You’re shipping an AI product in the UK. Data provenance, the claims you make and the contracts you sign this quarter set your exposure.
Information, not advice
This page is information, not legal advice about your matter. A retainer begins only when a lawyer confirms it.
Start here
Write down what your model is trained on, and what you say it can do
Those two facts sit behind every contract you sign and every question the ICO or the FCA might ask. They are cheap to pin down now and expensive to reconstruct later.
What to work through, in order
Data provenance
UK GDPR governs any personal data in training material, including the lawful basis and transparency obligations. The text and data mining exception in UK copyright law is narrow and does not cover most commercial training.
Claims about the system
Misleading claims engage consumer protection law and, for regulated activity, the FCA’s fair, clear and not misleading standard. The CMA has published principles for foundation models.
Contracts and liability
Liability allocation, warranties on output quality, and the limits the Unfair Contract Terms Act places on exclusions. Enterprise buyers increasingly require indemnities for IP infringement in training data.
Next steps
What happens if you go ahead
Product and claims review
Provenance and contract memo
Contract suite
Who would handle it
Related reading
Legal Considerations on Artificial Intelligence and Machine Learning in Financial Services
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