"Using AI for Official Decisions Raises Questions Over Compliance" The Times

Partner Joanna Ludlam authored an article for The Times examining how UK government agencies increasingly rely on artificial intelligence in decision-making, from benefits administration and immigration assessments to regulatory policing. Joanna warns that many algorithmic systems function as "black boxes" where the underlying logic remains opaque, even to the officials using them. This lack of transparency creates serious barriers for individuals while exposing public authorities to judicial review on grounds including unlawful fettering of discretion and procedural unfairness.

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As Chair of Jenner & Block's London Public Law and Crisis Management Practice, Co-Chair of the firm’s Global Hearing Preparation and Global Crisis Management and Strategic Risk practices, and Co-Chair of the firm’s Investigations department, Joanna advises major corporations, regulators, and public bodies on complex issues spanning administrative and public law, contentious regulatory investigations, legislative hearings and inquiries, and corporate crime underpinned by her experience in reputation and risk management.

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© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.

"Using AI for Official Decisions Raises Questions Over Compliance" The Times

Partner Joanna Ludlam authored an article for The Times examining how UK government agencies increasingly rely on artificial intelligence in decision-making, from benefits administration and immigration assessments to regulatory policing. Joanna warns that many algorithmic systems function as "black boxes" where the underlying logic remains opaque, even to the officials using them. This lack of transparency creates serious barriers for individuals while exposing public authorities to judicial review on grounds including unlawful fettering of discretion and procedural unfairness.

Read More

As Chair of Jenner & Block's London Public Law and Crisis Management Practice, Co-Chair of the firm’s Global Hearing Preparation and Global Crisis Management and Strategic Risk practices, and Co-Chair of the firm’s Investigations department, Joanna advises major corporations, regulators, and public bodies on complex issues spanning administrative and public law, contentious regulatory investigations, legislative hearings and inquiries, and corporate crime underpinned by her experience in reputation and risk management.

Related Locations

© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.

News and Insights

Event

Associate Steven Arango to Speak at the Veterans' Legal Career Fair

On September 18, Associate Steven Arango will speak on a panel at the Veterans' Legal Career Fair (VLCF), the only legal career fair in the United States dedicated to veterans, active-duty service members, and military spouses.

September 18, 2026

Publications

Partner Lucy Blake Discusses the FCA's New Non-Financial Misconduct Regime in Law360

Partner Lucy Blake spoke with Law360 for an article examining the Financial Conduct Authority's new non-financial misconduct rules, which took effect this week and extend existing banking-sector conduct standards to roughly 37,000 non-banking financial businesses.

September 2, 2026

Publications

In American Banker, Partner Laurel Loomis Rimon Weighs in on OCC's Handling of Fintech Bank Charter Applications

Partner Laurel Loomis Rimon spoke with American Banker about how the Office of the Comptroller of the Currency is approaching bank charter applications from fintechs, amid a growing wave of companies seeking charters from federal regulators.

August 18, 2026

Event

Partner David Greenwald to Speak at PLI Program on Privilege and AI

On August 17, David Greenwald will speak at "Fitting New “Tech” Into the Attorney-Client Privilege and Work Product Protection," a virtual program hosted by the Practising Law Institute (PLI).

August 17, 2026