Cleary Gottlieb Steen & Hamilton LLP

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Background

On 19 November 2025, the European Commission presented its much-anticipated Digital “Omnibus” package[1] intended to ease the administrative and compliance burden facing European businesses. Executive Vice-President of the Commission Henna Virkkunen stated that “[f]rom factories to start-ups, the digital package is the EU’s answer to calls to reduce burdens on our businesses.”[2]

On November 4, 2025, the UK High Court handed down judgment in Getty Images v. Stability AI,[1] a case emphasized for its significance to content creators and the AI industry and “the balance to be struck between the two warring factions”.[2] Despite significant public interest in the lawsuit, the issues that remained before

On 10 October 2025, Law No. 132/2025 (the “Italian AI Law”) entered into force, making Italy the first EU Member State to introduce a dedicated and comprehensive national framework for artificial intelligence (“AI”). The law references the AI Act (Regulation (EU) 2024/1689) and grants the government broad powers to implement its principles and establish detailed operational rules.

On September 29, 2025, Governor Gavin Newsom signed the Transparency in Frontier Artificial Intelligence Act (TFAIA, SB 53 or the Act)[1], establishing a comprehensive framework for transparency, safety and accountability in the development and deployment of the most advanced artificial intelligence models. Building upon existing California laws targeting AI such as AB 2013

As part of our response to the European Commission’s consultation on possible reforms to its merger control guidelines,[1] we provided our views on Topic C – Innovation And Other Dynamic Elements In Merger Control.