Less noise, more accountability
Data protection and AI regulation continue to evolve, but the tone for 2026 is not about dramatic new rules. We’re gunning for clarity and less rigidness.
UK developments
Early 2026 is expected to see the main reforms under Part 5 of the Data (Use and Access) Act 2025 come into force. These changes adjust the UK GDPR rather than replace it.
They include new “recognised legitimate interests” to make it easier to rely on legitimate interests in certain scenarios, a modest relaxation of the strict rules on automated decision-making, an expansion of the soft opt-in for charities, and new exceptions around cookies and similar tracking technologies.
Later in the year, the focus shifts from legal bases to process. Those business’s responsible for determining the why and how of handling personal data (also known as ‘controllers’) will be required to have clear, formal mechanisms for handling data protection complaints. That means giving individuals a clear route to complain, acknowledging complaints within 30 days, and investigating them without undue delay.
This is not just about updating a privacy notice. Organisations will need to be clear internally on who owns complaints, how they are triaged, how outcomes are recorded, and how decisions are justified if challenged.
Alongside this and a couple of other updated guidance notes expected to come through this year, the ICO will formally transition into the Information Commission, with a new strategic plan and a revised approach to enforcement. The direction of travel is away from box-ticking compliance and toward whether organisations can demonstrate responsible data use in practice.
EU developments
At EU level, the European Commission published its Digital Omnibus package at the end of 2025. While the proposals are not law yet, they matter.
The Omnibus is an attempt to reduce friction between the GDPR, the AI Act and other digital legislation, simplify overlapping obligations, and ensure that AI development is not unintentionally hampered by conflicting rules.
The EU AI Act, adopted in 2024, remains central. Its requirements phase in between 2025 and 2027 and will have wide extraterritorial impact. For UK businesses operating into the EU, the interaction between AI regulation, data protection and contractual risk allocation will only become more important.
For many businesses, 2026 is the right year to get confident on how to use data and AI. We can help to make sense of it all one step at a time because lets be honest, it’s certainly overwhelming and your business cannot afford to get left behind.