Source: Global Law Experts

Ireland’s General Scheme of the Regulation of Artificial Intelligence Bill 2026, published on 4 February 2026 by the Department of Enterprise, Trade and Employment, will require startups that develop, deploy or resell AI-powered software in Ireland to revise software licence and SaaS contracts to reflect obligations derived from the EU AI Act. The Bill creates an AI Office within that Department and adopts a distributed enforcement model where sectoral regulators including the Data Protection Commission and the Central Bank will share supervisory responsibilities, meaning compliance enforcement may come from multiple authorities rather than a single regulator. The guide maps specific regulatory duties — such as technical documentation, risk classification, transparency and post-market monitoring — back to contract clauses and provides sample drafting language plus a prioritised 90-day action plan for early-stage companies.

Contract-level changes the guide identifies include introducing precise definitions (for “AI system”, “model”, “training data”, “prompt engineering”, “model update”), audit and documentation obligations (including model cards and technical documentation ownership), intended-use restrictions to limit downstream high-risk deployment, and revised warranties, indemnities and liability allocations tied to classification and regulatory change clauses. It highlights that high-risk systems (e.g., employment or credit decision tools) must meet conformity assessment, monitoring and human-oversight requirements, limited-risk systems trigger transparency and disclosure obligations, and minimal-risk systems remain subject mainly to existing product-safety and consumer-protection laws. The guide also recommends supplier checks, insurer notification, and early engagement with the AI Office once operational (H2 2026 expected), and notes IHREC’s observations calling for stronger fundamental-rights impact assessments and transparency obligations that affect contractual warranties and user-facing disclosures.