Signal / Other / 30 April 2026

ICO refreshed direct-marketing guidance due spring 2026: what UK sales leaders should expect

The ICO has signalled that updated direct-marketing and PECR guidance, reflecting the Data (Use and Access) Act 2025 and recent enforcement, is due in spring 2026. Sales operations teams running UK outbound programmes should plan a compliance review against the refreshed text within 60 days of publication.

The current ICO PECR guidance was last comprehensively refreshed before the Data (Use and Access) Act 2025 took effect. The regulator has confirmed the next iteration is in preparation and expected in spring 2026.

For UK sales leaders the implication is procedural: any outbound programme launched between now and the new guidance landing should be designed to the conservative end of current ICO interpretations rather than to current vendor or recruiter advice.

Two areas where the refreshed guidance is expected to add specificity: (a) what 'significant effect' means for AI and profiling under DUAA, and (b) how the corporate subscriber exemption interacts with named-individual UK GDPR rights when a list is bought from a third party.

Practical step: schedule a compliance pass on any UK outbound programme for the 60-day window after the new guidance lands. The cost of one compliance pass is materially less than one ICO action.

Source: ICO commentary on data protection reform implementation; ICO PECR guidance pages: https://ico.org.uk/for-organisations/direct-marketing-and-privacy-and-electronic-communications/