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Comment & Opinion

Legal Horizon – June/July 2026

“Across the horizon, we’re seeing businesses navigate a period of rapid change – from evolving technologies to shifting workforce expectations and sustainability priorities. The organisations that will thrive are those that stay curious, adaptable and forward-looking, using these developments as an opportunity to strengthen operations, build resilience and drive long-term growth.”

Rachel Turnbull, Director, Regulatory & Compliance
Rachel Turnbull

Corporate/general commerical

See our recent article outlining the key commercial and legal issues when considering contract termination, and practical solutions to address them.

In today’s uncertain market, many businesses are reconsidering deals which have become commercially unfavourable – perhaps due to supply chain disruption, the rising costs of materials, outdated appraisals and other factors.

Kathryn Vickers, Director, Commercial Dispute Resolution

The government launched a new Supply Chain Centre – a central hub for supply chain intelligence and policy – with the aim of strengthening national resilience at a time of increasing global disruptions, geopolitical fragmentation, climate impacts and technological change. One of the actions on its 14-point plan is to develop clearer standards for business on actions they should be taking periodically to map their supply chains, explore alternative sourcing options and ensure disruption preparedness.

The Office of Financial Sanctions Implementation fined a UK technology company more than £1 million for breaching Russian sanctions legislation. This is the largest such penalty issued since Russia’s 2022 invasion of Ukraine.

The Money Laundering and Terrorist Financing (Amendment) Regulations 2026 came into force on 30 June 2026. They make targeted changes to the UK’s money laundering regulations to improve the effectiveness, proportionality and clarity of the anti-money laundering and counter-terrorist financing regime and ensure maintained compliance with Financial Action Task Force standards. These changes include refining customer due diligence, enhanced due diligence and additional due diligence requirements, including for unusually complex or unusually large transactions and high risk jurisdictions.

HM Treasury published an updated money laundering advisory notice following the FATF’s most recent update to its lists of jurisdictions identified as having strategic deficiencies in their AML/CTF regimes.

The Department for Business and Trade issued a written statement setting out revised plans for the Part 15 Companies Act 2006 annual accounts filing reforms introduced by the Economic Crime and Corporate Transparency Act 2023. The reforms include software-only filing and the removal of abridged accounts for small companies. The government has now confirmed the reforms will proceed from 1 April 2028, one year later than originally planned, to give companies and software providers more time to prepare.

The Chartered Governance Institute published updated guidance on the proper purpose test for access to registers of members under section 116 of the Companies Act 2006. The CGI suggests that companies (and registrars) should develop internal processes to deal with such requests, particularly given the requirement that the register must be supplied or an application to court made within five working days of receipt.

See our recent article on the proactive measures landowners can take to manage trespass, fly-tipping and nuisance risk.

In an unreported decision, the High Court found that litigation privilege does not attach to communications prepared for the dominant purpose of enabling a litigation funder to assess a claim’s commercial viability.

The government launched a new ‘concierge service’ of hands-on support and a visa scheme to help the country’s fastest-growing firms scale and attract talent.

The Competition and Markets Authority warned businesses to be transparent on costs or risk enforcement action, after fining secondary ticketing platform StubHub UK for the illegal practice of drip pricing and ordering it to refund customers over the hidden fees.

The Committee of Advertising Practice and Broadcast Committee of Advertising Practice published an article explaining how their codes apply to accessibility provisions in advertising.

The International Chamber of Commerce and Global Anti-Scam Alliance published a framework on best practices for combatting scams in advertising.

See our recent article on the Terrorism (Protection of Premises) Act 2025 known as ‘Martyn’s Law’ and the practical steps you can take now to prepare ahead of expected implementation in 2027.

Martyn’s Law introduces a new legal duty for organisations to consider terrorism risks in their day-to-day operations. Engaging with the statutory guidance early will help organisations implement proportionate measures, demonstrate compliance, and better protect their people and reputation.

Stuart-Ponting

Stuart Ponting, Partner, Regulatory & Compliance

Data protection/cybersecurity/tech and digital

In RTM v Bonne Terre the Court of Appeal confirmed that the test for consent under data protection law is objective, not subjective.

The Information Commissioner’s Office published finalised guidance setting out its expectations for Internet of Things manufacturers and developers. It comes as new research shows that only 1 in 7 people have a clear understanding of how their smart devices collect and use their personal data.

The ICO’s 2026/27 workplan will include an AI code of practice and dedicated guidance on agentic AI.

The Digital Regulation Cooperation Forum issued a call for input as part of a project looking at consumer approaches to the risks of generative and agentic AI.

The Five Eyes cybersecurity agencies, including the UK’s National Cyber Security Centre, issued an urgent call for organisations to act now in the face of rapidly transforming cyber risk. The NCSC has published a frontier AI webpage on what you need to know, bringing together in one place a wide range of resources.

The government’s plans to introduce a social media ban for under-16s were widely reported. The measures are expected to come into force in spring 2027. This is not just a consumer protection measure – it will have significant implications for businesses operating in the digital ecosystem. Companies will need to implement robust age assurance technologies, reassess platform design, and ensure compliance with evolving regulatory expectations.

The International Chamber of Commerce launched a new platform to support companies preparing for digital trade adoption.

The Competition and Markets Authority introduced two new conduct requirements to make sure that Google’s search rankings, including AI Overviews, are fair and that users can benefit from sharing their data.

Measures to streamline the EU AI Act have now been approved, including delaying obligations for high-risk AI systems and watermarking obligations for AI-generated content placed on the market before 2 August 2026.

The Act’s transparency obligations place core disclosure duties on providers and deployers of AI systems so that users know when they’re interacting with AI-generated content. Note the short delay to watermarking obligations only applies to content placed on the market before 2 August 2026. The bulk of the transparency obligations – along with most of the Act’s provisions – start to apply on 2 August 2026. If you’re in scope of the Act, now’s the time to make final preparations ready for compliance.

The European Commission published its finalised code of practice on transparency of AI-generated content. The code is voluntary, but those that sign it can rely on its measures to demonstrate compliance. Others will need to be able to show that their chosen measures are adequate. Signatories will be publicly listed in July 2026. Final Commission guidelines on the scope of the transparency obligations are also expected.

The government held the first AI adoption summit to “focus on how we as a country adopt AI. How we take it out of the lab and put it into practice and into people’s hands“.

AI adoption plans were published by AI champions in the priority sectors identified in the government’s Modern Industrial Strategy. These include digital and technologies, advanced manufacturing and clean energy. The plans follow a pro-worker approach, with the government launching a pro-worker AI adoption prize which recognises and promotes organisations adopting AI in ways that increase productivity, provide workers with new capabilities and create new jobs.

Setting out the government’s interim response, the Technology Secretary said that businesses in every sector must step up and engage with the AI champions and their plans, invest in their workforce and lead transformation in their sectors. She describes it as “urgent, high-stakes work“.

Other key announcements include a UK AI hardware plan, new support for young people including AI ‘bootcamps’, and billions of pounds of new investment.

These developments underline how quickly the focus is shifting from AI innovation to real-world implementation. For businesses, engaging with AI is becoming a baseline expectation. Sector-specific plans, workforce initiatives and investment create a strong platform for growth and transformation. Organisations should be exploring where AI adds value, building skills and governance, contracting with AI providers where necessary and embedding AI thoughtfully into operations. Early, proactive adopters of AI stand to unlock productivity gains and new capabilities, making this a pivotal moment for every sector.”

Paul Armstrong, Director, Commercial

For more on tech developments, see the latest edition of our Technology & Digital round-up.

Sustainability/ESG

The government says that UK businesses can save millions of pounds and unlock new growth opportunities by putting nature at the heart of boardroom decisions. Together with various business partners, it recently launched new resources to help boards cut costs, reduce risk and drive growth through investment in nature.

The government published research examining whether the Streamlined Energy and Carbon Reporting framework, introduced in April 2019, has met its original aims, whether those aims remain relevant and whether the regime should be reformed. Its findings will help shape future policy on energy and carbon reporting, including the role of the SECR rules within the wider corporate reporting framework.

The ISO is consulting on the world’s first international independently verifiable standard designed to support organisations in developing credible and comprehensive net zero transition plans.

The Science Based Targets initiative published its revised Corporate Net Zero Standard to accelerate corporate climate action. This and the ISO’s draft standard are intended to be complementary, consistent and used alongside each other, reducing complexity for businesses.

The European Commission is consulting on the development of guidelines to support the effective implementation of the Corporate Sustainability Due Diligence Directive. All in-scope companies, which includes certain non-EU companies, must comply with the relevant domestic legislation by 26 July 2029.

The government published a policy paper on strengthening the UK’s approach to tackling deforestation. The aim is to introduce legislation in 2027 requiring businesses with an annual turnover of over £1 million, that use forest risk commodities and wood products, to carry out due diligence to make sure production complies with relevant local laws. The government wants the measures to operate consistently alongside the EU’s Deforestation Regulation (EUDR). The intention is to move towards a deforestation-free standard.

Back in May, the European Commission published a report on the simplification of the EUDR and a set of further measures for a smooth and effective implementation. Any operator or trader who places the relevant commodities covered by the EUDR on the EU market, or exports from it, must be able to prove that the products do not originate from recently deforested land or have not contributed to forest degradation. The EUDR will apply from 30 December 2026 for large and medium companies, as well as for micro and small enterprises from the timber sector, and from 30 June 2027 for other micro and small enterprises.

“Climate litigation is now a permanent feature of the global governance landscape” according to a recent report from LSE’s Grantham Research Institute on Climate Change and the Environment.

The Independent Anti-Slavery Commissioner published a report exploring how modern slavery and human trafficking in the UK are likely to evolve over the next decade, identifying emerging threats driven by technology, economic pressure and global instability, and setting out the actions needed.

People

The Employment Rights Act 2025 (ERA) is making sweeping changes to UK employment law. To help you navigate the changes, we’ve created a tracker to keep you updated on the proposals, what they mean for employers and how you can prepare, organised by topic and timeline. Access our tracker here.

Commencement regulations have now been made bringing the sections of the ERA dealing with unfair dismissal into force on 1 January 2027. The reduction of the qualifying period and removal of the cap will apply to any case where the effective date of termination falls on or after 1 January 2027.

The government also published a summary of feedback from stakeholders on changes to unfair dismissal law and committed to issuing guidance on the practical implications. Reference is also made to the setting up of a dispute resolution system taskforce to consider longer-term reforms that promote a more efficient and resilient system. Research commissioned by the Employment Lawyers’ Association, which proposes significant reforms, is expected to feed into this work.

The government is consulting until 25 August 2026 on reforms relating to zero hours and similar contracts, to implement measures in the ERA to end one-sided flexibility. Many details of the new rights need to be set out in regulations. The government has said that following this consultation it will develop final policy positions to deliver the measures, and that guidance will be published.

The government is consulting until 1 September 2026 on new rights for unpaid carers and parents of seriously ill children. This is not ERA-related and is part of a wider review of employment rights for unpaid carers.

The government is also consulting until 4 September 2026 on how the right to time off work for public duties operates in practice, and on proposed changes to the list of public duties eligible for time off under the relevant legislation. This follows publication of a report setting out review findings and the proposed changes.

The government published the results of a call for evidence on fit note reform launched by the previous Conservative government in 2024. Employers generally found that the current process was ineffective in meeting their needs, with concerns raised about the ease with which fit notes could be obtained without a face to face consultation and the need for clearer guidance on workplace adjustments, return to work timelines, and so on. As we reported previously, the government recently announced a radical overhaul of the system.

According to the results of a survey commissioned by Acas, one in four workers believe media coverage of sexual harassment has improved workplace culture.

The Equality and Human Rights Commission published research warning that employers must move beyond tick-box exercises to prevent workplace harassment.

In a recently published report, Work and Pensions Committee MPs call for a two-week legal deadline for employers to respond to requests for reasonable adjustments from disabled workers.

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Rachel
Turnbull

Director

Regulatory & Compliance

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Kathryn
Vickers

Director

Dispute Resolution

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Stuart
Ponting

Partner

Regulatory & Compliance

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Paul
Armstrong

Director

Commercial

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