The regulatory landscape continues to shift across multiple fronts. Congress is pushing renewed federal privacy legislation in the 119th Congress, while states advance their own AI and privacy bills ahead of legislative deadlines. Healthcare entities are preparing for potential HIPAA Security Rule revisions. The current enforcement wave follows Trump's January 2025 revocation of the prior administration's AI order and a December 2025 DOJ directive challenging state AI laws deemed inconsistent with federal policy.
Attorneys should act now on several fronts. Platforms and AI developers must implement TAKE IT DOWN Act compliance immediately—the 48-hour removal obligation is already live. Companies in media, advertising, and AI should review FTC settlement terms for enforcement signals. In-house counsel should monitor whether the voluntary executive order framework becomes de facto mandatory through regulatory pressure, and track whether federal privacy legislation gains traction or whether the state patchwork persists as the governing standard.