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United Kingdom

EU AI Act: Employment Compliance for UK and Multinational Employers: Scope, Extraterritorial Reach, Risk Categories, Provider/Deployer Obligations, Worker Information and Consultation, AI Literacy and Penalties

Practice notes
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This Practice Note sets out an overview of the main considerations for employers under Regulation (EU) 2024/1689, the EU Artificial Intelligence (AI) Act (EU AI Act). It highlights essential details on scope, the risk-classification approach, obligations, and how these could be relevant in the employment context. For further material on the EU AI Act, see Practice Notes:

  • The EU AI Act
  • The EU AI Act—snapshot
  • EU AI Act—literacy rules
  • EU AI Act—general purpose AI models
  • Artificial intelligence in the EU—the key legal issues

Background and context

The EU AI Act creates a comprehensive legal framework governing the development, placing on the market, putting into service, and use of AI systems in the EU. Its aims are to advance the uptake of human-centred and trustworthy AI while safeguarding health, safety and fundamental rights, guarding against harmful effects of AI systems in the EU, and supporting innovation. For more information, see Practice Note: The EU AI Act—Objectives of the EU AI Act.

The EU AI Act identifies the principal actors in the AI value chain—importers, distributors, product manufacturers, authorised representatives, providers and deployers. It introduces a risk-classification system, assigning different obligations to...

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Hannah Mahon
Hannah Mahon

Hannah is a partner in our Employment, Labor and Pensions group.She is an experienced tactical litigator specialising in high value and/or complex and strategically challenging employment tribunal litigation and confidential and restrictive covenant matters.Her recent experience includes defending a circa £2m cross-jurisdictional ET claim (harassment (race), race discrimination, victimisation, whistleblowing, unfair dismissal and breach of contract) for a non-UK headquartered bank leading to ultimate withdrawal of claim.Successfully defending a circa. £2.2m ET claim (race, sex, associative disability, victimisation and unfair dismissal) for a global tech company and its Global Head of Sales.Hannah has also advised an upsurging tech company (including seeking opinion from Leading Counsel) on appropriate employment status for the business model and holiday pay for atypical workers.While successfully resolving an extremely sensitive equal pay and discrimination grievance with a value of circa. £200-£250k for a global underwriter. Complainant remained employed...

Rebecca Denvers
Rebecca Denvers

Rebecca is an experienced Professional Support Lawyer. She supports clients and colleagues in keeping up-to-date with all aspects of employment law, including writing legal updates, guidance and client materials. She also supports business development and marketing activity for the group and devises and contributes to internal and client-facing training....

Marieke Koster
Marieke Koster

Marieke is Office Location Head (OLH) of the Dutch (Amsterdam and Rotterdam) Employment, Labor and Pensions practice group.Marieke is a highly regarded employment law specialist with over 20 years of experience of sensitive and complex matters on a national and international basis. She is praised for her employment law expertise, pleasant client approach and high responsiveness. Working at international law firms for the vast majority of her career, she is well acquainted to advise national and international clients on a wide variety of employment law. She especially focuses on European labour law, whistle blower protection across the EU and pay transparency, flexible employment, (cross-border) reorganisations and restructurings including (collective) dismissal proceedings, in- and outsourcing, TUPE matters, termination of high level employees including managing directors, sick employees and employment litigation. In often highly complex matters with both a pensions and employment law angle Marieke works...

Jannick Thonemann
Jannick Thonemann

Jannick is a Counsel in the Commercial Advisory practice group in our Munich office.He focuses on the protection and enforcement of his clients' rights in the field of information technology and intellectual property, both in and out of court. His out-of-court work includes telecommunications law, technology transfer, software licensing, open-source software compliance, SaaS agreements, cooperation, and manufacturing agreements. Since 2017, he has been working on the legal implications of AI as part of his dissertation, and he is a frequent speaker on topics around AI. He advises on AI governance and compliance, covering the entire lifecycle of AI software from training to deployment, including the intellectual property implications during this process. His clients value not only his legal but also his technical understanding, which enables him to provide practical solutions to complex problems. He has a general understanding of several...

Robbert Santifort
Robbert Santifort

Robbert operates and specializes at the interface of Technology & Data Protection, having a strong focus on cyber security, data protection/privacy law, copyright law, software, database law, and trade secret protection. Legal aspects of the digital age are truly up his alley, pioneering in the area of new technologies such as blockchain, algorithms and big data analysis.Robbert has gained extensive experience with advising clients on cyber security incidents, data breaches, eDiscovery operations, DSARs, international data transfer mechanisms and other issues on the legitimacy of data processing activities.Before joining the IT & Data Protection team of Eversheds Sutherland, Robbert gained experience at top-tier Dutch law firm Houthoff. Robbert works for major clients in several tech/data related industries. He is known for his strong perseverance, offering clients exceptional but pragmatic legal advice when timing is critical.  ...

Web page updated on 21/05/2026

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