UK AI Bill Loading… Considerations for In-House Counsel

The UK government is planning a comprehensive bill to regulate AI technology and its use of copyrighted material. Initially expected in March 2025, it has now been delayed until at least the next King’s Speech, potentially in May 2026. In this article, Chambers looks at the current legal position and the key issues that in-house counsel could use this extra time to consider. 

In this Article: 

The Current Legal Position 

New UK AI Bill: What Could it Include? 

How to Prepare: Key Action Areas 

An Eye to Other Jurisdictions 

Conclusion & Key Takeaways 

Bingzhen Song, Research Manager (FinTech), Chambers and Partners 

While 2023 catapulted artificial intelligence onto the public agenda, moves towards UK AI regulation have been more sedate. A patchwork of existing legal frameworks currently does the work, including data protection (GDPR), IP and consumer law. Similarly, regulatory oversight is shared between agencies as varied as the Information Commissioner’s Office (ICO) and the Medicines and Healthcare products Regulatory Agency (MHRA). 

This picture was in line with the previous government’s declared ‘pro-innovation approach to AI regulation’, which focused on five broad principles (still applicable today): 

In contrast, the current administration has signalled its intentions for a tighter approach, first hinting at regulation in its AI Opportunities Action Plan. A quick, focused bill was on the cards last year, but was postponed to allow for more complex and far-reaching legislation. 

The Secretary of State for Science, Innovation and Technology is now expected to bring forward a comprehensive new bill on UK AI regulation in the next parliament — which could be as early as May 2026. 

For a detailed look at current law and practice in this area, see our Artificial Intelligence 2025 Global Practice Guide. 

Partner & Head of Data, UK-based international law firm

While there is no draft bill as yet, several key areas could potentially be covered in the proposed legislation, based on policy discourse and government publications on AI. There is also a separate private members’ bill currently in play. While the Artificial Intelligence (Regulation) Bill is not expected to make it to law, it may provide some clues to the key themes on legislators’ minds. 

Large language models that run generative AI applications like ChatGPT and CoPilot may be subject to external scrutiny, particularly those judged high-risk. The government’s previously planned bill would have seen companies required to submit them for evaluation by the AI Security Institute. It remains to be seen whether a similar provision will return in the next iteration. 

While AI models rely on publicly available data to learn and operate, creators and copyright holders are lobbying for stronger protection against infringement, and this has been the subject of parliamentary debate. New UK AI law will have to find a way to balance these competing clams. 

The upcoming bill could introduce formal lifecycle oversight for high-risk AI systems. Both the alternative draft bill and thinktank policy proposals suggest regulators could be empowered to require safety testing before deployment. They might also intervene after launch to modify or withdraw systems that pose unacceptable risks. This would mark a shift from voluntary principles to enforceable oversight, with implications for product timelines and liability exposure. 

In a parallel with data protection law, companies could be required to appoint designated AI officers to oversee compliance and ethical governance. The current private members’ bill proposes embedding this role into Companies Act reporting, alongside a programme of long-term public engagement to shape future regulation. While speculative, these proposals reflect growing pressure for internal accountability and democratic input into AI oversight. 

Senior Executive, Global Hedge Fund

With the upcoming UK AI bill delayed until at least 2026, general counsel and their legal teams have a rare window to get ahead. To help prepare for alignment and mitigate future risk, it may be useful to consider your current and planned AI deployment in light of the following: 

Intellectual Property Lawyer, European Law Firm 

UK AI law is clearly not the only game in town. The EU AI Act, passed in June 2025, introduces tiered risk categories and strict obligations for high-risk systems, including biometric surveillance and critical infrastructure. Italy recently became the first member state to enshrine the law within national statute. Rollout across the bloc will continue through 2025 and 2026. 

Meanwhile, the US is taking a more decentralised approach, with sectoral regulators and voluntary commitments from major AI developers.  

General counsel in organisations operating across markets should benchmark internal policies against these frameworks to ensure interoperability and avoid regulatory fragmentation. 

Compare how different jurisdictions are handling the regulation of AI in the comprehensive Artificial Intelligence 2025 Global Practice Guide from Chambers. 

This is a moment of opportunity. The UK’s AI bill may be paused, but the general direction is clear. Legal teams have a valuable opportunity to assess their organisation’s current use of AI, strengthen internal processes, and anticipate future regulatory expectations. 

For general counsel and in-house teams, this isn’t just about compliance; it’s a chance to lead with integrity, embed trust into innovation, and build governance that scales with ambition. By engaging now, you can help shape responsible deployment, reduce long-term risk and ensure your organisation is ready to respond when legislation arrives. 

Explore the Chambers Artificial Intelligent Global Practice Guide for practical insights, jurisdictional comparisons, and strategic frameworks to help you lead with confidence on AI. 

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