There is no UK AI Act. Your obligations already exist under UK GDPR, the Equality Act, and the ICO's incoming AI code.
The UK has chosen not to legislate a standalone AI law, relying instead on existing regulators. The ICO is now required to prepare a statutory Code of Practice on AI and Automated Decision-Making, and UK GDPR Article 22 rights already apply to automated decisions. Organisations still need documented evidence, there is just no single Act to point to.
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The challenge
Common governance gaps for uk ai governance organisations deploying AI.
Assuming 'no AI Act' means no obligations
Because the UK has not passed a horizontal AI law, many organisations wrongly assume AI use is unregulated. UK GDPR, the Equality Act, and sector regulators already apply to AI systems today.
No evidence for Article 22 automated-decision rights
UK GDPR Article 22 requires organisations to support human review, explanation, and challenge of solely automated decisions. Few organisations can currently produce evidence of how this is honoured.
Unprepared for the ICO's statutory AI code
The ICO is preparing a statutory code of practice on AI and automated decision-making. Organisations without a documented governance baseline will have further to go once it lands.
Regulatory obligations
The Data Protection Act 2018 (Code of Practice on Artificial Intelligence and Automated Decision-Making) Regulations 2026 require the Information Commissioner to prepare a statutory code of practice covering transparency, bias and discrimination, and rights and redress for AI and automated decision-making, with a mandatory children's-data component. Independently of that code, UK GDPR Article 22 already gives individuals rights over solely automated decisions with legal or similarly significant effects, and organisations must be able to evidence how those rights are met.
How AI Governance Hub helps
Platform features mapped to your specific governance workflow.
AI System Inventory
Record every AI system that makes or supports decisions about people, including which ones are wholly automated and fall under UK GDPR Article 22.
Risk Assessment
Flag systems with automated decision-making and protected-characteristic impact so Article 22 and Equality Act exposure is visible before it becomes a complaint.
AIIA Generator
Generate ICO-aligned AI Impact Assessments documenting fairness, transparency, and human oversight for every system, ready to evidence against the ICO's forthcoming code.
Compliance Dashboard
Track your position against UK GDPR, ICO AI guidance, and Equality Act obligations in one view, so you are not starting from zero once the statutory AI code is published.
What you will have in 4 weeks
A documented inventory of every AI system that makes or supports decisions about people
Evidence of how UK GDPR Article 22 rights (human review, explanation, challenge) are met
A governance baseline ready to map onto the ICO's statutory AI code of practice once published
Important: AI Governance Hub is a preparation tool that helps you understand, document, and work towards your compliance requirements. It does not provide legal advice and does not certify regulatory compliance. You remain responsible for your own compliance obligations. Consult a qualified solicitor or data protection specialist for legal advice specific to your situation.
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