On 5 June 2025 the UK Information Commissioner’s Office published a new AI and biometrics strategy. It is not a new set of rules; its purpose is to state where the regulator will direct its attention next.
Four priority areas
The strategy concentrates on foundation model training, generative AI, automated decision-making and biometrics. All four share a feature: they involve processing personal data at scale, and their risks often surface only after deployment.
Singling out foundation model training means the regulatory gaze has moved forward to the data acquisition and model building stage, rather than fixing only on the application layer.
What front-end supervision means
Data protection enforcement has traditionally begun after harm has occurred. The strategy argues for stronger front-end supervision — intervening at the design stage of products and processes — to reduce the passivity of penalising after something goes wrong.
This approach matches the audit posture the ICO has taken towards police facial recognition: an audit is not a penalty but an early identification and correction of problems. See our notes on the ICO audit of police facial recognition and on the UK Upper Tribunal ruling in the Clearview AI case.
What it means for companies going abroad
The UK market sits outside the EU framework, but its data protection rules are closely similar. A company facing both the EU and the UK can usually adapt one compliance framework to both, provided it watches for the differences. See our notes on EU AI Act obligations for general-purpose AI models and on outbound personal information certification.
Where companies can start
First, move data protection assessment forward to the design stage, completing it alongside model training and product planning.
Second, build explainable records for automated decision-making, so that the logic of a decision can be reviewed.
Third, watch the special rules for biometric data, which are held to a higher standard than ordinary personal data. See our note on EDPB coordinated enforcement on transparency.
For a company, front-end supervision is easier to accommodate than it sounds: much of what it asks for — documented decisions, tested controls, an assessable record of why a design choice was made — is the same material a serious internal review would produce anyway.
A shift forward in the regulatory centre of gravity also changes the structure of compliance cost: the earlier the investment, the less there is to repair afterwards.
This article is based on the UK Information Commissioner’s Office AI and biometrics strategy and public information and is for reference only; it does not constitute legal advice.