Clifford Chance

This is part seven of our series of articles on the UK's Data (Use and Access) Act 2025 (DUA Act) - Click on the links to read the other parts.

• Overview
• Framework for smart data schemes
• Digital Verification Services Framework
• Changes to UK data protection laws
• Enforcement and regulatory engagement
• Cookies, trackers and security patches

We have also published a comprehensive PDF bringing all these together in one document for you to read and share.

Other provisions

The DUA Act includes a number of other provisions which include, for example:

Copyright and AI – emerging issues to be addressed outside the DUA Act

There was prolonged debate after Baroness Kidron put forward proposals to include provisions mandating transparency in respect of the copyright works used in pre-training, training and fine-tuning AI models, despite a parallel consultation process on copyright and AI taking place. These were not ultimately reflected in the final text.

However, the DUA Act does require the Government to publish a report addressing the economic impact of the policy options set out in the Copyright and AI Consultation Paper and consider the effect of copyright on the development of AI systems. The report must be ready by 19 March 2026, with a progress report to Parliament in December 2025.

Facilitating research into online safety

The DUA Act amends the Online Safety Act 2023, empowering the Secretary of State to make regulations requiring providers of internet services to share information for independent research into online safety matters. Those regulations are to set out the criteria, application and handling requirements for the provision of such information.

Investigating children’s deaths that may be related to their online activities

The DUA Act amends the Online Safety Act 2023 to provide for a coroner investigating the death of a child to notify Ofcom, and for Ofcom to require internet service providers of certain regulated services to retain information relating to the use of that service by the deceased child.

New information standards in health and social care

Currently, health and social care providers can face challenges in accessing or sharing patient care-related information due to, for example, inconsistencies in data and system interoperability challenges. Reforms included in the Health and Care Act 2022 made information standards mandatory and extended their application to private health and care providers. The DUA Act extends the scope of information standards further, so they apply also to IT suppliers of systems and services used in the health and adult social care system.

Mapping what's underground

The DUA Act provides a legislative basis for the existing National Underground Asset Register (NUAR) of infrastructure below street level, such as electricity and utility cables and water pipes. The information included in NUAR is be prescribed in regulation and the >600 owners of underground assets will be required to upload such information into the NUAR.

Smart meter communication services

The DUA Act amends energy, gas and electricity laws to empower the Gas and Electricity Markets Authority (Ofgem) to administer smart meter communication licences. These licences support the telecommunications networks to which smart meter devices connect.

Data for improving public service delivery

The DUA Act amends the Digital Economy Act 2017 such that public bodies may disclose information for purposes of improving public service delivery to undertakings (in addition to existing provisions allowing this in relation to individuals and households).

Digitising births and deaths registers

The DUA Act supports the complete digitisation of registers of births and deaths.

New crimes for creating or soliciting intimate images

The DUA Act amends the Sexual Offences Act 2003 to create new offences in relation to the creation of deepfake intimate images without consent from the person depicted.