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Privacy & law23 September 2026 · 2 min read

The Data (Use and Access) Act 2025: what changed for UK businesses

The Data (Use and Access) Act received Royal Assent in June 2025, the biggest change to UK data protection law since Brexit.

May 2018UK GDPR and DPA 2018Jan 2021UK GDPR after BrexitJun 2025Data (Use and Access)Act: Royal Assent2025–26Phased commencement
UK data law: recent milestonesUK legislation

Headline changes

  • A list of recognised legitimate interests that need no balancing test (such as crime prevention and safeguarding).
  • A duty to have a complaints process for data subjects.
  • Changes to rules on automated decisions and some cookies.

What hasn't changed for data deals

Commercial licensing isn't a recognised legitimate interest, so the full assessment still applies, and de-identification standards remain.

Key takeaways
  • Big reform, phased in over time.
  • Commercial data licensing still needs a full assessment.
  • Take advice on what's in force when you act.
Sources
  • Data (Use and Access) Act 2025, legislation.gov.uk

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