Capabilities›Practices›AI, Data & Technology

AI, Data & Technology

Overview

Regulatory counsel for the companies building and deploying AI, across the EU, Switzerland and the United Kingdom.

The regulation of AI split three ways in the space of two years: the EU built a code, Switzerland chose sectoral legislation, with a cross-sectoral core on transparency, data protection, non-discrimination and supervision, on the foundation of a Council of Europe treaty it has signed but not yet ratified, and the United Kingdom regulates through its existing authorities. Companies rarely operate in just one of the three.

Our work is translation: from regulation into role analysis, controls and documentation proportionate to the product and the risk. The same applies to the data, cyber and contract layers around an AI deployment: the GDPR and the FADP, DORA, NIS2 and the Cyber Resilience Act, and the technology contracts that allocate the risk. We act for businesses on both sides of the technology, providers building and shipping AI systems and models, and deployers embedding them into products, decisions and operations, and for the boards that have to own the risk.

The starting point is almost always the same three-step sequence: an inventory of what the organisation runs, a role and risk mapping against the applicable regimes, and a prioritised gap list that separates what is legally required now from what arrives on the published timelines.

EUROPEAN UNION The AI Act Risk tiers, provider and deployer roles, transparency duties, GPAI obligations, AI Office Generally applicable since 2 August 2026 SWITZERLAND Sectoral, on a signed treaty No horizontal act; FADP and FINMA expectations today; implementing the CoE AI Convention (signed, unratified) Consultation draft due end-2026 UNITED KINGDOM Regulator-led No AI statute; existing law applied by sector regulators: ICO guidance, FCA approach for financial firms Statutory ICO AI/ADM code in development (SI 2026/425) Feb 2025 EU prohibitions, AI literacy Aug 2025 GPAI duties, governance rules 2 Aug 2026 EU general application, incl. Art 50 transparency (legacy marking by 2 Dec 2026) End 2026 Swiss consultation draft Dec 2027 EU high-risk rules (Annex III) Aug 2028 AI in regulated products (Annex I) Key dates as at 26 September 2026; verify against current texts. Timelines reflect the Digital Omnibus.

Three regimes, one governance framework, mapped three ways.

Follow the frameworks behind this practice in our AI Regulatory Hub.

How we help

AI Act compliance

  • Provider, deployer and importer role analysis, including the Article 25 reclassification triggers
  • System classification and risk-tier mapping, with the high-risk timelines planned in
  • Transparency implementation: content marking, chatbot disclosure, deepfake and text rules
  • GPAI obligations for model builders and fine-tuners, including open-source positions
  • Readiness reviews and gap analyses against the current and incoming texts

Deployment governance

  • AI use policies and internal rulebooks that staff can follow
  • Model procurement analysis, including non-EU models and hosted versus self-hosted architectures
  • Agentic AI governance: mandates, limits, logging and human override by design
  • Incident readiness across the EU, Swiss and UK reporting regimes
  • Board briefings and accountability structures for AI risk

Data, privacy and cyber

  • Data protection under the GDPR, the Swiss FADP and the UK GDPR: DPIAs, transfer assessments, controller–processor terms
  • GDPR and Swiss FADP analysis for AI training and deployment
  • Lawful basis, transparency and automated decision-making assessments
  • Operational resilience and cyber obligations: DORA for financial entities, NIS2 through national transposition, the Cyber Resilience Act from 11 September 2026 (reporting) and 11 December 2027 (full application)
  • Interface to sector rules, from FINMA expectations to the ICO's AI guidance

Contracts and transactions

  • AI vendor and customer contracts, with the Act's cooperation and flow-down terms built in where high-risk systems are involved
  • White-label and modification structures that place the provider role deliberately, within what Article 25 allows
  • Liability, warranty and indemnity architecture for AI products and outputs
  • AI diligence in M&A, investments and financing rounds
  • Insurance-facing documentation of AI governance and containment

How we engage

Three formats cover most needs. Each starts from the same principle: one governance framework, mapped to the EU, Swiss and UK regimes, in place of three parallel programmes.

AI readiness review

A fixed-scope assessment: inventory of AI systems and use cases, role and risk mapping against the applicable regimes, and a prioritised gap list with what is required now, what arrives on the published timelines, and what can wait. Designed to give a board a defensible picture within weeks.

Ongoing counsel

Continuing support as the frameworks harden: policies and contract reviews, guideline and technical-standard tracking, positions on new use cases as product teams raise them, and documented decisions that stand up when a supervisor, customer or insurer asks how a choice was made.

Product and transaction support

Pre-launch regulatory review of AI-driven products across the three regimes, vendor and customer negotiations, and AI-focused diligence in investments and acquisitions, including the provider-role and data questions that decide valuation adjustments.

Insights

Related