Kritia Law Watch
the fine that says a computer cannot decide alone
Sunday 2026-08-30
A quiet weekend for new publications, so this is the fortnight worth catching up on — led by the largest automated-decision penalty the EU has produced.
01 — ENFORCEMENT
Decisions authorities and courts actually published.
Uber fined nearly 825 million euros for automated driver blocking (4 minute read)
Autoriteit Persoonsgegevens (Netherlands)· EU
Between 2018 and 2022 Uber's software deactivated drivers' accounts on suspicion of fraud or low ratings, with no human looking at it, and drivers lost their income from one moment to the next. The Dutch authority found that unlawful and fined 824,990,000 euros. The number is Uber's; the rule is everyone's.
Italian authority fines Lusha 2 million euros over large-scale monitoring (5 minute read)
Garante (Italy)· EU
A decision of 27 July 2026 against a contact-data business, over the monitoring of a large number of people. Worth a look if your firm buys prospect lists: the questions the authority asked the seller are the ones a buyer should be asking too.
02 — RULES & GUIDANCE
New or changed official text, guidance and proposals.
AI Omnibus enters into force (3 minute read)
European Commission· EU
The Commission's own account of the 27 July 2026 amendment: high-risk rules under Annex III now apply from 2 December 2027 and product-embedded ones from 2 August 2028, the AI literacy requirement on companies is simplified, and some measures previously reserved for SMEs extend to small mid-caps. This is why guidance written before July describes duties that have changed.
Commission starts enforcing AI Act rules and new transparency requirements (2 minute read)
European Commission· EU
The announcement that enforcement began on 2 August 2026, with the AI Office and national authorities sharing it. The Commission also published a first list of more than 180 organisations signed up to the Code of Practice on transparency of AI-generated content.
Quick facts: transparency rules for AI systems (3 minute read)
European Commission· EU
A one-page summary of the Article 50 duties from the people who wrote them, last updated 29 July 2026. The shortest reliable thing to send someone who asks what the transparency rules actually say.
03 — PRACTICAL
Worth doing, or worth the time to read.
Identifying and managing a DPO's conflicts of interest (6 minute read)
CNIL (France)· EU
Published 10 August. If the person overseeing data protection in your firm also runs the operation being overseen, the French regulator sets out why that is a problem and what to do about it. In French.
04 — THE WIDER VIEW
Written about the rules, not by the people who make them.
AI literacy: the Digital Omnibus rewrites Article 4 of the AI Act (8 minute read)
Law & Technology· EUAnalysis
A walk through what changed in Article 4 and what survived it. Useful for seeing the before and after side by side, which most coverage still does not do. One author's reading, not an official one.
EU Digital Omnibus on AI enters into force (5 minute read)
Hunton Andrews Kurth· EUAnalysis
A firm's summary of the same amendment, written for people who have to explain it to someone else. Shorter than the Commission's version and organised by what moved.
05 — QUICK LINKS
- A controller must report a breach that happened at its processor (3 minute read)
UODO — Your vendor had the incident; the 72-hour clock is still yours. Poland, 12 August. - Regulation (EU) 2026/1744 — the amending act itself (25 minute read)
Official Journal — Published 24 July 2026. The text, if you would rather read it than read about it.
06 — COUNTDOWN
94days · 2026-12-02
Machine-readable marking for generative systems placed on the market before 2 Aug 2026.
What this isn’t
News about the law, not legal advice, and not an assessment of your business. Items marked Analysis are someone’s view of the rules, not the rules. Whether a duty applies to you depends on what you actually do — the scope checker is free.
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