On May 27, the Connecticut governor signed into law a comprehensive artificial intelligence (“AI”) bill that regulates safety, transparency, and consumer protection, including subscription marketing (“SB 5”). Alongside key provisions on Employee Reporting Protections, AI Companions, and Automated Employment-Related Decision Technology (discussed in more detail here), SB 5 also sets out disclosure requirements for businesses
Inside Privacy
Updates on developments in data privacy and cybersecurity
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OMB Publishes 2026 Unified Agenda Signaling Upcoming Health Privacy and Interoperability Updates from HHS
The Office of Management and Budget (“OMB”) has released its 2026 Unified Agenda, which identifies regulatory actions that federal agencies expect to propose or finalize during the remainder of the year. Below, we highlight several notable health privacy, interoperability, and data exchange rules that the Department of Health and Human Services (“HHS”) has listed for…
New York City Adopts ‘Click to Cancel’ Rule
On July 10, 2026, New York City Mayor Zohran Mamdani and Department of Consumer and Worker Protection (“DCWP”) Commissioner Samuel Levine announced the adoption of a new “Click to Cancel” rule governing how businesses disclose, bill, and cancel subscriptions. The rule takes effect October 1, 2026.…
CJEU Decides When Streaming Subscriptions Are Subject to the Right of Withdrawal
On July 9, 2026, the Court of Justice of the European Union (“CJEU” or “Court”) delivered its judgment in Sky Österreich Fernsehen (C-234/25), deciding that a streaming offering constitutes a digital service under the Consumer Rights Directive (Directive 2011/83/EU), rather than digital content, where the trader’s offering is of a dynamic nature and…
CJEU Clarifies the Conditions for Seizure of Business Emails During Competition Inspections
On July 16, 2026, the Court of Justice of the European Union (“CJEU”) issued a decision clarifying that EU law does not, as a rule, prevent a national competition authority from seizing business emails stored on a company’s systems without prior authorisation from a court. However, strict legal safeguards and effective ex post judicial review must be…
FTC Settles with Hopper Over Hidden Fee Practices
On July 2, 2026, the Federal Trade Commission (“FTC”) announced that Hopper (USA), Inc. and its Canadian parent, Hopper Inc., agreed to a $35 million settlement resolving allegations that Hopper engaged in unfair and deceptive fee practices in violation of Section 5 of the FTC Act and the Trade Regulation Rule on Unfair or Deceptive…
Delaware General Assembly Passes HB 380, an Amendment to the Delaware Personal Data Privacy Act
On June 16, 2026, the Delaware General Assembly passed HB 380, which would amend the Delaware Personal Data Privacy Act (DPDPA). The bill is currently awaiting the Delaware governor’s signature, and if signed, the amendments would take effect on January 1, 2027. The amendment would impose the following:…
Irish NCSC Issues Cyber Governance Guidance for Management Boards Ahead of NIS2 Implementation
By Mark Young & David Brazil
On July 7, 2026, the Irish National Cyber Security Centre (“NCSC”) published guidance for management boards and senior executives of organizations subject to the EU’s Network and Information Security Directive (“NIS2”). Reflecting a central theme of NIS2, the Guidance makes it clear that cybersecurity is no longer solely a technical issue, but a governance and…
FTC Seeks Comment on Proposed Policy Statement Addressing AI Accuracy and Output Steering
By Laura Kim & Carter McCants
On July 1, 2026, the Federal Trade Commission (“FTC”) issued a proposed policy statement addressing what it describes as the “suppression of accuracy” in artificial intelligence (“AI”) systems and is seeking public comment through July 31, 2026. The proposal was issued pursuant to Executive Order 14365, Ensuring a National Policy Framework for Artificial Intelligence,…
Supreme Court Holds FTC Removal Protections Unconstitutional
On June 29, 2026, in a 6-3 decision, the U.S. Supreme Court held that (1) the Federal Trade Commission’s (FTC) statutory “for‑cause” removal protection for Commissioners violates the Constitution’s separation of powers and (2) President Trump lawfully removed Rebecca Slaughter from the FTC. The Court concluded that because FTC Commissioners exercise executive power, they must…