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United Kingdom

DUAA 2025: UK GDPR/DPA/PECR reforms—private sector compliance guide to DSARs, legitimate interests, purpose limitation, automated decision-making, international transfers, cookies, direct marketing, enforcement and commencement dates

Practice notes
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The Data (Use and Access) Act 2025 (DUAA 2025) obtained Royal Assent on 19 June 2025. It revises elements of the UK General Data Protection Regulation, Assimilated Regulation (EU) 2016/679 (UK GDPR), the Data Protection Act 2018 (DPA 2018), and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (PECR 2003), SI 2003/2426. This Practice Note sets out the compliance consequences for private sector commercial organisations in the UK. DUAA 2025 both clarifies the domestic data protection regime and introduces added flexibility in several areas. If your organisation already follows UK data protection and ePrivacy requirements, only limited updates to your compliance procedures should be needed.

Which amendments are in force?

The table below sets out the implementation timetable:

  • Data subject requests — Yes: clarification of the searches needed for DSAR responses took effect on 19 June 2025 (and is treated as effective from 1 January 2024). The remaining changes took effect on 5 February 2026.
  • Legitimate interests — Yes, from 5 February 2026
  • Purpose limitation — Yes, from 5 February 2026
  • Complaints — No—this change comes into...
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Web page updated on 21/05/2026

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