Published on December 3, 2025, the article reviews the UK position on Artificial Intelligence regulation following recent multi-billion pound investment into the country’s infrastructure and scientific research. It notes that, unlike the European Union’s AI Act, the UK has no dedicated Artificial Intelligence Act and has preferred a decentralised, principles-based approach that relies on existing regulators such as the CMA, FCA, ICO and Ofcom. The Law Commission has issued a discussion paper, titled “AI and the Law”, and launched a project limited to public sector uses of Artificial Intelligence and automated decision-making. The Commission cannot make law but its recommendations often inform government policy.
The Law Commission paper aims to raise awareness of legal risks and to prompt wider discussion rather than to propose detailed reforms. It revisits long-standing questions about whether granting some form of legal personality to Artificial Intelligence systems could close so-called liability gaps. The paper highlights core challenges: the autonomy and adaptiveness of systems that learn and change post-deployment, the difficulty of establishing factual and legal causation and mens rea when outputs are unpredictable, and the opacity of models protected by proprietary rights or technical complexity. It also addresses oversight and over-reliance concerns in regulated professions and public decision-making, and training and data issues, including copyright and personal data protection.
The article concludes that the Law Commission’s paper is a measured starting point that organises key issues and identifies areas for further policy work. It flags that the suggestion of legal personality raises complex criteria questions such as how to define autonomy thresholds and design accountability mechanisms. Without follow-up work that converts the discussion into clear priorities and concrete proposals, uncertainty will persist. Developments in the EU and elsewhere will continue to be watched closely as domestic and global regulatory responses to Artificial Intelligence evolve.
