Artificial Intelligence Annual Review 2025

Welcome to our Artificial Intelligence Annual Review for 2025. It was a pivotal year for organisations tracking the rapidly evolving EU AI regulatory landscape.

Guidelines and codes published

2025 also saw a wave of EU guidance, including:

• Prohibited AI practices guidelines
• Guidelines on the definition of AI systems
• AI literacy FAQs
• Guidance on obligations for providers of general-purpose AI models
• The General-Purpose AI Code of Practice
• Draft serious incidents guidance

What to expect in 2026

We anticipate further uncertainty in 2026 following the publication of the draft Digital Omnibus package, which may affect compliance planning, particularly the timing of high-risk AI requirements and the future of the AI literacy obligation for providers and deployers.

Separately, with the AI Office’s enforcement powers coming into effect in August, we expect increased supervisory activity, including requests for information and potentially more formal investigations.

What’s covered in the Annual Review

In this edition, we focus on:

• Prohibited AI practices guidelines and what they mean for providers
• The AI systems definition guidelines
• Key takeaways from the AI literacy FAQs
• The practical implications of signing up to the General-Purpose AI Code of Practice
• What you need to know about the EU Commission’s General-Purpose AI model guidelines
• Draft serious AI incidents guidance
• Key learnings from the draft Digital Omnibus package
• What we expect in the year ahead

Download now

Our 2025 Annual Review is available as a PDF and is designed for easy internal sharing across legal, regulatory, technology and commercial teams.

For more information and expert advice, contact a member our of Artificial Intelligence team.

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The content of this Annual Review is provided for information purposes only and does not constitute legal or other advice.