In 2025, technology is set to transform the way we live, work and connect. This year also marks the coming into effect of laws which will create new challenges and opportunities for technology-dependent organisations. To explore the key issues shaping the Technology, Media and Telecoms (TMT) landscape, we sought insights and predictions from partners in our TMT practice across the UK, Ireland and the Middle East.

The top 10 at a glance

1. Artificial intelligence
• Businesses will establish their AI governance models
• There will be increased clarity on the intersection of copyright law and AI
• Vendor terms will adapt to the AI age
2. Data
• Data compliance will become more complex globally
• International data transfers will again be in the spotlight
3. Consumer
• Consumer law compliance will become a C-Suite issue
4. Supply chain
• Supply chain management will be a key issue in commercial negotiations
5. SaaS/cloud
• On-premise solutions could make a comeback
6. Public procurement
• The Procurement Act will transform public sector procurement
7. Digital infrastructure
• The Middle East will become a digital infrastructure powerhouse
8. Brand protection and enforcement
• Copycat products may face greater attacks; brand owners will be checking the scope of their trade mark protection and enforcement approach
9. IP Audits
• AI-driven tools will make IP audits more rapid and cost-effective
10. Commercial agents
• The Commercial Agents Regulations could be scrapped

1. Artificial intelligence

AI Governance models will need to continue to adapt and evolve

Contributor: Simon Elliott

Did we see "peak AI" in 2024? The US's US$500 billion Stargate AI investment initiative, the UK government's AI Opportunities Action Plan and a projected quarter trillion dollar spend on AI infrastructure by Big Tech in 2025 say not. It is true that, in general, companies are continuing to search for the "killer app" use of AI and continue with targeted, tactical deployment of AI tools – rather than enterprise and strategic transformation.

Despite this, increasingly leveraging the benefits of AI is becoming "hardwired" into company strategies, supporting strategic objectives to digitalise the business or to make a strong tech pivot, or as part of significant cost control programmes. Having the right AI governance structures and controls in place is essential to manage risk as businesses continue at pace on their AI journey.

Establishing a cross-functional and efficient risk assessment and control framework is key to ensure appropriate issues are mitigated as well as achieving compliance with the increasing requirements of AI legislation and regulatory guidance. This will become even more important as the first stages of the EU AI Act take effect (with significant penalties for non-compliance). It will also become more challenging with AI regulation risks being at the front line of the developing "tech wars" between the US and EU, resulting in greater global divergence of AI management.

For more information, view our Global AI trends report: key legal issues for 2025 and our global overview for AI regulation, governance and ethics here.

For more detailed insights on how businesses are entering this new era of working with AI, please explore our Laws of AI Traction Report.

Simon Elliott is a partner in the TMT team, based in London. He is the Head of Dentons' Data Privacy and Cybersecurity practice for the UK, Ireland and Middle East.

There will be increased clarity on the intersection of copyright law and AI

Contributor: Jennifer Cass

Generative AI models are advancing at a rapid pace, but significant challenges remain at the intersection of AI and intellectual property law in the UK. Critical issues, such as the subsistence and ownership of IP rights in AI-generated outputs, and potential infringements arising from the training and use of AI models, remain unresolved.

2025 promises to be a pivotal year for addressing these concerns. The UK government is currently seeking feedback on its proposal to permit text and data mining of copyright-protected materials for commercial purposes (though with an opt-out provision for rights holders). Additionally, the high-profile legal battle between Getty Images and Stability AI is set to be heard before the High Court in the summer, likely setting important guidance for future cases involving AI and copyright.

As the landscape evolves, we anticipate a marked increase in the licensing of content to AI developers. Content owners are looking to capitalise on new revenue streams by licensing their materials, enabling AI models to access and allow for the legal training of AI models. This trend is expected to play a crucial role in shaping the future relationship between AI innovation and IP rights.

For more about the UK's AI-copyright consultation, view our insight here.

For more information about recent and predicted developments in AI and IP, view our insight here.

Jennifer Cass is a partner in the TMT team, based in London. She is the sector lead for TMT for the UK, Ireland and Middle East.

Vendor terms will adapt to the AI age

Contributor: Dan Burge

We expect to see significant development in the legal terms under which Al technologies are supplied – be it by technology companies, or by general businesses in their arrangements with their suppliers and customers. This is being driven by evolving capabilities, customer demands and the legal environment.

A major change in 2025 is likely to be the focus on deployment and orchestration of semi-autonomous AI agents. Generally, commercial terms currently emphasise that results must be verified by users – rather than vendors assuming full responsibility. It is difficult to reconcile the agents' autonomy with this kind of allocation of risk and responsibility. Trust in AI agents will be crucial for business value and it will be interesting to see if a new consensus can be established.

As the AI regulatory environment becomes clearer, we expect to see vendor terms begin to better reflect the customer's legal obligations when designing and deploying AI solutions. We anticipate 2025 to be the year when vendor contracts start defining a sustainable commercial model to support their investment commitments.

For more information about procurement of AI technologies, view our insight here.

Dan Burge is a partner in the TMT team, based in London.

2. Data

Data compliance will become more complex globally

Contributor: Antonis Patrikios

As businesses continue to leverage their data as a key asset and adopt data-hungry AI applications, the global legal framework for data is rapidly becoming more complex and higher risk.

Privacy and data protection laws continue to proliferate globally and we have seen the landscape evolve in the US, Middle East, India and Africa. In more mature data privacy regimes, such as the UK and the EU, regulatory guidance and case law develop and refine the statutory rules, which themselves are under review – such as the currently ongoing reform of UK data protection and cybersecurity law (which we consider below), and recent developments in Australian privacy law.

At the same time, the world is moving from personal data regulation to tech and data regulation: non-personal data, digital services and AI are all becoming subject to specific regulation – examples of this can be found in the form of the EU Digital Services Act, Data Act, EU AI Act and the UK Online Safety Act. Now, more than ever, it is essential to take comprehensive, pragmatic and proportionate approaches to compliance globally. The right approach to global data governance enables compliance in a way that makes operational sense and helps unlock the value of data. Because, in the final analysis, it is all about the data!

For more information about the EU Digital Services Act, view our insight here.

For more information about the EU AI Act, view our insight here.

For more information about the UK Online Safety Act, view our insight here.

For more information about data privacy and cybersecurity, view our practice page here.

Antonis Patrikios is a partner in the TMT team, based in London. He co-chairs Dentons' Global Privacy and Cybersecurity Group and leads the Global TMT sector group.

International data transfers will again be in the spotlight

Contributor: Nick Graham

Restricted transfers under data protection law are transfers of, or the allowing of access to, personal data across international boundaries. In essence, this is permitted provided you "export the law with the data".

In the last few years, we have seen businesses struggle with the nuances of the Schrems II requirements for assessing the risk of government access/use in a recipient jurisdiction and the undertaking of transfer risk assessments. While the basic requirements in generating an audit trail on this are becoming more "business as usual", we are still likely to see challenges in 2025 in how to operationalise this. This will likely be driven by needing to navigate multiple new data export restrictions – not just the familiar UK GDPR ones.

The development and implementation of AI models and products will also likely drive this and present new challenges in this market. We may also see developments in some of the data transfer tools such as EU Binding Corporate Rules. There are also discussions on a new template Referential for Processor BCRs, which is a record of compliance and forms part of the complex BCR application process, for example. This may affect timing for Processor BCR applications "in-flight" and those which are "pre-launch".

Nick Graham is a partner in the TMT team, based in London. He is the founding partner of Dentons' Global Privacy and Cybersecurity Group.

3. Consumer

Consumer law compliance will become a C-Suite issue

Contributor: Tristan Jonckheer

Historically, there has been limited enforcement of consumer laws in the UK. This is set to change in 2025. The consumer law provisions under the Digital Markets, Competition and Consumers Act 2024 (DMCC Act) are expected to take effect in April. Under the DMCC Act, the CMA will now be given new direct enforcement powers for consumer laws, including the power to impose penalties of up to 10% of global turnover.

This will be a step change for businesses who may have previously deprioritised consumer law compliance.

The CMA will be keen to flex its new enforcement muscles in 2025. The initial focus is likely to be on misleading price promotions, drip pricing and fake or misleading reviews. My prediction is that the travel sector and e-commerce marketplaces will be early targets for enforcement this year.

For more information about the DMCC Act, view our insight here.

Tristan Jonckheer is a partner in the TMT team, based in London. He is the Head of Dentons' TMT practice for the UK, Ireland and Middle East.

4. Supply chain

Supply chain management will be a key issue in commercial negotiations

Contributor: Martin Fanning

2025 promises a rapidly evolving global landscape marked by new governments and policy shifts, trade tensions and regional conflicts, as well as a proliferation of AI-enabled tools and technologies. In entering long-term arrangements – whether with strategic partners, technology vendors or key subcontractors – businesses must try to anticipate this wide range of externalities and legal complexities.

Key provisions become critical risk management devices, especially termination, subcontracting, force majeure and pricing clauses.

• Do your enterprise sourcing arrangements allow you to nimbly pivot to emerging markets to access AI talent and technologies?
• In a world of uncertainties, is it better to have prime contracting relationships to manage downstream change or is a multi-vendor posture preferable to maintain agility and best of breed service provision?
• If tariff trends accelerate inflationary pressures on the cost of service provision, is that a pass-through matter, a renegotiation point, an economic hardship or relief discussion with your contractor?
• How best to manage these points of friction?
• What dispute resolution clauses, including arbitration or mediation, offer structured pathways to resolve conflicts arising from changing legal and economic environments?

There is always much to think about in strategic partnering negotiations but these themes bring supply chain management and contracting risks into sharper focus for 2025.

Martin Fanning is a partner in the TMT team, based in London. He is the Head of Dentons' Commercial division.

5. SaaS/cloud

On-premise solutions could make a comeback

Contributor: Scott Singer

The past decade has seen businesses widely adopt cloud-based infrastructure to deliver critical software on an SaaS basis. Last year saw major corporates making significant eight-figure+ commitments to the main hyperscalers (AWS, Google and Microsoft). Additionally, there was a continued shift of applications from on-premise to cloud environments, with enterprise software giants such as Oracle, SAP and Microsoft all actively migrating clients to SaaS infrastructure.

We anticipate SaaS and cloud services will remain dominant in 2025, driven by enhancements such as AI integration, edge computing for improved performance, and enhanced privacy and security features. While SaaS offers significant benefits, some organisations have reported concerns over increased fees fuelled by provider lock-in and loss of control over critical infrastructure.

This raises questions about a potential shift back to on-premise solutions in some markets. We foresee customers seeking more flexibility, possibly opting for shorter renewals, usage-based pricing or new pricing models that offer greater adaptability.

Scott Singer is a partner in the TMT team, based in London. He is Chair of Dentons Helix & Co-Head of the Retail Sector.

6. Public procurement

The Procurement Act will transform public sector procurement

Contributor: Sarah Lima

A key development in 2025 is the Procurement Act 2023 which comes into force on 24 February 2025.

This is going to transform the way the public sector procures goods and services, and will be a major change to how suppliers need to engage to bid for public sector contracts.

Key changes include new procedures for procurement, as well as strengthened powers to cancel contracts and exclude suppliers on the basis of poor contract performance, with a mandatory requirement for KPIs for contracts of more than £5 million, plus the creation of a centralised debarment list.

Sarah Lima is a partner in the TMT team, based in London.

7. Digital infrastructure

The Middle East will become a digital infrastructure powerhouse

Contributor: Henrietta Baker

As companies, financial institutions and governments embrace tech-driven GCC initiatives such as digital transformation, AI, smart-cities, digital payments, IoT and blockchain, the strong demand for data storage and digital infrastructure looks set to continue into 2025.

The Middle East has a well-publicised ambition to become a global technology hub through strategic investments, innovation and partnership. This is most recently supported by the Abu Dhabi government's recent announcement of the its Digital Strategy 2025-2027 which is:

• aimed at establishing a robust digital infrastructure, creating a flexible and scalable foundation; and
• achieved through the allocation of US$3.5 billion to boost digital infrastructure, automate 100% of government processes and integrate sovereign cloud computing.

Effective cybersecurity and robust data protection will be key in managing risk. To support the development of these initiatives, we will see increased focus on regulatory compliance including under:

• the KSA's National Cybersecurity Strategy and Data Governance Framework;
• the UAE's Cybersecurity Strategy and Data Protection Regulations; and
• guidance in key areas such as AI.

Henrietta Baker is a partner in the TMT team, based in Dubai. She is Head of Dentons' TMT practice for the Middle East.

8. Brand protection and enforcement

Copycat products may face greater attacks; brand owners will be checking the scope of their trade mark protection and enforcement approach

Contributor: Anna Copeman

In the trade mark and brands world, two recent cases will have a significant impact on how brand owners go about protecting and enforcing their rights into 2025 and beyond.

Retailers trying to stop copycat products have received a boost from the Court of Appeal in finding that Aldi's "look-alike" cider product infringed trade marks owned by Somerset-based cider house, Thatchers. The Court of Appeal found that Aldi took unfair advantage of the Thatchers trade mark, confirming that infringement claims based on section 10(3) of the Trade Marks Act 1994 can be an effective avenue to tackle copycat products where one party is riding on the coat-tails of the success of an earlier product (although the issue is still highly fact-dependent). On investigation of Aldi's design process, the court concluded that the design of its Taurus cider product was intended to convey to consumers that the Aldi product was "like the Thatchers product, only cheaper".

In Q4 2024, the Supreme Court handed down its long-awaited decision in the long-running Sky v. Skykick case. The outcome puts a sharp focus on brand owners with broad specifications for their trade marks, which may make it more difficult for the owner to show a genuine intention to use the mark at the time of filing and therefore defend revocation attacks against their marks on the grounds of bad faith. As we head into 2025 and beyond, brand owners will be looking closely at the scope of their specifications and enforcement practices to ensure they are not susceptible to a bad faith attack.

Anna Copeman is a partner in the TMT team, based in London. She is Co-head of Dentons' Intellectual Property practice for the UK, Ireland and Middle East.

9. IP Audits

AI-driven tools will make IP audits more rapid and cost-effective

Contributor: Justin Hill

IP audits including risk assessments have long been central to establishing intellectual assets and strategy. Typically performed when a new stakeholder is conducting IP due diligence ahead of an investment or collaboration, IP audits are also used within businesses to better understand their own intangible value and the opportunities these assets present.

So-called "dry-run due diligence" is an excellent way for a company to check strategy and prepare for an upcoming transaction.

In 2025, we expect to see increased use of our market-leading Intanify AI platform by businesses to rapidly establish, and optionally value, their intellectual assets across 25 asset classes. This empowers businesses to build value, optimise strategy, transact successfully and leverage more attractive finance.

For more information on how Dentons uses the Intanify AI platform to help our clients, view our case study here.

Justin Hill is a partner in the TMT team, based in London. He is Head of the Firm's Patent Prosecution and Opposition practices across Europe.

10. Commercial Agents

The Commercial Agents Regulations could be scrapped

Contributor: Steph Innes

Late 2024 was an interesting time for commercial agents falling within the scope of the 1993 Regulations. Welcome clarity was provided in the High Court's ruling in Kompaktwerk v. Liveperson, effectively providing that agents concerned with the supply of SaaS products will generally not fall within the scope of the protections provided by the Regulations – SaaS is, as the name suggests, a service and therefore typically out of scope.

Beyond the courts, the previous UK government also launched a consultation in 2024 in connection with a proposed scrapping of the Regulations entirely, such that they would not apply to any newly appointed commercial agent. With the change in government, the status of the Regulations in 2025 is now unclear – whether or not the new government will pick up the baton remains to be seen.

The new government has already proposed notable changes to employment law to better protect employees – it might be said that the protective spirit of those changes seems inconsistent with a complete scrapping of the Regulations to the detriment of commercial agents. In the meantime, whilst any uncertainty remains, renewed focus should be placed on the terms of written agency agreements where – irrespective of any potential change to the legislation – the parties' intentions can be fully recorded.

Steph Innes is a partner in the TMT team, based in Glasgow.

Dentons' market-leading UK, Ireland and Middle East TMT practice provides strategic counsel to some of the largest domestic and global businesses operating across varied industries. With more than 75 dedicated partners and fee earners in England and Wales, Scotland, the Republic of Ireland and the United Arab Emirates, we have one of the strongest specialist TMT teams across the regions.