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November & December 2025

NOVEMBER DECEMBER 2025

AI Governance and Tech Review November & December 2025

By Jana Schöneborn
🇪🇺 𝗧𝗵𝗲 𝗘𝗨 𝗔𝗜 𝗔𝗰𝘁 𝗮𝗻𝗱 𝗿𝗲𝗹𝗮𝘁𝗲𝗱 𝗘𝘂𝗿𝗼𝗽𝗲𝗮𝗻 𝗿𝗲𝗴𝘂𝗹𝗮𝘁𝗶𝗼𝗻:
  • Within this timespan, the AI Office did not only start the working groups on the Code of Practice on Transparency obligations, but already produced a first draft containing almost hands-on guidance on how to label and mark AI-generated content.
  • Most talked about and most relevant for 2026: The Digital Omnibus on AI Regulation proposal has first been leaked and then published in its full extend: Meaning to simplify and unify regulation, tying obligations for high-risk AI systems closer to the provision of standards, it still raised quite a few questions. Here I want to mention two particularly interesting ones: 1. the proposed change to GDPR in order to facilitate AI training and 2. the shifted (or possibly not?) timelines for high-risk requirements, with backstop compliance dates in December 2027 (for systems listed in Annex III) and August 2028 (Annex I).
  • The Danish NGO Institute for Human Rights published a Guide and a template for the Fundamental Rights Impact Assessment – one possible and surely helpful and quite extensive interpretation of what the AI Act (article 27) requires.
  • Lastly, the AI Office launched its Whistle Blower app.
📚 𝗔𝗜 𝗹𝗶𝘁𝗲𝗿𝗮𝗰𝘆:
  • One of the clear points of the Omnibus refers to a topic I very much care about, AI Literacy, demoting it from an obligation for organisations to a recommendation, while shifting the responsibility to governments. It was such an achievement to position this obligation differently than other regulations – I will write about the implications of this soon!
  • The Rolling Stones Magazine (yes, just that one) published a well-written (and -researched) article on AI flop in academia.
🇺🇸 𝗨𝗦 𝗥𝗲𝗴𝘂𝗹𝗮𝘁𝗶𝗼𝗻 & 𝗚𝗼𝘃𝗲𝗿𝗻𝗮𝗻𝗰𝗲:
  • THE one over-arching US-topic was clearly the Executive Oder signed by the president aiming (again) to end state-regulation regarding (almost) anything AI.
AI Governance globally:
  • India released its “India AI Governance Guidelines” defining the country’s own position on AI Governance, including a focus on trust, the commitment to establish interdisciplinary committees within the government (including the AI Governance Group and the AI Safety Institute) alongside practical guidelines.
  • Canada launched their AI register for AI use cases used by the government.
  • Sirak Abraha brought my attention to these newsfrom the UK with relevance for all banks using Agentic AI.
📄 𝗣𝗮𝗽𝗲𝗿𝘀 & 𝘀𝘁𝘂𝗱𝗶𝗲𝘀:
  • Capgemini & the World Economic Forum published this bright report on Governing Agents.
Tech-developments: