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The Renters’ Rights Act 2025 received Royal Assent in October 2025 and will make fundamental changes to the Private Rented Sector.

Most major changes will start from 1 May 2026, including:

• “no-fault” evictions will be abolished – landlords will need reasons to end tenancies, such as non-payment of rent;
• the end of fixed term tenancies – all tenancies in the PRS will become monthly or weekly rolling tenancies;
• landlords will be unable to ask for more than one months’ rent in advance and can be fined for asking for more;
• landlords will only be able to increase rents once per year and must give at least two months’ notice of an increase. Tenants can apply to a Tribunal if they consider the rent increase is excessive and landlords will not be able to evict tenants for challenging rent increases; and
• tenants will typically have to give two months’ notice of terminating their tenancy unless the lease states, or the landlord agrees to, a shorter notice period.

From late 2026 onwards, further changes will be implemented, including:

• an online database of all landlords and rental properties in England;
• a free complaints service to help resolve complaints against landlords without the need for court (The Private Landlord Ombudsman); and
• consultations to extend Awaab’s law (to force landlords to act quickly when properties are unsafe) and to set a Decent Homes Standard (to ensure that there are rules that all private rentals are safe, warm and in good repair).

Read our article: Renters’ Rights Act 2025 – All Systems Go!

The government’s consultation on reforming the home buying and selling process ended in December 2025. The intention behind the reform is to make the buying and selling process faster, cheaper and easier and to minimise the number of transactions which fall through.

Some proposals include:

• requiring sellers and agents to provide key information about a property upfront;
• giving parties the option to enter into binding conditional contracts earlier in the process;
• expanding the use of digital tools and streamlining transactions; and
• introducing mandatory qualifications and a Code of Practice for agents.

The government’s roadmap is due to be published in the first half of 2026.

New obligations to register information about contractual controls will be implemented through The Provision of Information (Contractual Control) (Registered Land) Regulations 2026 which are currently in draft.

The Regulations apply to options, conditional contracts, pre‑emption rights and promotion agreements which require the owner of registered land to transfer the legal estate or grant a lease for a term of 15 years or more and which give the power to control how registered land is developed or disposed of. The right must be held by a business, a charity or similar or in exercise of public functions.

The Regulations will require relevant information (such as the parties, the type of agreed, length of agreement and details of any conditionality) to be filed with HM Land Registry within 60 days of the grant, variation or assignment or termination of a contractual control agreement. If information is not provided or false information is given knowingly or recklessly, this could constitute a criminal offence under the Levelling Up and Regeneration Act 2023 which carries a maximum of 2 years imprisonment and an unlimited fine. From April 2028, the Land Registry will publish contractual control data in a monthly dataset.

The Regulations will come into force on 6 April 2027, but transitional provisions mean that grantees of contractual control agreements entered into after the Regulations are made (the date for this is not yet fixed but is expected in the first half of 2026) but before 6 April 2027 must file the contractual control information by 6 October 2027. This means agreements entered into even before 6 April 2027 may still be caught by the Regulations.

Developers will need to be aware of the Regulations and the potential impacts they may have – these include mandatory reporting by a conveyancer (and therefore additional costs) and also issues surrounding confidentiality of deals relating to sensitive or strategic sites.

Read our article: A new register: the contractual control database

The English Devolution and Community Empowerment Bill was introduced to Parliament in July 2025.

The Bill proposes to amend the Landlord and Tenant Act 1954 so that upwards-only rent reviews are banned for new and renewal commercial tenancies. The Bill will not apply retrospectively, so existing leases will not be affected until they are renewed.

The Bill is continuing to progress through Parliament and is currently in the Report Stage of the House of Lords.

If enacted, the Bill has the potential to:

• encourage SMEs back to the high street by making rental properties more affordable; and
• encourage longer leases with rent renewal provisions, rather than the current common practice of shorter leases or break clauses to avoid rent renewals,

but alternatively, it could also:

• limit flexibility in open market negotiations by not allowing commercial entities to agree to upward only provisions;
• create a disparate market between new/renewal leases which are subject to the Bill and existing leases which can continue with the upward only renewals; and
• impact valuations and destabilise investor confidence in properties subject to commercial leases.

Read our article: A turning point for commercial leasing: reforming rent reviews in England and Wales

Regulations concerning how local authorities create their local plans have changed on 25 March 2026. This is due to the implementation of the Town and Country Planning Act (Local Planning) (England) Regulations 2026, which will replace the prior 2012 framework.

Changes to the plan-making system include, among other things, expanding the contents of what neighbourhood plans can encompass and the introduction of supplementary plans for local authorities to be more detailed in setting designs for specific arears or to more closely influence development sites.

The policy behind updating how local authorities create plans are efficiency-based: the government considers that updating procedural regulations is necessary to introduce a more transparent and accessible process for preparing plans.

There are detailed transitional provisions that govern the position between 25 March and 31 December 2026.

The government has opened a consultation seeking input on plans to create a national default fee schedule for planning applications. There is also an opportunity to comment on how the government’s approach to setting local fees.

Some specific items that can be commented include proposals to rework fee categories that are currently in use for easier usability and views on the potential to implement a cap on locally set fees. The consultation also looks to review the future role of discretionary services such as Planning Performance Agreements and pre-application advice.

The consultation is open until 28 May 2026 for those who wish to contribute to the consultation. Please find more details here.

The government has launched a public consultation on its draft New Towns Programme following the New Towns Taskforce report in September 2025. The programme is positioned as a vehicle to unluck development opportunities in locations primed for growth. The consultation is open to the public from 23 March 2026 and will close on 19 May 2026.

The current towns in focus are:

• Tempsford;
• Crews Hill and Chase Park, Enfield;
• Leeds  South Bank;
• Manchester Victoria North;
• Thamesmead, Greenwich;
• Brabazon and the West Innovation Arc, South Gloucestershire; and
• Milton Keynes.

During the consultation period, views can be submitted on the implementation of new towns, including on subjects such as incentives the government can provide to new areas. There is also an opportunity to comment on a Strategic Environmental Assessment report; this includes views on topics such as the knock-on effects of new locations opening up for development.

Please find details on the consultation here.

Planning portal fees are set to increase by 3.8% from 1 April 2026. The increase is set to reflect the consumer price index. A full schedule of fee increases has been provided by the Planning Portal here. Furthermore, the planning portal service charge is set to increase by £5 to £75.83 +VAT per application submission. Developers should note that, from approximately 17:00 on Tuesday March 31 2026, there will be an outage on the Planning Portal to apply fee updates and any submissions after this point will be charged the updated values.

The government launched a consultation in July 2025 in relation to proposals to reform poor payment practices in business to business relations. Noting that healthy cash flow benefits businesses and the wider economy, and that over 1.5 millions businesses are affected by late payments costing the UK economy almost £11 billion a year, the government is seeking to tackle:

• late payments;
• long payment terms;
• disputed payments; and
• unfair practice around retention payments.

The consultation sought feedback on a number of potential measures to tackle the main issues identified, but notably for the construction industry, proposed amendments to Part 2 of the Housing Grants, Construction and Regeneration Act 1996 (the “Construction Act”) to either prohibit the use of retention or introduce requirements to protect retention funds deducted and withheld from insolvency and late/non payment.

The other proposed measures cover:

1. introducing audit committees and board-level scrutiny of payment practices at large companies;
2. introducing maximum payment terms (limiting payment terms between businesses to 60 days);
3. introducing a 30-day deadline for disputing invoices;
4. making statutory interest mandatory on late payments;
5. requiring additional reporting on statutory interest;
6. enforcing financial penalties for persistent late payers;
7. introducing additional powers for the Small Business Commissioner (designed to improve their ability to conduct investigations into poor business to business payment behaviour);
8. changes to/removal of the use of retention in construction contracts.

All of the proposed measures would impact on the construction supply chain, though it is possibly the proposed changes to retention that will cause the biggest shake-up, given that these are routinely used throughout the construction industry and their removal or stricter regulation will force parties to consider alternative means of security.

The results of the consultation were due to be published mid-January 2026, but they have not yet been issued and the Government has not issued a statement to say when they can be expected.

Athough the consulation has closed, you can still view it here: Late payments consultation: tackling poor payment practices – GOV.UK

On 4 February 2026 the Government Commercial Function issued guidance on contract payment information, which is information that contracting authorities are required to publish in accordance with s70 of the Procurement Act 2023.

Date: this section of the Act is expected to be in force on 1^st April 2026.

Which payments: under this legislation, any payments over £30,000 (including VAT) made by a contracting authority under public contracts must be published on a quarterly basis.

Application: it applies to public contracts procured on or after 1 April 2026 (when this section enters into force).

Exceptions: the publication obligation does not extend to a public contract that is:

• a utilities contract awarded by a private utility;
• a concession contract;
• awarded by a school;
• awarded by a transferred Northern Ireland authority (although there are exceptions to this);
• awarded as part of a procurement under a transferred Northern Ireland procurement arrangement; or
• the establishment of a framework agreement (under which not payments are made) or dynamic market (i.e. not a public contract).

The guidance clarifies that this legislation will apply to payments made under call-off contracts where those contracts are:

• Public contracts;
• Awarded under a framework or dynamic market established under the Procurement Act 2023; and
• Commenced after 1 April 2026

The aim of this section of the Act is to improve transparency in public procurement. The publishing of this contract payment information will allow payments to be linked to specific contracts.

The guidance can be found here: Guidance_-_Contract_Payment_Information_FINAL.pdf and Guidance – Contract Payment Information (HTML) – GOV.UK

On 23 March 2026 the UK Government’s Department for Work and Pensions published a consultation seeking views on the proposal to combine the Engineering Construction Industry Training Board (ECITB) and the Construction Industry Training Board (CITB) to create a single, unified “Industry Training Board” (ITB).

Some of the reasons for the proposed reform include:

• Too few people entering the workforce;
• Experienced workers leaving at all stages of their career (research suggests more people are leaving the construction workforce each year than joining);
• Lack of skills is a significant barrier to employment;
• Skills shortages are a critical constraint on productivity growth;
• Transferability of skills within the workforce hampered by lack of recognition.

The consultation closes on 14 June 2026 and can be found here: Industry Training Board reform – GOV.UK

On 25 February 2026 the UK Government published a consultation on the proposed reform of the regulation of construction products. Like many new/reformed building safety measures in recent years, this is part of the Government’s response to Grenfell. The regulation of construction products has been impacted by the UK leaving the EU as many of the product safety regulations were mandated by EU law and have not been materially updated since then.

The consultation seeks views on:

1. expanding the current construction products regulatory regime;
2. the introduction of a “general safety requirement” for currently unregulated products; and
3. the provision of enforcement powers to the national regulator for construction products.

Key proposals include:

1. mandatory risk assessment by manufacturers of products;
2. provision of clear product information;
3. labelling and traceability with unique identifiers to facilitate recalls;
4. record keeping of risk assessments, product documentation and safety incident records for 10 years;
5. safe storage and transportation;
6. obligations on importers and distributors;
7. monitoring of safety issues; and
8. enhanced powers for the national regulator to enforce including market surveillance, investigatory powers, and proportionate intervention measures.

The proposals for sanctions for breach of the regulations include monetary penalties, cost recovery, and criminal offences for serious breaches.

The consultation closes on 20 May 2026, with new regulations aiming to be introduced by the end of 2026 and coming into force in late 2027.

The consultation can be found here: Consultation on the General Safety Requirement for Construction Products – GOV.UK

In Paragon Group Ltd v FK Facades [2026] EWHC 78 (TCC), the Technology and Construction Court faced the novel  question of who may exercise the right to adjudicate where rights under a construction contract have been assigned.

In this case the original Employer had assigned its rights under the contract to Paragon. The works were delayed and Paragon commenced adjudication to recover liquidated damages from FK Facades. The adjudicator made an award in Paragon’s favour and ordered FK Facades to pay the adjudicator’s costs. However, FK Facades asserted that Paragon had no right to refer the dispute to adjudication as it was not an original party to the contract.

The main issue for the Court to decide was whether an assignee qualify as a “party” for the purposes of the statutory right to refer to adjudication under section 108(1) of the Housing Grants, Construction and Regeneration Act 1996 (as amended) (“the Construction Act”).

The Court found that a valid assignment of contractual rights will generally include the right to adjudicate and if parties want to restrict this right then it must be clearly drafted.

Chloe Wood discusses the importance of the judgment here: Assignment of construction contracts: who has the right to adjudicate? | Foot Anstey

In Vision Construct Ltd v Gypcraft Drylining Contractors Ltd [2025] EWHC 2707 (TCC), the Technology and Construction Court considered whether a document originally issued and intended to be a payment notice can be retrospectively converted into a pay less notice.

In this case the sub-contractor issued an interim application for payment, to which the contractor responded with an email titled “payment notice” but the content of which stated that the sub-contractor was owed less than the application for payment. The sub-contractor then commenced a “smash and grab” adjudication for the remainder of the interim application sum, as the contractor had not issued a valid “pay less notice”.

The adjudicator found that the payment notice was invalid as a pay less notice so the sub-contractor was entitled to the full notified sum in the application for payment. The contractor then commenced Part 8 court proceedings asking the court to declare that the payment notice should be given retrospective effect as a pay less notice.

The court refused on the basis it would undermine both the Housing Grants, Construction and Regeneration Act 1996 and the sub-contract itself if the payment notice could somehow retrospectively be converted into a pay less notice.

Chloe Wood discusses the importance of the judgment here: No second chances: Strict rules on Pay Less Notices | Foot Anstey

The Renters’ Rights Act 2025 introduces major reforms to the private rented sector, with the first phase taking effect on 1 May 2026. Key changes include the abolition of Section 21 no‑fault evictions, the automatic conversion of all ASTs into assured periodic tenancies, and tighter controls on rent increases. Landlords must also provide tenants with new mandatory information by 31 May 2026. These reforms reshape compliance expectations for stakeholders involved in residential‑led development, private rented sector / build to rent schemes, and mixed‑use regeneration projects. Developers delivering new residential units should expect increased due‑diligence scrutiny from funders and purchasers, particularly around:

• long‑term management obligations,
• projected rental revenue modelling under capped increase rules, and
• enhanced compliance expectations baked into the regime from 2026 onward.

Read our article: Leasehold Reform 2026: what developers of new-build sites need to know

The High Court decision significantly alters long-assumed practice on service notices under the Landlord and Tenant Act 1954. The Court held that were a commercial lease includes its own mandatory service provisions (in this case, s196 LPA), that method becomes the exclusive method for service notices – even statutory notices such as s.25 notices. A notice returned undelivered therefore failed to be validly served. The ruling has immediate implications for developers acting as commercial landlords, particularly where possession or re-development strategies rely on correctly served notices.

In January 2026, the Government launched the Warm Homes Plan which is intended to cut bills for households in the UK, tackle fuel poverty, deliver energy security and help address climate crises in the UK.
The details of the Plan include:

a. £5 billion for low-income schemes, 2 billion for consumer loans, £2.7 billion for the Boiler Upgrade Scheme, £1.1 billion for Heat Networks, £2.7 billion innovative finance through the Warm Homes Fund to invest in home upgrades AND £1.5 billion other funding for Warm Homes Plan Programmes and Devolved Administrations.

b. The development of a new Warm Homes Agency (WHA) to co ordinate and oversee the delivery of the major effort that delivering millions of home upgrades will entail.

c. Support for heat network investment, including investing £1 billion and introducing heat network zoning.

d. Establishing a new Workforce Taskforce in partnership with the Trade Union Congress.

Further details can be found here.

On 11 March 2026, the Government published a consultation titled ‘Accelerating electricity network connections for strategic demand’. This is to address the issue of speculative activity which is materially inflating the demand connections’ pipeline and obscuring the real level of viable future demand. Whist the focus of the consultation is primarily on data centres (and the proposed measures are in the first instance focussed on removing unviable data centres from the demands’ connection queue), we do anticipate that large energy demand projects are likely to be affected in the future. The consultation closes on 15 April 2026 and housebuilders and developers of large demand projects are encourage to share their views to provide the Government with as an accurate picture of the anticipated demands’ queue as possible.

A summary of the proposed measures can be found here.

For those heat networks that are deemed authorised, the general authorisation conditions will become effective from 27 January 2026 and Ofgem will have powers to take enforcement action from that date.

Ofgem has now made available the general authorisation conditions through its public register.

For more information please read here.

The Labour Government has expressed its continued support for the Boiler Upgrade Scheme. In the Autumn 2024 Budget the Government committed £5.8 million of funding to develop England’s first heat network zones in 5 cities (Leeds, Plymouth, Bristol, Stockport, Sheffield and London). Construction is expected to start from 2026. The Government also reaffirmed its plans to introduce secondary legislation as outlined above.

Following the enactment of the Energy Act 2023 (‘Act’)

“The Heat Networks (Market Framework) (Great Britain) Regulations 2025” were made on 2 March 2025. The provisions are coming into force on a staggered basis, such that as of 1 April 2025 it is prohibited to carry out a ‘regulated activity’ without authorisation. Broadly, a ‘regulated activity’ involves the operation of a heating network and the supply of heating or cooling through such a network.

So far, OFGEM has consulted on proposed measures that are intended on protecting end consumers (for instance the tenants of residential buildings), by providing for transparency around pricing and a set of standards that suppliers need to adhere to. OFGEM will have regulatory responsibilities under the proposed new regime.

A lot of the detail is yet to be ironed out, so for now those who operate heat networks or supply heating or cooling through such networks are encouraged to: (i) where they own or operate buildings that are connected to a district heat network or buildings that use a communal heat network, identify whether they are a “heat supplier” or “operator” and (ii) monitor the developments in this space to ensure that they are well placed to respond to any transitional arrangements that the Government may put in place.

From 1 April 2025, all existing communal and district heat networks (i.e. those in existence prior to 1 April 2025) will be deemed authorised. Operators of such networks and suppliers of heat or cooling in those networks will be required to register their regulated activities with Ofgem by 26 January 2027.

All new developments, whether they are residential or commercial or an energy project, require a connection to the grid to be able to import electricity (and where there is on-site generation) export electricity to the grid. Whether a development is connecting to the distribution system or the transmission system, it will be affected to some extent by the Grid Connection Reform that National Grid has instigated.

The Grid Connection Reform is a process by which applications for new connections are submitted, assessed and managed is significantly amended. Additionally, the existing queue for projects connecting to the transmission system is going to be rearranged.

The first phase of the Grid Connection Reform, being the submission of evidence as part of the Gate 2 process, has now been completed and developers of clean energy projects will be notified in the w/c 1 December 2025, whether they have been successful in securing a Gate 2 Offer (with a guaranteed date of connection and point of connection) for their projects.

There is currently no indication from NESO as to when the next Gated Application Window will be. This is bound to create further uncertainty in the energy sector and cause delays in the delivery of clean energy projects. For those residential and commercial developers, who are looking to procure their energy through a renewable energy source, the delays resulting from the Grid Connection Reform, could have a direct impact on their energy procurement strategy.

Read our articles:

Grid connection reform: The big shake-up

NESO moves the goalposts on connections’ reform

NESO is currently consulting on changes to the methodologies that will apply from the next Gated Application Window. As part of this consultation, it has been indicated that the next Gated Application Window is likely to open towards the end of Q3 2026.

The Gate 2 process, which was concluded in August 2026 had and continues to have a significant impact on the renewable energy sector and we anticipate that the number of new clean energy projects (especially large scale ground mounted solar and wind projects) that will come to fruition in the next few years will be impacted.

In the last horizon scanner, it was mentioned that the Future Homes Standard (FHS) was intended to be published in Autumn 2025. The Government finally published the long-awaited amendment to Part L of Schedule 1 to the Building Regulations 2010 on 24 March 2026.

The FHS will take effect from 24 March 2027 and is intended to ensure that new homes and non-domestic buildings incorporate energy efficiency measures and low-carbon heating options to ensure that there will not need to be retrofitted further to align with the Government’s Net Zero ambitions.

Anticipated changes include a requirement to ensure that any roof-mounted pv arrays on new homes cover an area that is at least equivalent to 40% of the home’s ground floor area (with exceptions) and the move away from gas boilers to heat pumps.

The Act will reform private renting including abolishing section 21 “no fault” evictions, introducing a tenancy structure where all assured tenancies are periodic and applying the Decent Homes Standard and ‘Awwab’s Law’ to the private rented sector. The aim is to give renters greater security and stability and includes the following proposals:

• all tenancies will be periodic tenancies;
• existing possession grounds and notice periods are to be reformed.

The Act will cause significant changes for investors with residential stock.

Read our articles below:

• Renters’ Rights Act 2025 – All Systems Go!
• Renters’ Rights Act 2025: update on implementation

The English Devolution and Community Empowerment Bill introduced to Parliament in July 2025, proposes a ban on upwards only rent reviews for new commercial leases. This has the potential to impact rent negotiations for leases and create a two-tier market until all existing commercial leases are renewed or terminated. This will likely impact investment valuations if it becomes law.

The Bill is currently making its way through the House of Lords, and the committee stage ended on 5 March 2026. The Bill will enter the report stage on 24 March 2026.

Read our article: A turning point for commercial leasing: reforming rent reviews in England and Wales

The government has reformed its apprenticeship programme, with wide ranging changes to apprenticeships including the following items:

• The minimum duration for an apprenticeship is now 8 months, or 187 hours of off-the-job training, whichever is longer.
• For apprentices with no prior learning, off-the-job training hours (which will be published for each apprenticeship standard) must be delivered.
• The apprenticeship funding rules for 2025-2026 have been updated.

Changes are now in effect for English and maths requirements.

The maximum ‘protective award’ for failure to consult in collective redundancy will double from 90 days’ pay to 180 days’ pay. This will change on 6 April 2026.

The waiting period for SSP shall be removed from 06 April 2026, so SSP will be paid from day one of sickness. The lower earnings limit will also be removed so all employees, regardless of their earning, qualify for SSP.

For employees who earn less than £123 per week, they will be entitled to receive 80% of pay as SSP.

From October 2026, employers must take “all reasonable steps” to prevent workplace sexual harassment, including harassment by subcontractors, agency workers, and clients.

Read our article: Third party harassment: Preparing for October 2026

The ERA 2025 introduces new restrictions on zero‑hours arrangements. Key changes include:

• Workers can request guaranteed minimum hours based on a 12‑week reference period.
• Employers will need to justify refusals and may owe compensation for short‑notice shift cancellations.

This will materially affect sectors that rely on flexible site resourcing, including property development and construction.

Dismissing someone then rehiring them on worse terms and conditions will become an automatically unfair dismissal in most cases. Changes are expected to take effect in January 2027, and an updated code of practice is also expected in 2027.

A recent Employment Appeal Tribunal decision highlights the discrimination risks that can arise following any TUPE transfer, where transferred employees are left on less favourable terms than their new employer’s existing workforce.

TUPE, race discrimination and the two-tier workforce – why the GOSH case matters

In the case of Ms Sarah Lindup v Bright HR Ltd [2025], the Tribunal found in favour of a saleswoman who was denied her previous role after returning from maternity leave.

Employment tribunal and court judgments | July 2025

The Data (Use and Access) Act 2024 (the “DUAA”) is now largely in effect, following its phased implementation timeframe between June 2025 and June 2026. It represents one of the most significant modernisations to UK data protection law since the UK GDPR and Data Protections Act 2018.

The reform will directly affect how developers collect, use and manage data, which is even more prevalent if digital tools, AI and smart-site technologies are being harnessed the business.

Several provisions make it easier for organisations to develop and use AI systems. Under the UK GDPR, using solely automated systems to make decisions with “legal or similarly significant effects” (such as hiring or shift patter) was heavily restricted. The DUAA relaxes this provided that appropriate safeguards are in place. Safeguards include:

• transparency around the logic used;
• ability for individuals to contest decisions; and
• meaningful human intervention where required.

The relaxation allows developers the freedom to further harness AI system to, for example:

• schedule their workforce;
• support recruitment and onboarding;
• monitor safety compliance;
• support performance evaluations; and
• predict maintenance and project analytics.

Developers may wish to review their processes and policies to take advantage of the widening ‘innovation-friendly’ changes brought in by the DUAA.

From 06 February 2026, the DUAA removes certain thresholds relating to breaches the Information Commissioner’s Office (ICO) could fine organisations for.

Prior to the change, and under the Privacy and Electronic Communications (EC Directive) Regulations 2003 (the “PECR“), the ICO could only issue fines for contraventions in cookies law if it was a ‘serious’ contravention and ‘likely to cause substantial damage or distress’. These two thresholds have been removed, meaning any breach of the cookies rules can now, in principle, result in a fine.

The change increases potential regulatory exposure. We have previously noted the ICO’s increased scrutiny of UK websites, following its investigation of the top 1,000 UK websites to conduct cookie compliance checks.

Construction firms are not exempt. Long ago are the days of considering the developer sector as a bricks-and-mortar industry. Most developers operate websites, digital portals, tender plaforms, project dashboards and recruitment pages. These all fall within the UK’s cookie law regime and are equally exposed to ICO enforcement (potentially bringing fines and reputational damage).

Developers may wish to consider:

• conducting cookie compliance audits;
• updating their cookie banners; and
• review their privacy and cookie policies.

Read our article: ICO’s cookies enforcement strategy: what businesses need to know in 2025

The Data (Use and Access) Act 2025 (DUAA) introduces a statutory duty for organisations to maintain a formal, publicised process for handling data protection complaints, effective from 19 June 2026.

Organisations must acknowledge complaints within 30 days, investigate promptly, and inform complainants of their right to escalate to the ICO.

The statutory duty applies to all organisations with personal data (including employee data). Developers may wish to:

1. Implement or review their complaints process to ensure it meets the requirements of the statutory duty (including acknowledging the complaint within 30 days); and/or
2. Consider forming a dedicated team to deal with such complaints or ensuring they form part of the responsibilities of an existing team within the organisation.

The ICO has set several priority areas for 2026, which will continue to drive enforcement and guidance updates throughout the year.

We expect there will be a focus on the following areas, from the regulator:

• Online advertising practices (including advertising technologies, profiling, and targeted advertising);
• Direct marketing and unlawful electronic communications; and
• AI and automated decision‑making, especially where decisions produce significant effects on individuals.

Although the ICO has indicated it will prioritise action where the harm is most likely, developers should take note of the ICO’s increased enforcement powers (both in greater latitude of application and increased fine amounts).