FORTHCOMING DEVELOPMENT: The Pensions (Extension of Automatic Enrolment) (No. 2) Bill received Royal Assent on 18 September 2023 as the Pensions (Extension of Automatic Enrolment) Act 2023 (the Act) and was published on 19 September 2023. The Act gives regulation-making powers to the Secretary of State for Work and Pensions to (i) reduce the lower age limit at which otherwise eligible workers must be automatically enrolled and re-enrolled into a pension scheme by their employers, (ii) remove the Lower Earnings Limit from the qualifying earnings band so that contributions are calculated from the first pound earned, and (iii) modify the requirements of the annual review of the qualifying earnings band. The changes on eligibility for automatic enrolment are to be implemented after a period of consultation on the precise implementation approach and timing. The date for the coming info force of section 1 of the Act is set to be ‘on such day or days as the Secretary of State may by regulations appoint’. For further information, see: DWP press release,

The Department for Transport has announced that the Automated Vehicles (AV) Act came into force on 20 May 2024 following its Royal Assent. The new law will unlock the industry's potential, which is estimated to be worth up to £42bn and will create 38,000 more skilled jobs by 2035. The law will also put an obligation on self-driving vehicles to achieve a high level of safety as careful and competent human drivers and require self-driving vehicles to meet rigorous safety checks before they are on the roads in 2026. This could drastically help prevent and reduce deaths and injuries from drink driving, speeding, tiredness and inattention and for the first time, corporations such as insurance providers, software developers and automotive manufacturers will be able to assume responsibility for how the vehicle drives.

UK Parliament has announced that the Automated Vehicles Bill will be examined by members of the House of Lords in committee stage. The Bill will be examined line by line on 10 January, 15 January and 17 January 2024.

UK Parliament has reported that the Automated Vehicles Bill has returned to the House of Lords for consideration of the House of Commons amendments. The House of Commons has proposed 11 amendments to Clauses 40, 43, 89, 93 and 100, as well as amendments to Schedule 1. The House of Lords will consider the amendments on 8 May 2024.

Automated financial product advisers or robo-advisers are automated computer systems that provide financial planning services with little or no human intervention. They are emerging across the financial service industry, helping consumers choose investments, banking products and insurance policies. This Practice Note considers the following: • Scope and uses of robo-advisers • Advantages and disadvantages • Risk creation versus risk mitigation • Regulatory framework • Recent FCA Reviews and Key Findings • Legal issues in relation to advice provided by robo-advisers • Views from the market • Next Phase of Robo-Advice Artificial intelligence (AI) underpins robo-advice and provides an opportunity for financial institutions to develop business models in order to better meet the needs of clients. Banks are aware that they need to organise, analyse and use data to reshape business models. This is the potential of AI: offering a range of benefits from better client experience, efficient risk management and compliance through to operational efficiency. AI technology improves speed, accuracy and consistency. As with most industries, banking

An automated calling system does what the name suggests. It is a system that: • automatically calls a series of different telephone numbers, and • transmits a message which is not live speech

MLex: The European Commission’s justice and consumer department recently launched a new work stream related to artificial intelligence (AI) in contracting—a growing phenomenon in which machines make decisions without explicit human consent. Algorithmic-based contracts are increasingly used in various sectors, from supply chain management to finance, prompting discussions on how traditional contract law applies in the case of computer errors.

Information Law analysis: The Court of Justice provided several clarifications around the scope of data subject access requests (DSARs) in the context of automated decision-making. The court held the determining factor for whether information constitutes ‘meaningful information about the logic involved’ under Article 15(1)(h) of the EU’s General Data Protection Regulation, Regulation (EU) 2016/679 (EU GDPR) is whether the information enables the data subject to understand the logic involved in automated decision-making involving their personal data. The court also held disclosure by controllers should be underpinned by the principles of transparency, which requires information to be clear, accessible and intelligible, both in terms of content and form, from the perspective of data subjects. In the context of automated decision-making this doesn’t necessarily mean providing the exact algorithm, if it doesn’t help the data subject’s understanding of the ‘how’. The court confirmed DSARs do not mandate the disclosure of trade secrets, but this can only be decided by the relevant supervisory authority or competent court, after assessing all relevant information provided to them by a controller. The protection of trade secrets cannot be used as a blanket excuse by businesses to withhold certain information from individuals making a request under Article 15(1)(h) of the EU GDPR. Written by Marija Nonkovic, associate at Kemp IT Law LLP.

The Smart Precedent handbook enables users to select which policies and procedures they wish to include in either a long-form or a short-form handbook from our suite of over 50 precedents. Users also: • decide, in one go, how the employer should be referred to throughout the handbook

This Practice Note considers the following data, privacy and cybersecurity issues arising in connection with the use of autonomous and connected vehicle technology: • The technology • Declaration of Amsterdam • Cooperative Intelligent Transport Systems (C-ITS) • EU General Data Protection Regulation • ePrivacy Directive • Cybersecurity • Data accessibility • Liability • EU AI Act • eCall • Data preservation and data production in the context of criminal proceedings • International • Practical issues For more information about other key legal issues arising in connection with this technology, see Practice Note: Automated vehicles—key legal issues in the EU and for a summary of key dates and information, see Practice Notes: EU data initiatives—tracker [Archived], EU Media, digital and telecoms tracker—horizon scanner and EU Media, digital and telecoms tracker—key developments tracker. To track developments in the UK, see Practice Notes: Autonomous vehicles—key legal issues, Autonomous and connected vehicles—data protection and privacy issues and UK automated vehicles—tracker. The technology Modern vehicles already feature a range of external communications systems such

This Practice Note considers the following issues in relation to the development and use of autonomous and connected vehicles (also referred to as driverless cars or automated vehicles) in the EU: • Terminology • The state of EU law • Product safety and EU type-approval procedure • Product liability and insurance • Data protection and cybersecurity The majority of media attention in relation to driverless cars has been on private road vehicles, which is the focus of this Practice Note. However, the technology is applicable in a range of sectors and there is evidence that earlier benefits may be obtained from the development of automated vehicle technology in sectors such as shipping and agriculture. For a summary of key dates and information relating to the development of autonomous vehicles, see Practice Note: EU automated vehicles—tracker. Practice Note: Automated vehicles—data, privacy and cybersecurity issues in the EU considers the data, privacy and cybersecurity issues arising in connection with the use of autonomous and connected vehicle technology in the EU. For

STOP PRESS/FORTHCOMING CHANGES: The UK is due to implement the OECD’s Cryptoasset Reporting Framework (CARF) into domestic law with effect from 1 January 2026. The implementing measure is the Reporting Cryptoasset Service Providers (Due Diligence and Reporting Requirements) Regulations 2025 (SI 2025/744), which was laid before the House of Commons on 25 June 2025. On the same day, HMRC published tax impact and information notes (TIIN) for the measure. HMRC has also published guidance on reporting under the CARF. The government has also introduced legislation amending the domestic law implementing the OECD’s Common Reporting Standard (CRS) and the UK’s obligations under the Intergovernmental Agreement with the US for the implementation of the US Foreign Account Tax Compliance Act (FATCA). The principal legislation is the International Tax Compliance Regulations 2015 (SI 2015/878) and the amending measure is the International Tax Compliance (Amendment) Regulations 2025 (SI 2025/740). The amendments implement the OECD’s 2023 changes to the CRS and introduce other changes ‘to make the UK’s implementation