In 2025, state and federal officials continued scrutinizing the data privacy aspects of artificial intelligence (AI) systems, with enforcement agencies focusing on deceptive marketing claims, opaque data use disclosures, and potential risks to children stemming from chatbots and AI enabled customer interaction tools.
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Year in Review: The Top Ten US Data Privacy Developments from 2025
In 2025, federal and state privacy activity grew through DOJ’s new Data Security Program and rising AI and child‑privacy laws, despite no new broad privacy bills.
Transparency in Frontier Artificial Intelligence Act (SB-53): California Requires New Standardized AI Safety Disclosures
California has passed a new AI safety law (“the Transparency in Frontier Artificial Intelligence Act” or “TFAIA”) that requires developers of powerful AI systems to publicly share how they manage safety risks.
European Commission Releases Mandatory Template for Public Disclosure of AI Training Data
The European Commission has introduced a mandatory template for providers of general-purpose AI (GPAI) models to publicly disclose detailed summaries of their training data. This requirement aims to enhance transparency and support copyright and data protection enforcement.
AI and GDPR: A Road Map to Compliance by Design – Episode 5: Using AI
The use of AI requires organizations that act as controllers under the GDPR to determine the purposes and means of processing personal data.
European Commission Issues Guidelines for Providers of General-Purpose AI Models
EU issues GPAI guidelines under AI Act, detailing compliance for AI model providers, effective Aug 2, 2025, with focus on transparency and risk.
Artificial Intelligence and Abuse of Dominance in EU Law
AI’s autonomy and inference abilities may complicate enforcement of EU competition law, especially under Article 102 TFEU on market dominance abuse.
Texas Enacts New AI Law
On June 22, 2025, the Texas governor signed the Texas Responsible Artificial Intelligence Governance Act into law, making Texas the second state to pass comprehensive artificial intelligence regulation (with Colorado).
Another EU AI Act Milestone – Nearly Final Version of the General-Purpose AI Code of Practice Published
On July 10, 2025, the European Commission released a nearly final version of the General-Purpose AI (GPAI) Code of Practice (Code) under Regulation (EU) 2024/1689 (AI Act).
AI and EU Merger Control
The integration of AI into EU merger control presents challenges due to complex deal structures, limitations of revenue thresholds, and evolving regulatory responses, prompting authorities to consider new mechanisms and thresholds to ensure fair competition and effective oversight in digital markets.