UK Knowledge Collection | Product regulation, sandboxes, and contingent workforces

A draft of the European Product Act has been leaked ahead of the Commission's expected formal proposal on 6 October 2026. It will consolidate the EU's New Legislative Framework and the Market Surveillance Regulation into a single directly applicable regulation covering conformity assessment, digital product passports and market surveillance. Our Insight looks at the implications for online marketplace operators, manufacturers of regulated products and importers.

Our Regulatory Outlook considers this and other recent product regulation developments, including the Office for Product Safety and Standards' new Product Regulation Sandbox programme. This lets a company developing an innovative product work directly with the regulator at an early stage, rather than waiting until the product is ready for market.

The Information Commissioner's Office (since 30 September, renamed the Information Commission's Office) has published findings from its research into the viability of a data protection statutory regulatory sandbox, which it conducted as part of its economic growth commitments to government. The sandbox would provide innovators with time-limited derogations from certain aspects of data protection law to test emerging technologies, including AI. The Food Standards Agency also has plans for a regulatory sandbox programme for cell-cultivated products as part of its approach to supporting economic growth while safeguarding public health and consumers. The Medicines and Healthcare products Regulatory Agency is also running a sandbox that will bring together AI-enabled medical device manufacturers and NHS organisations to deploy technologies in live clinical settings under its oversight.

Next week, we are hosting an in-person seminar at our London office, to discuss how the Employment Rights Act will affect users and suppliers of flexible workforces. Our Insight considers how the forthcoming Budget may further affect costs for businesses that hire, supply or pay contingent workers.

Recent Insights

Regulatory Outlook

The month's edition includes the new regulatory sandboxes being launched by UK regulators, with the ICO, FSA, OPSS and MHRA all consulting on or opening sandbox programmes covering data protection, cell-cultivated food products, product safety and AI-enabled medical devices respectively.
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Marketinglaw

A round-up of regulatory updates and Advertising Standards Authority rulings, including deceptive pricing, reference pricing and the advertising of AI products.
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Leaked draft European Product Act gives the Commission direct enforcement powers and exposes marketplaces to liability as authorised representatives

A leaked draft suggests significant changes ahead for online marketplaces, importers and manufacturers in respect of liability, enforcement powers and penalties.
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Contingent workforces contend with major reform in the countdown to the UK Budget

A wave of legal and regulatory change is heading towards anyone who hires, supplies or pays contingent workers, including guaranteed-hours rights, tribunal limits and tax risk.
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Events

Risk and reward: navigating the Employment Rights Act 2025 in a private equity context

Webinar | 7 October | 11:00-11:45 BST
Major reforms to unfair dismissal rights are coming into force from 1 January 2027, bringing uncapped liability across salary, bonus, commission and wider incentives. This webinar offers practical guidance on what this means for PE funds and their portfolios and what can be done to address the risks.
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Employment Rights Act 2025 | Zero-hours reforms and the Conduct Regulations

One London Wall | 8 October | 09:00-11:00 BST
This seminar will focus on reforms to guaranteed hours, shift notice/cancellation and changes to the Conduct Regulations, and the impact on users and suppliers of contingent workers.
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The Employment Rights Act 2025 in practice

Webinar series | 10:00-10:30 BST
A series of 30-minute webinars covering one employment reform in each session, explaining what the law says and what it means.

• Every step you take: the new harassment prevention duties | 12 October
• An offer you cannot refuse: new union rights every employer must understand | 2 November
• Playing with fire: the new rules on varying contractual terms and fire and re-hire | 23 November
• All together now: the new rules on collective redundancy consultation | 13 January
• Family matters: new protections around family friendly rights and flexible working requests | 24 February
• Zero to guaranteed: new rights for zero hours, low hours and agency workers | 17 March

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The PSD3/PSR masterclass | Customer protection, open banking and implementation

Webinar | 15 October | 10:30-11:30 BST
The third Payment Services Directive and the Payment Services Regulation will affect every player in the payment industry. From enhanced customer rights and safeguarding rules to Open Banking 2.0 and a practical implementation roadmap, this session tells you what to do and when to do it.
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AI Forum

One London Wall | 15 October | 13:30-17:30 BST
Designed for in-house counsel, compliance professionals and business leaders at every stage of the AI journey, this half-day forum offers actionable insight into where the law stands today and how organisations can build a coherent strategy for legal risk and business adoption.
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