ICOUK GDPR and the Data Protection Act 2018, as amended by the Data (Use and Access) Act 2025
What it means for AI design
Know your lawful basis, keep personal data out of prompts and logs that don't need it, and run a DPIA before high-risk processing. Since 5 February 2026, decisions made solely by automation that significantly affect people need safeguards: telling them, letting them make representations and contest the decision, and a route to a person. The strict limit now applies mainly where special category data is involved. Since 19 June 2026 people must also be able to complain easily about how their data is used: acknowledge each complaint within 30 days and respond without undue delay, and make sure any chat or voice agent routes such complaints to a person.
Source →ICOGuidance on AI and data protection, and the coming code of practice on AI and automated decisions
What it means for AI design
Build fairness testing, accuracy checks and plain-English explanations in from the start, and keep the records the ICO would ask to see. Regulations in force since 12 May 2026 (SI 2026/425) require the ICO to write a statutory code on AI and automated decisions, so design for meaningful human review now rather than retrofitting it.
Source →ICOPECR, as amended by the Data (Use and Access) Act 2025
What it means for AI design
Marketing written or personalised by AI still needs consent, or the soft opt-in, before it goes by email, text or phone. Keep service messages free of offers. The Act raised PECR fines to UK GDPR levels.
Source →NCSC and DCMSGuidelines for secure AI system development (2023) and the AI Cyber Security Code of Practice (January 2025)
What it means for AI design
Threat-model the AI like any other system, including prompt injection, poisoned data and the model supply chain. Give every agent tool the least privilege it needs, log every action, and plan how models and data are retired securely.
Source →EHRCEquality Act 2010, and the Public Sector Equality Duty (section 149)
What it means for AI design
Test outcomes across protected characteristics before go-live and keep monitoring after, including proxies such as postcode or name. Make reasonable adjustments, which usually means there is always a route to a person. Public bodies must also show due regard to equality, usually through an equality impact assessment.
Source →CMAConsumer law and AI agents: the DMCC Act 2024 and "Complying with consumer law when using AI agents" (9 March 2026, updated 30 October 2026)
What it means for AI design
A business is responsible for what its AI agent says and does, as it is for an employee, even when a vendor built the agent. Tell customers when they are dealing with AI, stop the agent misleading or pressuring them, and test and monitor it against consumer law.
Source →European CommissionEU AI Act, for UK organisations serving EU customers
What it means for AI design
It applies when an AI system is placed on the EU market or its output is used in the EU. Transparency duties for chatbots and AI-generated content have applied since 2 August 2026. Under the Digital Omnibus (Regulation (EU) 2026/1744), Annex III high-risk duties, such as credit scoring of individuals, recruitment and life and health insurance pricing, start on 2 December 2027, and Annex I product duties on 2 August 2028.
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