Legislative & Regulatory Developments

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The Measures outline requirements and procedures for self-initiated and regulator-mandated compliance audits from May 1, 2025.

By Hui Xu and Bianca H. Lee

The Cyberspace Administration of China’s (CAC’s) official release of the Measures for Personal Information Protection Compliance Audits (the Measures) marks the CAC’s commitment to implementing the compliance audit system under the PIPL, which has been in effect since November 1, 2021. There was no formal guidance on or implementation of this requirement prior to the publication of the Measures, aside from a draft version of the Measures. The Measures took effect on May 1, 2025 (an unofficial English translation can be found here). 

Compliance audits are mandatory for personal information processors (PI Processors) subject to PIPL, as stipulated in Articles 54 and 64 of the PIPL and Article 27 of the Regulations on Network Data Security Management (Network Data Regulations).

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The first updates to the COPPA Rule since 2013 impose new obligations for sharing children’s personal information with third parties.

By Jennifer C. Archie, Marissa R. Boynton, Michael H. Rubin, Molly O’Malley Clarke, and Elizabeth Yin

On April 22, 2025, the Federal Trade Commission (FTC or Commission) published the final amendments to the Children’s Online Privacy Protection Rule (COPPA Rule)1 in the Federal Register. The published amendments will become effective on June 23, 2025…

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The draft law proposes a data embassy ecosystem and comprehensive framework in Saudi Arabia, promoting its position as a global AI hub.

By Brian Meenagh, Ksenia Koroleva, and Faisal Imam*

On April 14, 2025, Saudi Arabia’s Communications, Space and Technology Commission (CST) issued a consultation draft of a “Global AI Hub Law.” This draft law marks Saudi Arabia as the first G20 nation to publish a draft of a comprehensive legal framework that embraces the…

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Proposals grant controllers increased flexibility for automated decision-making, provided suitable safeguards are implemented.

By Fiona Maclean, Gail Crawford, Amy Smyth, and Lorenzo Meusburger

On 23 October 2024, the UK government introduced the Data (Use and Access) Bill (the Bill) to Parliament, marking a significant step in the evolution of the country’s data protection landscape. It follows previous reform attempts that lapsed after the July 2024 government change. The proposed legislation aims to reform various aspects of UK data protection law while also addressing broader initiatives related to data access and digital identity. Among its many provisions (138 Clauses, 16 Schedules and 251 pages to be precise), the Bill outlines notable changes in the realm of automated decision-making.

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The draft guidelines provide further clarification to the EDPB’s interpretation of legitimate interests, and suggest a potential divergence with the UK ICO.

By Gail Crawford, Fiona Maclean, Myria Saarinen, Tim Wybitul, Alice Brunning, and Calum Docherty

On 8 October 2024, the European Data Protection Board (EDPB) released draft Guidelines 1/2024 (the Guidelines) setting out its approach to processing personal data based on the “legitimate interests” legal basis in Article 6(1)(f) of the GDPR. The Guidelines…

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The deadline is fast approaching for in-scope financial entities and their ICT service providers to conform to the EU’s new digital operational resilience regulation.

By Christian F. McDermott and Alain Traill

With effect from 17 January 2025, a broad range of EU financial entities will be subject to the new EU regulation on digital operational resilience for the financial sector (DORA), with significant impact for firms and their third-party ICT service providers. As the new landscape takes shape, below is an overview of some of the key changes and steps that impacted financial entities and providers should be taking ahead of the deadline.

Covered institutions will need to review their cybersecurity and incident response policies and procedures ahead of the applicable compliance deadline.

By Robert Blamires, Laura Ferrell, Daniel Filstrup, Jennifer Howes, and Sarah Zahedi

The Securities and Exchange Commission (SEC) recently1 adopted amendments to Regulation S-P that expand the scope of requirements applicable to brokers, dealers, investment companies, SEC-registered investment advisers, and foreign (non-resident) SEC-registered brokers, dealers, investment companies, and investment advisers (together, Covered Institutions) in order…

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The Act establishes the world’s first comprehensive regulatory framework for AI, and is expected to shape the future of AI regulation and governance both within and beyond the EU.

By Elisabetta Righini, Hanno F. Kaiser, Tim Wybitul, Fiona M. Maclean, and Michael H. Rubin

After three years of legislative debate, the Council of the European Union cast its final vote on the European Union (EU) Artificial Intelligence (AI) Act on 21 May 2024. Once published in…

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Businesses need to be proactive in updating their compliance measures to meet the ever-evolving set of privacy laws and regulatory expectations in 2024 and beyond.

By Michael H. Rubin, Robert W. Brown, Max G. Mazzelli, Jennifer Howes, and Sarah Zahedi

Following the notable uptick in state-level privacy laws in 2023, a wave of new comprehensive state privacy laws and state laws seeking to regulate health privacy, youth privacy, online platforms, and data brokers are set to take effect this year. While a draft federal comprehensive privacy law — the American Privacy Rights Act — aimed at harmonizing this patchwork of state laws was introduced last month, until such a law actually passes, the quickly evolving state regulatory landscape will continue to set the standards for how most businesses must handle personal information in the US.

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The PDPL has broad extraterritorial scope and substantial penalties for non-compliance, with full enforcement expected to start in September.

By Brian A. Meenagh and Lucy Tucker

The Personal Data Protection Law (PDPL) is the first comprehensive data protection law in Saudi Arabia. The Saudi Data and Artificial Intelligence Authority (SDAIA) is expected to start full enforcement of the PDPL from 14 September 2024, after the current compliance transition period ends. SDAIA emphasised that it expects entities to take measures to achieve compliance with the PDPL by the September deadline.