Generative AI

Recent proposals to amend the UK’s national security investment screening regime mean that investors may in future be required to make mandatory, suspensory, pre-closing filings to the UK Government when seeking to invest in a broader range of companies developing generative artificial intelligence (AI). The UK Government launched a Call for Evidence in November 2023 seeking input from stakeholders on a number of potential amendments to the operation of the National Security and Investment Act (NSIA) regime, including whether generative AI, which the Government states is not currently directly in scope of the AI filing trigger, should expressly fall within the mandatory filing regime. The Call for Evidence closes on 15 January 2024.

This blog sets out how the NSIA regime operates, how investments in companies developing AI are currently caught by the NSIA, and the Government’s proposals to refine the scope of AI activities captured by the regime, including potentially directly encompassing generative AI.Continue Reading UK Government Consults on Amending Mandatory Filing Obligations for AI Acquisitions

On December 9, 2023, the European Parliament, the Council of the European Union and the European Commission reached a political agreement on the EU Artificial Intelligence Act (“AI Act”) (see here for the Parliament’s press statement, here for the Council’s statement, and here for the Commission’s statement). Following three days of intense negotiations, during the fifth “trilogue” discussions amongst the EU institutions, negotiators reached an agreement on key topics, including: (i) the scope of the AI Act; (ii) AI systems classified as “high-risk” under the Act; and (iii) law enforcement exemptions.

As described in our previous blog posts on the AI Act (see here, here, and here), the Act will establish a comprehensive and horizontal law governing the development, import, deployment and use of AI systems in the EU. In this blog post, we provide a high-level summary of the main points EU legislators appear to have agreed upon, based on the press releases linked above and a further Q&A published by the Commission. However, the text of the political agreement is not yet publicly available. Further, although a political agreement has been reached, a number of details remain to be finalized in follow-up technical working meetings over the coming weeks.Continue Reading EU Artificial Intelligence Act: Nearing the Finish Line

On October 30, 2023, days ahead of government leaders convening in the UK for an international AI Safety Summit, the White House issued an Executive Order (“EO”) outlining an expansive strategy to support the development and deployment of safe and secure AI technologies (for further details on the EO, see our blog here). As readers will be aware, the European Commission released its proposed Regulation Laying Down Harmonized Rules on Artificial Intelligence (the EU “AI Act”) in 2021 (see our blog here). EU lawmakers are currently negotiating changes to the Commission text, with hopes of finalizing the text by the end of this year, although many of its obligations would only begin to apply to regulated entities in 2026 or later.

The EO and the AI Act stand as two important developments shaping the future of global AI governance and regulation. This blog post discusses key similarities and differences between the two.Continue Reading From Washington to Brussels: A Comparative Look at the Biden Administration’s Executive Order and the EU’s AI Act

On 13 October 2023, members of the G7 released a set of draft guiding principles (“Principles”) for organisations developing advanced AI systems, including generative AI and foundational models.

In parallel, the European Commission launched a stakeholder survey (“Survey”) on the Principles, inviting any interested parties to comment by 20 October 2023.  After the Survey is complete, G7 members intend to compile a voluntary code of conduct that will provide guidance for AI developers.  The Principles and voluntary code of conduct will complement the legally binding rules that EU co-legislators are currently finalizing under the EU AI Act (for further details on the AI Act, see our blog post here).

The Principles build on the existing OECD AI principles published in May 2019 (see our blog post here) in response to recent developments in advanced AI systems.  They would apply to all participants in the AI value chain, including those responsible for the design, development, deployment, and use of AI systems.Continue Reading G7 Countries Publish Draft Guiding Principles for Advanced AI Development

On September 19, 2023, the UK’s Online Safety Bill (“OSB”) passed the final stages of Parliamentary debate, and will shortly become law. The OSB, which requires online service providers to moderate their services for illegal and harmful content, has been intensely debated since it was first announced in 2020, particularly around the types of online harms within scope and how tech companies should respond to them. The final version is lengthy and complex, and will likely be the subject of continued debate over compliance, enforcement, and whether it succeeds in making the internet safer, while also protecting freedom of expression and privacy.Continue Reading UK Online Safety Bill Passes Parliament

On 31 August 2023, the UK’s House of Commons Innovation and Technology Committee (“Committee”) published an interim report (“Report”) evaluating the UK Government’s AI governance proposals and examining different approaches to the regulation of AI systems. As readers of this blog will be aware, in March 2023, the UK Government published a White Paper setting out its “pro-innovation approach to AI regulation” which will require existing regulators to take responsibility for promoting and overseeing responsible AI within their sectors (for further information on the UK Government’s strategy, see our blog post here).

The Report recommends that the UK Government introduce a “tightly-focused AI Bill” in the next parliamentary session to “position the UK as an AI governance leader”.Continue Reading UK Parliament Publishes Interim Report on the UK’s AI Governance Proposals