UK Statutory Code on AI and automated decision-making – United Kingdom
On 16 April 2026, the UK Official Gazette published Statutory Instrument SI2026/425 – the Data Protection Act 2018 (Code of Practice on Artificial Intelligence and Automated Decision-Making) Regulations 2026. The Regulations place the Information Commissioner's Office (ICO) Code of Practice on AI on a statutory footing, clarifying how existing UK GDPR and Data Protection Act 2018 obligations apply to the development and use of AI-driven systems, including automated decisions involving personal data. The Code may be taken into account by the ICO and courts when interpreting compliance with data protection requirements, and came into force on 12 May 2026.
This is a significant shift for any organisation using AI in its operations. What was previously guidance is now a statutory instrument. Businesses using automated decision-making in recruitment, credit assessment, customer profiling, or any other function involving personal data must now assess whether their practices align with the statutory Code – or face real regulatory and legal exposure.
Buy Now Pay Later brought into regulation – United Kingdom
On 2 April 2026, the FCA updated its guidance explaining how Buy Now Pay Later (BNPL) products, structured as Deferred Payment Credit, will be brought within the UK regulatory perimeter. The guidance clarifies the scope of agreements that will become regulated, outlines which firms and activities are in and out of scope, and explains authorisation expectations for providers. Firms intending to continue offering new deferred payment credit agreements from regulation day – 15 July 2026 – may notify the FCA to enter the Temporary Permissions Regime from 15 May 2026.
Separately, on 2 April 2026, the FCA issued formal directions specifying that firms wishing to obtain temporary permission must notify the FCA between 15 May and 1 July 2026 using the prescribed notification form, with a £280 application fee applying. For BNPL providers and any retailer offering deferred payment options, the regulatory clock is running. This is no longer a future concern – it is an immediate compliance deadline.
National Insurance Contributions Act – Pension salary sacrifice treatment – United Kingdom
On 29 April 2026, the UK Official Gazette published the National Insurance Contributions (Employer Pensions Contributions) Act 2026, amending Section 4 of the Social Security Contributions and Benefits Act 1992. The Act includes certain salary sacrifice pension contributions within National Insurance Contributions liability, providing that contributions above £2,000 annually are subject to Class 1 NICs for both employer and employee, while the first £2,000 remains exempt. The amendments apply from the 2029–30 tax year, but the Act entered into force immediately on passing.
While the operative date is 2029, the planning implications are immediate. Salary sacrifice pension schemes are widely used across UK businesses as a tax-efficient remuneration tool. Any business that has not already modelled the cost impact of this change on its total remuneration structure needs to do so now, before those structures are locked in through multi-year agreements.
UK deposit return scheme – Key operational details confirmed – United Kingdom
On 24 April 2026, the UK Deposit Management Organisation confirmed that a flat 20 pence deposit value will apply to all in-scope drinks containers under the UK Deposit Return Scheme, ahead of its planned introduction in October 2027. A single deposit value was selected to simplify consumer understanding and support consistent return behaviour.
Separately, on 17 April 2026, the UK DMO published a material specification setting out technical and design requirements for in-scope drinks containers, covering PET plastic, aluminium and steel containers within a size range of 150ml to 3 litres, including requirements on barcodes, product identification, compaction performance and registration timelines. For businesses in the drinks, retail, and packaging industries, the operational design of this scheme is now taking shape. Planning timelines, labelling changes, and logistics adjustments cannot be deferred to 2027.
EU AML Authority launches foundational rulemaking consultations – European Union
On 16 April 2026, the European Union Anti-Money Laundering Authority (AMLA) launched a public consultation on draft Guidelines under the Anti-Money Laundering Regulation, setting out minimum requirements for business-wide risk assessments to be conducted by obliged entities across financial and non-financial sectors. The draft guidelines establish core expectations for identifying, assessing and documenting risks related to money laundering, terrorist financing and the circumvention of targeted financial sanctions.
On the same date, AMLA launched a further consultation on draft Regulatory Technical Standards setting out proposed group-wide minimum AML/CFT requirements and additional measures for financial groups with subsidiaries and branches in third countries, including expectations on governance, risk assessments, internal controls, and information sharing. AMLA is now actively building the binding rulebook that will govern AML compliance across the EU. Businesses in the financial and professional services sectors that are not tracking this process risk being caught unprepared when these standards become enforceable obligations.
This content has been prepared based on regulatory and legislative updates identified across UK and EU jurisdictions as of April 2026. It is intended for awareness purposes and does not constitute legal advice.
Take a look at last month’s article: Regulations that will change the way you do business in 2026 | DWF Group
