2026 is shaping up to be the most consequential year for UK data protection enforcement since the introduction of the EU/UK GDPR regime. With record fines issued in late 2025, a new enforcement playbook on the horizon, and shifting legislative and regulatory expectations, the Information Commissioner’s Office (“ICO”) is signalling a marked transformation in how it supervises and sanctions organisations.
This blog explores what is changing, why it matters, and what businesses should be doing now. The point being that firms will need to carefully review their current practices and procedures and, in particular, re-think their compliance processes in respect of cybersecurity, incident response, supplier oversight, data governance, and contractual risk allocation to be properly and effectively prepared for the changing landscape.
What is a Lasting Power of Attorney?
Lasting Power of Attorney. The chances are that you won’t need it for a long time and maybe not at all. However, if something unexpected happens, for example if you are in an accident, then having an LPA in place will be one less thing for your loved ones to worry about.
If you make an LPA now and change your mind about who your attorneys should be, then you can always make a new one later.
When should I make my Lasting Power of Attorney?
You can only make an LPA while you have mental capacity so it is a good idea to think about it early, even if you are young and healthy. The chances are that you won’t need it for a long time and maybe not at all. However, if something unexpected happens, for example if you are in an accident, then having an LPA in place will be one less thing for your loved ones to worry about.
If you make an LPA now and change your mind about who your attorneys should be, then you can always make a new one later.
Do I need a solicitor to make a Lasting Power of Attorney?
You can only make an LPA while you have mental capacity so it is a good idea to think about it early, even if you are young and healthy. The chances are that you won’t need it for a long time and maybe not at all. However, if something unexpected happens, for example if you are in an accident, then having an LPA in place will be one less thing for your loved ones to worry about.
If you make an LPA now and change your mind about who your attorneys should be, then you can always make a new one later.
Can my attorney just do what they like with my money?
You can only make an LPA while you have mental capacity so it is a good idea to think about it early, even if you are young and healthy. The chances are that you won’t need it for a long time and maybe not at all. However, if something unexpected happens, for example if you are in an accident, then having an LPA in place will be one less thing for your loved ones to worry about.
If you make an LPA now and change your mind about who your attorneys should be, then you can always make a new one later.
Conclusion
The UK data governance landscape is changing. The ICO is moving away from a guidance‑led approach toward a more public and interventionist enforcement strategy. Coupled with various new statutory requirements (such as those introduced by the DUAA), businesses face a materially heightened compliance burden.
Treat data governance as a board‑level strategic priority. Those who invest early in robust governance, stronger supplier oversight, enhanced cyber‑resilience and transparent data practices will be best placed to navigate the ICO’s new environment.
If you have any questions regarding this blog, please contact Caroline Sheldon in our Corporate, Commercial & Finance team.
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Thinking of investing or trading in the US?
This podcast delves into the critical state-level tax considerations for businesses investing or trading in the US.
John Young from Kingsley Napley, Jamie Baker and Michael Campbell from Aprio in this podcast explore key topics such as:
- Economic Nexus: How the concept of economic nexus impacts your tax obligations in different states, even without a physical presence.
- Foreign Transactions: Understanding the limitations of federal tax protections for foreign transactions at the state level.
- Sales Tax: The intricacies of sales tax, including collection, remittance, and the potential for personal liability.
- Remote Employees: How the rise of remote work impacts state tax obligations for businesses and the potential risks associated with employee location.
This podcast provides valuable insights for businesses looking to expand into the US market, emphasising the importance of proactive planning and expert guidance to navigate the complexities of state-level taxation.
Click here to listen to part 1.
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Autumn Budget 2025
Here’s what the announcements will mean for you, your family, and your business.