ICO issues draft guidance on enforcement

On 31 October 2025 the ICO published draft guidance on enforcement. The guidance covers:

  • Investigation process: how the ICO decides whether to investigate, what organisations can expect, including engagement and possible changes to scope

  • Information-gathering powers: the use of information notices, assessment notices, interview notices and entry and inspection powers

  • Limits on powers of investigation: dealing with situations where information may be not be used in investigations

  • Decision-making factors

  • Enforcement outcomes and appeals: including guidance on when settlement with a reduced fine may be appropriate.

The consultation closes on 23 January 2026.

The full guidance can be found here.

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