Technology

This update highlights key legislative and regulatory developments in the first quarter of 2026 related to artificial intelligence (“AI”), connected and automated vehicles (“CAVs”), and Internet of Things (“IoT”).

I. Federal AI Legislative Developments

In the first quarter, members of Congress introduced several AI bills related to nonconsensual images, chatbots

Continue Reading U.S. Tech Legislative & Regulatory Update – First Quarter 2026

On 19 March 2026, Advocate-General Capeta issued an opinion in the case of Elisa Eesti AS v Estonian Government Security Committee (C-354/24). This case concerned, among other things, whether a 2022 order from the Estonian Government for Elisa Eesti AS—a 5G network operator—to remove Huawei components from its network for national security reasons was subject to EU law, constituted a lawful restriction on the right to offer an electronic communications network, and amounted to a “deprivation of property” requiring compensation.

AG Capeta concluded that the relevant Estonian regime was within scope of EU law—specifically the European Electronic Communications Code (“EECC”)—even though that regime allowed for the imposition of orders on electronic communications network (“ECN”) providers for national security reasons. She also concluded that the requirement to obtain prior authorization from the Estonian government for use of network equipment constituted a restriction on the freedom to provide an ECN, but that this could be justified on national security grounds if the decision was based on a genuine risk assessment that meets the requirements for proportionality under EU law. She stated that this determination should be left to the referring court. Finally, she concluded that the Estonian Government’s order did not amount to a “deprivation” of property for which compensation would be required, as it was instead a mere “restriction” on the use of property.

Below, we describe these non-binding conclusions in more detail. The Court’s final ruling in this case will have significant implications for the European Commission’s proposed revisions to the EU Cybersecurity Act, which as drafted would—among other things—allow the Commission to require ECN providers to remove and cease using components from designated high-risk jurisdictions in their networks. See our prior blog post on the proposal for a revised Cybersecurity Act here.Continue Reading CJEU Advocate-General indicates that communications network operators can lawfully be required to remove Chinese components, and that compensation is not required

In late December 2025, the FCC updated its “Covered List” to add foreign-produced Uncrewed Aircraft Systems (“UAS”) and their critical components. In early January 2026, the FCC narrowed that action by creating a temporary exception for certain UAS and critical components, including those on the Department of War’s Blue UAS

Continue Reading FCC Updates Covered List to Conditionally Approve the Use of Certain Drones

On March 17, Colorado Governor Jared Polis released a draft bill that would substantially overhaul the Colorado AI Act, replacing its core requirements with a narrower regime focused on disclosure, recordkeeping, and consumer notice requirements for “automated decision-making technology” (“ADMT”).  The proposal, which is still in draft form and

Continue Reading Colorado Officials Push to Repeal and Replace the Colorado AI Act

As artificial intelligence (AI) technologies continue to advance and states increasingly pass legislation to regulate AI development and use, Congress and the White House are proposing comprehensive nationwide laws.

New proposals from the White House Office of Science and Technology Policy (OSTP) and Senator Marsha Blackburn (R-TN) offer comprehensive approaches

Continue Reading White House, Blackburn Introduce Visions of Comprehensive Federal AI Policy

In a recent addition to the EU’s evolving digital rulebook, the European Commission has published a set of Guidelines under the European Media Freedom Act (“EMFA”). The Guidelines advise very large online platforms, as defined under the Digital Services Act (“DSA”), on how to set up a functionality that lets media organisations identify themselves—and, in doing so, unlock a set of procedural protections when it comes to content moderation.Continue Reading European Commission Issues Guidelines on Article 18 of the European Media Freedom Act

January brought several significant, long-awaited developments in the U.S. semiconductor policy space, marking an inflection point in how the Administration is deploying trade tools to advance national security and industrial policy objectives.

On January 14, 2026, the White House issued Presidential Proclamation 11002 (the “Proclamation”) and an accompanying Fact Sheet adopting

Continue Reading A Month in Semiconductor Policy: Section 232 Measures, BIS Rule, and Taiwan Deal Signal Strategic Push

On January 21, 2026, the FCC’s Media Bureau released a Public Notice providing new guidance on how it will evaluate whether broadcast television stations have triggered an obligation to provide “equal opportunities” to political candidates under Section 315 of the Communications Act.  

The FCC’s equal opportunities rule generally says that if a station gives one legally qualified candidate free airtime, it usually has to offer comparable airtime to the other candidates running for the same office unless an exemption applies. To avoid discouraging general news coverage, Congress created several exemptions to this rule—one of the most commonly used being the exemption for bona fide news interviews.  In its new guidance, the FCC signals a more restrictive view of the bona fide news exemption, particularly in the context of late‑night shows, daytime talk shows, and other hybrid news‑entertainment formats.Continue Reading FCC Issues Guidance Focused on Candidate Appearances on Talk Shows

On January 13, 2026, the U.S. Commerce Department, Bureau of Industry and Security (“BIS”) issued a final rule, titled Revision to License Review Policy for Advanced Computing Commodities (the “BIS Rule”), that implements a more favorable license application review policy for exports from the United States of certain advanced computing

Continue Reading U.S. Commerce Department Revises License Review Policy for Exports of Certain Advanced Computing Commodities to China and Macau

In 2024, the Federal Communications Commission (FCC) issued fines to four major telecommunications carriers—Verizon, AT&T, Sprint, and T-Mobile—for allegedly failing to protect the geolocation data of their subscribers, which the FCC claimed violated its Customer Proprietary Network Information (“CPNI”) rules. To challenge the action, all four carriers had to first pay the fines, which they did.  They then petitioned for review of the FCC’s decision in various U.S. courts of appeals, arguing that the FCC’s procedure for adjudicating monetary fines violated their right to a jury trial as guaranteed by the Seventh Amendment. Verizon sought relief in the Second Circuit, T-Mobile (which had merged with Sprint) sought relief in the D.C. Circuit, and AT&T sought relief in the Fifth Circuit.

The Second Circuit and the D.C. Circuit held in favor of the FCC, rejecting the carriers’ argument that the FCC violated their Seventh Amendment rights. But the Fifth Circuit reached a different conclusion, holding that the FCC’s procedure did in fact violate AT&T’s right to a jury trial. The FCC (which lost in the Fifth Circuit) and Verizon (which lost in the Second Circuit) each has filed a petition for certiorari at the Supreme Court.

With a 2-1 federal circuit split and two certiorari petitions pending, some are predicting that there is a good chance that the Supreme Court will decide to consider the appeals. The dispute raises a fundamental question about the FCC’s authority to impose monetary penalties through its in-house administrative enforcement procedures. If the Supreme Court grants certiorari, it will be called upon to determine whether the Communications Act violates the Seventh Amendment by authorizing the FCC to order the payment of monetary penalties for violations of the Act, without guaranteeing the right to a jury trial. The resolution of this dispute thus could have significant implications for how the FCC enforces the law against telecommunications carriers and other entities subject to its jurisdiction.

Both petitions for certiorari have been distributed for a January 9, 2026 conference.Continue Reading FCC Privacy Enforcement May Face More Constitutional Scrutiny: Supreme Court Review of FCC CPNI Fines Sought Amid Circuit Split