Early Adoption of the GPAI Code: Strategic Advantage or Compliance Burden?
Introduction
AI is now firmly embedded in business operations across multiple sectors, influencing customer engagement, risk management, and decision-making. As adoption grows, regulatory scrutiny is intensifying. Frameworks such as the European Union’s General-Purpose AI Code of Practice (GPAI Code), published in July 2025, promote responsible, transparent, and lawful AI use — offering early adopters both a compliance tool and a commercial edge. In tightly regulated sectors such as gaming, gambling, and fintech, AI governance is no longer optional. These industries already face close oversight, and AI now drives functions tied to licensing, conduct, and consumer protection. Early adoption of the GPAI Code can boost credibility, reduce risk, and enhance competitive positioning.
Why Early Adoption Matters
The GPAI Code is a voluntary, forward-looking framework aligned with the trajectory of AI regulation. Early adopters gain advantages across regulatory, commercial, and reputational fronts. Regulators increasingly demand transparency and accountability from businesses using AI in decision-making. Aligning with the GPAI Code helps demonstrate these qualities and can improve supervisory relationships, especially during licensing or compliance reviews.
Investor expectations are evolving too. Governance-focused investors now see AI governance as part of responsible corporate conduct. Companies with structured oversight of automated systems are viewed as lower-risk investments. Early adoption also reduces exposure to enforcement and litigation. Failures involving algorithmic bias, data misuse, or poor oversight are becoming regulatory flashpoints. The GPAI Code offers a defensible framework, showing proactive risk management.
Commercially, early adopters gain an edge in tenders and B2B negotiations. Partners increasingly seek assurance that counterparties meet recognised AI governance standards. Compliance transparency is becoming a differentiator — and the GPAI Code provides a visible benchmark.
A Strategic Imperative for High-Risk Sectors
In gaming, gambling, and fintech, AI underpins compliance, marketing, and risk systems. Tools that assess affordability, detect money laundering, personalise promotions, or monitor behaviour are vital to both efficiency and regulation. Without proper oversight, these tools pose serious risks. Misapplied AI can breach licence conditions, misjudge risk, or treat customers unfairly. Regulators have made it clear: complexity or automation does not absolve accountability. Licence holders remain responsible for outcomes, regardless of the technology used. Implementing the GPAI Code formalises governance. It mandates oversight, testing, and record-keeping, with accountability resting on senior management. This mirrors principles regulators apply to outsourcing: responsibility cannot be delegated. Early adoption allows high-risk sectors to anticipate regulatory shifts and show readiness. Waiting until frameworks become mandatory may force rushed compliance under pressure.
The Broader Compliance Landscape
Globally, AI regulation is accelerating. The EU’s Artificial Intelligence Act, the UK’s pro-innovation framework, and similar efforts worldwide signal growing legal accountability for automated systems. The GPAI Code aligns with this trend, offering a practical, principles-based model for immediate use. In the UK, regulators such as the Information Commissioner’s Office, the Financial Conduct Authority, and the Gambling Commission are sharpening their focus on AI risks — from transparency and data integrity to fairness and explainability. Their message is consistent: operators must maintain control and oversight of deployed systems.
Adopting the GPAI Code will help organisations benchmark against these growing expectations. It will highlight governance gaps before they attract scrutiny and will signal a proactive compliance stance to regulators and partners. Reputation matters too. As AI ethics gain visibility, consumers and counterparties are watching how businesses use data and automation. A clear commitment to responsible AI can build trust and strengthen relationships across stakeholders.
Practical Steps for Implementation
Early adoption should be approached methodically. Businesses can start by mapping AI use across the organisation — identifying where automated systems influence decisions with regulatory, ethical, or financial impact. These systems should be reviewed for transparency, fairness, and human oversight. Governance structures must be formalised. Senior managers should understand the capabilities and risks of AI systems, with clear accountability for oversight, testing, and reporting. Board-level engagement is essential, as regulators expect directors to explain governance in practice.
Where third parties provide or manage AI systems, contracts should include clauses on transparency, audit rights, and GPAI Code compliance. This mirrors established outsourcing controls, ensuring external providers meet internal governance standards. Monitoring must be continuous. AI models evolve through retraining and learning, so governance cannot be a one-off task. Regular audits, impact assessments, and documentation are vital for ongoing compliance and risk management.
Conclusion
The GPAI Code is more than an ethical guide — it is a structured approach to AI compliance. For early adopters, it offers both protection and distinction: reducing regulatory and litigation risk while signaling leadership in responsible innovation. In gaming, gambling, and fintech, the case for early alignment is compelling. AI systems in these industries directly affect licensing, conduct, and consumer outcomes. Embedding governance early ensures that technology supports — not undermines — compliance goals. In a fast-changing regulatory landscape, early adoption is an investment in resilience and reputation. Businesses that act now will shape best practice and set the standard others must follow. Those that wait may face higher costs — in scrutiny, sanctions, and trust.
This article is intended for information purposes only and provides a general overview of the relevant legal topic. It does not constitute legal advice and should not be relied upon as such. While we strive for accuracy, the law is subject to change, and we cannot guarantee that the information is current or applicable to specific circumstances. Costigan King accepts no liability for any reliance placed on this material. For further details concerning the subject of the article or for specific advice, please contact a member of our team.
Archie Berens
Corporate Commercial Specialist
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