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1.29.26
All Eyes on AI: Regulatory, Litigation, and Transactional Developments - Q3/Q4 2025
Wilson Sonsini’s All Eyes on AI: Regulatory, Litigation, and Transactional Developments closely follows the evolving regulatory landscape for artificial intelligence (AI) in the U.S., new EU regulations for AI, international developments, litigation, recent deals highlights, firm publications, and other AI and machine learning highlights. This latest Q3/Q4 2025 edition features:
Alerts
11.21.25
The EU Omnibus Proposals Intend to Introduce More Flexibility in the GDPR, AI Act, and Other EU Digital Regulations
On November 19, 2025, the EU Commission (Commission) published a set of legislative proposals to introduce more flexibility into a number of EU digital regulations, including:
Newsletters
9.09.25
All Eyes on AI: Regulatory, Litigation, and Transactional Developments - Q2 2025
The latest edition of All Eyes on AI addresses the White House’s AI Action Plan, the USPTO’s plan to accelerate patent review, the EC’s details of the EU AI Act for GPAI requirements, and the Japanese market’s study on generative AI markets.
Alerts
7.21.25
EU Releases Final Code of Practice for General-Purpose AI Models
On July 10, 2025, the European Commission (EC) published the final version of the General-Purpose AI Code of Practice (Code). This voluntary instrument provides guidance on how providers of general-purpose AI models (GPAI), including those posing systemic risks (GPAI-SR), can comply with their obligations under the AI Act, which become applicable on August 2, 2025. The Code is structured around three key areas: transparency, copyright, and safety and security. Adherence to the Code is voluntary, but providers who decide not to comply with it may face heightened scrutiny from regulators, as they will be expected to demonstrate AI Act compliance through alternative means.
Alerts
4.29.25
EU AI Office Clarifies Key Obligations for AI Models Becoming Applicable in August
On April 22, 2025, the EU Commission’s AI Office published draft guidelines to clarify the obligations in the EU AI Act for providers of general-purpose AI models (guidelines). These obligations will be applicable to AI models released in the EU market after August 2, 2025. The guidelines are currently open for public consultation, and the AI Office invited stakeholders to provide feedback by May 22, 2025, using this form. The AI Office plans to adopt a final version of the guidelines before August 2025. Below, we present the main takeaways from the guidelines.
Alerts
2.11.25
EU Commission Issues Guidelines on Prohibited AI Practices Under EU AI Act
On February 4, 2025, the European Commission (EC) issued draft guidelines clarifying the AI practices that are prohibited under the European Union’s (EU) Artificial Intelligence (AI) Act. While non-binding, the guidelines offer valuable clarifications and practical examples to help businesses navigate their obligations under the AI Act. The EC has approved the draft guidelines, but is still to formally adopt them, which is expected in the near term.
Alerts
12.20.24
EU Privacy Regulators Confirm That Legitimate Interest Is a Valid Legal Basis for AI Model Training and Deployment
On December 18, 2024, the European Data Protection Board (EDPB) published its much-anticipated Opinion on the processing of personal data in the context of AI models in light of the EU General Data Protection Regulation (GDPR).
Alerts
10.02.24
EU Agencies to Develop Guidance on the Interplay Between the DMA and GDPR
On September 10, 2024, the European Commission (EC) offices in charge of the enforcement of the Digital Markets Act (DMA) and the European Data Protection Board (EDPB)—the European body composed of all EU data protection regulators that oversees the consistent application of the General Data Protection Regulation (GDPR)—announced that they intend to provide guidance on the interplay between the DMA and GDPR.
Alerts
7.12.24
EU AI Act to Enter into Force in August
On July 12, 2024, the European Union’s (EU) Artificial Intelligence Act (AI Act) was published in the Official Journal of the EU. This was the last step for the AI Act to become law. The AI Act will enter into force 20 days after the publication, i.e., on August 1.
Alerts
5.21.24
EU AI Act Is Now Adopted
On May 21, 2024, the Council of the European Union (the Council) formally signed off on the latest draft of the European Union’s (EU) Artificial Intelligence Act (AI Act) (see the press release here). This marks the final seal of approval from the EU legislators. The text will officially become law once it is signed by Presidents of the European Parliament and of the Council and published in the Official Journal of the EU. This could take place within the next two to four weeks. However, the law will have phased effective dates, with the first obligations (i.e., the rules on prohibited AI systems) becoming effective at the end of this year.
Alerts
3.13.24
The EU AI Act Passes Another Hurdle Towards Becoming Law
On March 13, 2024, the European Parliament (EP) approved the latest draft of the European Union’s (EU) Artificial Intelligence Act (AI Act). Following this vote, the text will be sent to the Council of the EU (Council) for formal approval, after which the AI Act will officially become law. Once the AI Act starts to apply, it will introduce a swathe of new obligations for companies providing and using AI systems and general-purpose AI (GPAI) models in the EU, subject to hefty fines of up to EUR 35 million or seven percent of the total worldwide annual turnover, whichever is higher.
Alerts
2.02.24
The AI Act Just Got One Step Closer to Becoming Law
On February 2, 2024, a committee of ambassadors from all countries of the European Union (EU) approved the latest draft of the EU Artificial Intelligence Act (AIA or the Act). Following weeks of speculation that there could be a blocking minority of EU countries who had concerns about the final text, this vote confirms that the AIA has substantial support within the Council of the EU (Council). This means that the AIA has a good chance to become law within the coming months. For more information about the scope and requirements in the AIA, please see our client alert on last December’s political agreement on the AI Act, available here.