What to watch out for under the UK’s AI Opportunities Action Plan

The UK’s Department for Science, Innovation & Technology (DSIT) has released two key artificial intelligence (AI) documents:

• AI Opportunities Action Plan by Matt Clifford (the “Plan”)
• AI Opportunities Action Plan: government response (the “Response”)

The plan is underpinned by a set of important principles:

• Be on the side of innovators: Matt Clifford challenges the Government to ask “Does this benefit people and organisations trying to do new and ambitious things in the UK?” If not, he says, “we will fail to meet our potential”.
• Invest in becoming a great customer: he identifies that government purchasing power can be a “huge lever for improving public services, shaping new markets in AI, and boosting the domestic ecosystem”. He is correct in saying that doing this is not easy – that it will “require real leadership and radical change, especially in procurement”.
• Crowd in capital and talent: he identifies that the UK is a medium-sized country with a tight fiscal situation, but that the best talent around the world “want to start and scale companies here”. He believes the talent will attract investors (he is probably right).
• Build on UK strengths and catalytic emerging areas: he is right to shout about the fact that the UK has “strong companies in the AI application and integration layers that are well positioned to grow”. Science and robotics are seen as especially strong.

In this article, technology, data, and AI partner Vanessa Barnett sets out 12 key things to watch out for arising out of the Plan and Response.

1. Availability of data assets for AI training: the Department for Media, Culture & Sport (DCMS) and DSIT are expected to start engaging with partner organisations and industry to establish copyright-cleared British media assets. (Note, there is currently a separate consultation on Copyright and Artificial Intelligence, specifically addressing “text and data mining” which closes at midnight on 25 February 2025.)
2. Regulation of AI: it is clear that there will be more AI regulations, but also AI permissions. In the Spending Review in Spring 2025, we will start to see how much money is available for upskilling existing regulators. Regulators in the UK are not afraid of technology and are realistic about balancing innovation and regulation. The UK arguably sits emotionally halfway between the EU and the US when it comes to regulation of technology (and what technology is used for). We will expect more engagement on AI from all core regulators, including the Information Commissioner’s Office, Ofcom, and the Financial Conduct Authority. These will all continue to play a part alongside the enhanced AI Safety Institute (AISI). We will not expect to see our own version of the EU’s AI Act. Safety regulation is unlikely to be eased up.
3. Compute infrastructure planning and investing: expect a long-term compute strategy in Spring 2025 with a 10-year roadmap. This will allow builders of AI data centres, and builders of frontier models, to plan, and investors can plan to invest. Private investment will sit alongside the Government’s plan to start the delivery of a new supercomputing facility for AIRR.
4. AI Growth Zones: the first one is at Culham, the headquarters of the UK Atomic Energy Authority. In Spring 2025, it will be announced how more will be chosen. We will start to see gravity wells of organisations, investment and people around these.
5. Government contracts: it is clear that the Government must put its money where its policy is. Quite how that might pan out is not being announced until Autumn 2025, it seems. Optimistically, it should become easier to sell AI tools/enabled services to the Government.
6. Compliance: there will be no getting away from it – compliance and AI cover many overlapping areas (data, content, sectoral regulation, employment, safety, etc). Over Summer 2025, there may be an AI Knowledge Hub. This is welcome (and should sit neatly alongside the Government’s current efforts on assurance tools – see, for example, the Government’s AI Management Essentials Tool consultation which closes at 11:55pm on 29 January 2025).
7. International cooperations: expect this to be a slower burn as things settle politically in the US and EU.
8. Incentives to invest in the UK: this is unclear right now – likely because Chancellor Rachel Reeves has no wiggle room on tax incentives. There may possibly be some opposition to AI being treated differently to any other research and development.
9. Education: Clifford has identified a massive need for the UK’s people and organisations to be upskilled. Whilst 2025 may see some announcements here, it is likely that 2026/2027 will be the year education and AI are really focussed on by the Government. It will take time to assess in detail and then plan which bits of the UK educational infrastructure will be support that need.
10. Visas: Clifford has also identified a massive need for talent to come to the UK. The Department for Business and Trade (DBT) does currently have Global Entrepreneur and Global Talent programmes, but DBT will likely need to address these over 2025 and early 2026. There is definitely some political nervousness around immigration as recommendation 21, related to graduates, was one of the two “partially agreed” recommendations.
11. Public/private: from Summer 2025 we expect to see the Government work hand in hand with the private sector, in a reinforcing way. DSIT has identified and published five ‘quick wins’ to help this:
    1. Scale and open source 1-2 public sector-led AI solutions that are currently in pilot phase.
    2. Scale a citizen-facing AI tool that enables citizens to engage with Government in a more personalised and efficient way.
    3. Run Hackathons, aligned to the five key missions. This will be a key way to engage startups in mission delivery.
    4. Pilot the AI Knowledge Hub.
    5. Appoint an AI lead for each mission to help identify where AI could be a solution.
12. More ‘bodies’ doing stuff: from Summer 2025 we may well see an expansion of bodies who are tasked with unblocking blockers and really drive AI for the UK. But there will certainly be a new unit to partner with AI companies for AI Growth Zones, and the National Data Library. There is also a recognition that there needs to be partnerships between AI companies and the UK’s national security community.

Exciting times are ahead but there is lots to do. And of course, there is already much to do from a governance point for view for any builder or user of AI in business. AI governance work starts now.

If you have any questions about the AI governance you should be doing now, or the AI Action Plan, please contact Vanessa Barnett.