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)?
Continue Reading EU AI Act Update: The European Commission Publishes Draft Guidelines on HRAIs
EU AI Act Update: Timeline Relief, Targeted Simplification, and New Prohibitions
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
Continue Reading EU AI Act Update: Timeline Relief, Targeted Simplification, and New Prohibitions10 Takeaways: European Commission Draft Guidelines on AI Transparency under the EU AI Act
On May 8, 2026, the European Commission (“Commission”) published draft guidelines (“Guidelines”) on the implementation of the transparency obligations under Article 50 of the EU Artificial Intelligence Act (“AI Act”), opening a targeted consultation that runs until June 3, 2026.
The Guidelines are non-binding, but they are the first Commission instrument to provide interpretive guidance across the full scope of Article 50. They were prepared in parallel with the related, but more narrowly scoped, Code of Practice on Transparency of AI-Generated Content (“Code of Practice” or “Code”), the second draft of which was published on March 5, 2026.
Continue Reading 10 Takeaways: European Commission Draft Guidelines on AI Transparency under the EU AI ActEuropean Commission Launches Consultations on the EU AI Act’s Copyright Provisions and AI Regulatory Sandboxes
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), closing on 6 January 2026
Continue Reading European Commission Launches Consultations on the EU AI Act’s Copyright Provisions and AI Regulatory SandboxesThe Future of the AI Liability Directive
The European Commission first published a proposal for an AI Liability Directive (“AILD”) in September 2022 as part of a broader set of initiatives, including proposals for a new Product Liability Directive (“new PLD”) and the EU AI Act (see our blog posts here, here and here).
The AILD was intended to introduce uniform rules for certain aspects of non-contractual civil claims relating to AI, by introducing disclosure requirements and rebuttable presumptions.
However, unlike the new PLD and EU AI Act, which have both been adopted and have entered into force, the AILD has encountered stagnation and resistance during the legislative process.
Continue Reading The Future of the AI Liability DirectiveIntroduction of the Revised Code of Conduct+ and the Digital Services Act
The Commission and the European Board for Digital Services have announced the integration of the revised voluntary Code of conduct on countering illegal hate speech online + (“Code of Conduct+”) into the framework of the Digital Services Act (“DSA”). Article 45 of the DSA states that, where significant systemic risks emerge under Article 34(1) (concerning the obligation on very large online platforms (“VLOPs”) and very large online search engines (“VLOSEs”) to identify, analyse, and assess systemic risks), and concern several VLOPs or VLOSEs, the Commission may invite VLOPs and VLOSEs to participate in the drawing up of codes of conduct, including commitments to take risk mitigation measures and to report on those measures and their outcomes. The Code of Conduct+ was adopted in this context. VLOPs and VLOSEs’ adherence to the Code of Conduct+ may be considered as a risk mitigation measure under Article 35 DSA, but participation in and implementation of the Code of Conduct+ “should not in itself presume compliance with [the DSA]” (Recital 104).
The Code of Conduct+—which builds on the Commission’s original Code of Conduct on countering illegal hate speech online, published in 2016—seeks to strengthen how Signatories address content defined by EU and national laws as illegal hate speech. Adhering to the Code of Conduct+’s commitments will be part of the annual independent audit of VLOPs and VLOSEs required by the DSA (Art. 37(1)(b)), but smaller companies are free to sign up to the Code as well.
Continue Reading Introduction of the Revised Code of Conduct+ and the Digital Services ActUK Government Proposes Copyright & AI Reform
In case you missed it before the holidays: on 17 December 2024, the UK Government published a consultation on “Copyright and Artificial Intelligence” in which it examines proposals to change the UK’s copyright framework in light of the growth of the artificial intelligence (“AI”) sector.
The Government sets out the following core objectives for a new copyright and AI framework:
- Support right holders’ control of their content and, specifically, their ability to be remunerated when AI developers use that content, such as via licensing regimes;
- Support the development of world-leading AI models in the UK, including by facilitating AI developers’ ability to access and use large volumes of online content to train their models; and
- Promote greater trust between the creative and AI sectors (and among consumers) by introducing transparency requirements on AI developers about the works they are using to train AI models, and potentially requiring AI-generated outputs to be labelled.
In this post, we consider some of the most noteworthy aspects of the Government’s proposal.
Continue Reading UK Government Proposes Copyright & AI ReformICO Audit on AI Recruitment Tools
On November 6, 2024, the UK Information Commissioner’s Office (ICO) released its AI Tools in recruitment audit outcomes report (“Report”). This Report documents the ICO’s findings from a series of consensual audit engagements conducted with AI tool developers and providers. The goal of this process was to assess compliance with data protection law, identify any risks or room for improvement, and provide recommendations for AI providers and recruiters. The audits ran across sourcing, screening, and selection processes in recruitment, but did not include AI tools used to process biometric data, or generative AI. This work follows the publication of the Responsible AI in Recruitment guide by the Department for Science, Innovation, and Technology (DSIT) in March 2024.
Continue Reading ICO Audit on AI Recruitment ToolsEDPB adopts draft guidelines on requirements when responding to requests from non-EU public authorities
On 2 December 2024, the European Data Protection Board (“EDPB”) adopted its draft guidelines on Article 48 GDPR (the “Draft Guidelines”). The Draft Guidelines are intended to provide guidance on the GDPR requirements applicable to private companies in the EU that receive requests or binding demands for personal data from public
Continue Reading EDPB adopts draft guidelines on requirements when responding to requests from non-EU public authoritiesEuropean Commission Adopts Implementing Regulation on DSA Transparency Reporting Obligations
On November 4, 2024, the European Commission (“Commission”) adopted the implementing regulation on transparency reporting under the Digital Services Act (“DSA”). The implementing regulation is intended to harmonise the format and reporting time periods of the transparency reports required by the DSA.
Transparency reporting is required under Articles 15, 24 and
Continue Reading European Commission Adopts Implementing Regulation on DSA Transparency Reporting Obligations