EU AI Act Transparency Obligations: Preparing for Compliance by 2 August 2026
From 2 August 2026, organisations will become subject to the transparency obligations set out in Article 50 of the EU AI Act (Regulation (EU) 2024/1689).
Article 50 introduces transparency requirements for providers and deployers in relation to certain AI system functionalities and use cases that may create transparency risks for individuals. Whilst much of the EU AI Act focusses on obligations on high-risk AI systems, Article 50 obligations may also apply to certain limited-risk systems. As a result, many organisations will need to implement governance, disclosure and content-labelling measures to ensure users are appropriately informed about the use of certain AI systems and AI-generated content.
EU Lawmakers Reach Provisional Agreement to Delay Key EU AI Act Obligations
On 7 May 2026, following extensive negotiations, the European Council and European Parliament reached a provisional agreement on the EU Digital Omnibus on AI (AI Omnibus) which proposes targeted amendments to the EU Artificial Intelligence Act (AI Act). On 16 June 2026, the European Parliament voted to adopt the provisional agreement — although, formal adoption remains subject to European Council approval.
Cyber Strategy at the AI Frontier: President Trump Releases Executive Order to Promote Advanced Artificial Intelligence Innovation and Security
On June 2, 2026, President Trump issued the Executive Order, Promoting Advanced Artificial Intelligence Innovation and Security. The Executive Order carries forward several priorities included in President Trump’s Cyber Strategy for America, released in March 2026.[1] The Executive Order declares, “It is the policy of the United States to promote AI innovation and security by working collaboratively with the private sector to modernize government and private sector information systems and harden them against external threats; to protect American ingenuity and intellectual property from exploitation and theft by adversaries; and to cultivate America’s advanced AI-enabled capabilities.” (more…)
New York Department of Financial Services Issues Coordinated Guidance on Frontier AI Cybersecurity Risks
On May 21, 2026, the New York State Department of Financial Services (“DFS”) issued two coordinated Industry Letters: a letter on Heightened Cybersecurity Risks Associated with Frontier AI Models (the “AI Advisory”) and accompanying Guidance on Measures Regulated Entities Should Consider in a Heightened Cybersecurity Threat Environment (the “Guidance,” and together, the “May 2026 Publications”). The AI Advisory builds on DFS’s October 2024 guidance on cybersecurity risks arising from AI, but is narrower in focus. Specifically, it addresses frontier models that may materially increase the speed and effectiveness of vulnerability discovery and exploitation.
Chambers 2026 Global Practice Guide for Artificial Intelligence
The Chambers 2026 Global Practice Guide for Artificial Intelligence provides the latest legal information on the rapidly evolving AI landscape, covering the commercial use of AI across key industries, AI-specific legislation and regulation, government and regulatory oversight, generative AI, agentic AI systems and autonomous decision-making, liability, procurement and supply chain accountability, employment, IP, data protection, antitrust, cybersecurity, ESG, and AI governance and compliance.
European Biotech Act I: Navigating the EDPB/EDPS Vision for the Future of Clinical Trials
On 12 March 2026, the European Data Protection Board (“EDPB”) and the European Data Protection Supervisor (“EDPS”) issued a Joint Opinion (the “Joint Opinion”) on the proposed European Biotech Act I (the “Biotech Act”). The Joint Opinion broadly supports the EU’s ambition to strengthen its biotechnology sector. However, it emphasises that data protection safeguards must be tightened, particularly where health data is involved. The recommendations signal forthcoming scrutiny during the legislative process and highlight key compliance considerations for organisations involved in clinical trials.
Chambers 2026 Global Practice Guide for Cybersecurity
The Chambers Global Practice Guide for Cybersecurity 2026 has been published. The guide provides the latest legal information on cybersecurity law and regulation, including in relation to critical infrastructure, financial sector operation resilience, cyber-resilience, and ICT certification. The guide also covers the intersection of cybersecurity with data protection law, developments in AI and healthcare regulation.
Regulatory Update: National Association of Insurance Commissioners Spring 2026 National Meeting
The National Association of Insurance Commissioners (NAIC) held its Spring 2026 National Meeting (Spring Meeting) March 22–25, 2026. This blog post summarizes the highlights from this meeting in addition to interim meetings held in lieu of taking place during the Spring Meeting. Highlights include progress on addressing regulatory concerns related to indexed annuity illustrations, establishment of a new working group on market conduct modernization, exposure of a risk-based capital (RBC) adjustment framework for collateral loans, a Securities Valuation Office (SVO) report on resource strain caused by increased Private Letter Rating filings, multiple revisions to statements of statutory accounting principles (including guidance on sale-leasebacks, repurchase agreements and residential mortgage loans held in statutory trusts, and proposed disclosures for funding agreement-backed financing programs), and updates on the pilot phase of the AI Systems Evaluation Tool.
Generative AI in Discovery: Protective Orders as an Emerging Point of Dispute
As courts have begun addressing generative AI in the privilege and work product context, they are also confronting related disputes in the context of protective orders. Recent decisions Morgan v. V2X, Inc. and Jeffries v. Harcros Chemicals, Inc. show that disagreements about how protective orders should address the use of AI in discovery — issues previously handled through negotiation — now will be informed by guidance from the courts.
There’s a New Sheriff in Town — Texas as Privacy Regulator
For many years, the privacy community took the position that the state of California was the leading data privacy regulator. The state of New York, with its active cyber enforcement by the New York Department of Financial Services, was a close second. However, in the past two years, Texas has emerged not only as a significant privacy regulator but also as an aggressive enforcer of its laws.
