Saudi Legal Professionals and AI 2025: PDPL, SDAIA, and the Global AI Hub Law in Practice

The Complete Guide to Using AI as a Legal Professional in Saudi Arabia in 2025

Last updated: September 13, 2025

TL;DR

• Operationalize AI under SDAIA's strategy and the PDPL. Document Transfer Impact Assessments (TIAs), especially for cross-border hubs under the draft Global AI Hub Law.
• PDPL penalties can reach SAR 5,000,000 and include criminal sanctions for unlawful disclosure of sensitive data.
• Upskill now. A 15-week AI Essentials for Work bootcamp runs $3,582 (early) / $3,942 (after) and builds practical, compliance-aware workflows.

"We are living in a time of scientific innovation, unprecedented technology, and unlimited growth prospects. These new technologies such as Artificial Intelligence and the Internet of Things, if used optimally, can spare the world from many disadvantages and can bring to the world enormous benefits." - His Royal Highness Prince Mohammed bin Salman bin Abdulaziz Al Saud

Saudi Arabia's AI: Institutions, Strategy and Guidance

SDAIA sits at the center of AI and data policy. It oversees the National Data Management Office (NDMO), the National Center for AI (NCAI), and the National Information Center (NIC), and translates the National Strategy for Data & AI into procurement rules, public-sector controls, and talent programs.

Expect practical instruments, not just policy slides: SDAIA has issued AI ethics principles, separate generative AI guidelines (government and public), and alignment with international standards such as ISO 42001-now a likely benchmark for compliance and vendor assessments.

• SDAIA (official): strategy, ethics, PDPL resources, and guidance
• PDPL (in force since Sept 14, 2023): controller registration, DPO duties, data-subject rights, cross-border rules, and penalties
• Generative AI guidance: adoption practices for public agencies and citizens
• ISO 42001: increasingly used as a procurement and governance signal

What is the AI Conference 2025 Saudi Arabia? Events, Training and Networking

Use the 2025 calendar to get hands-on with tools, meet vendors, and pressure-test compliance. Mix practitioner summits with in-Kingdom academic forums for both workflow and governance depth.

• AI Legal Operations Summit (two-day, 2025): eDiscovery, risk management, and in-house adoption tracks
• International Conference on Legal Technology & Artificial Intelligence - Riyadh: 24 Sept 2025
• International Conference on Artificial Intelligence and Legal Reasoning - Dammam: 31 Dec 2025

Watch local innovation. Qaanoon.AI, an Arabic legal-query platform, surfaced strong Saudi-specific use cases and vendor demos lawyers will see on the floor.

Key Laws and Ethical Rules for AI in Saudi Arabia (PDPL, Law of Evidence, SDAIA Guidance)

PDPL is active. Controllers must register, appoint DPOs in many setups, maintain RoPA, enable data-subject rights, and meet strict cross-border rules. Breaches risk penalties up to SAR 5,000,000; unlawful disclosures of sensitive data can trigger criminal liability. Courts can double penalties for repeat offenses.

Transfers are under the microscope. SDAIA's four-phase transfer risk assessment guidance pushes documented TIAs that evaluate risks, recipient controls, and national interests. SCCs or BCRs without a TIA and minimization plan are a red flag.

• PDPL + Implementing Regulations: registration, rights, breach notifications, penalties
• SDAIA Transfer Risk Assessment Guidelines: preparation, impact, transfer risk, national interests
• Cross-border mechanisms: SCCs/BCRs allowed with documented TIAs and added controls for sensitive data

What are the New Rules for Saudi Arabia 2025? Regulatory Updates and Consultations

The headline move: the draft Global AI Hub Law by the Communications, Space & Technology Commission (CST) opened for consultation Apr 14-May 14, 2025. It introduces "data embassies" and three hub models-Private, Extended, and Virtual-that let services run in Saudi Arabia under foreign legal regimes.

This changes contracting fast. Bilateral agreements, Competent Authority approvals, and operator obligations will govern where data sits, which courts can issue orders, and how termination and emergency access work.

• Private Hub: guest country's exclusive use; guest country law via bilateral agreement
• Extended Hub: operator-run hosting; guest country law via bilateral + operator agreements
• Virtual Hub: Saudi provider hosts content under a designated foreign state's law; approvals required

CST (official)

What is the Artificial Intelligence Law 2025? The Draft Global AI Hub Law and Its Effects

Think legal optionality. The draft sets hub models, a Competent Authority, and Council approvals to manage designations and interventions. It anticipates cross-jurisdictional orders, Saudi judicial cooperation, and operational wind-downs (e.g., 120-day periods for canceled virtual approvals).

Action for counsel: renegotiate audit rights, incident playbooks, and exit clauses now. Map court order conflict paths and emergency access. Infrastructure choices will set legal exposure as much as model design.

Practical Uses, Tools and Market for Legal Professionals in Saudi Arabia

AI shortens research, accelerates contract review, and supports Arabic-native assistants. Tools like Qaanoon.AI improve Saudi law research and intake. eDiscovery platforms (e.g., Relativity) remain central for large reviews and privilege workflows-tie them to PDPL and vendor checks.

Build a lean, compliant workflow: Arabic-capable models, documented TIAs for any export, privacy-by-design, and a human-in-the-loop final check. The partner sees a court-ready citation, not a raw model output.

Operational and Ethical Risks, Evidence and Admissibility in Saudi Arabia

Risk lives in data protection and auditability. Run DPIAs, appoint accountable DPOs, and wire in privacy-by-design. Use SDAIA's policies, transfer templates, and generative AI guidance to structure procurement and daily operations.

For evidence, process beats opinion. Keep immutable RoPA entries, full audit trails, vendor logs, and clear breach-notification playbooks that meet PDPL timelines.

• Data breach: implement automated detection, 72-hour notifications, retention and destruction controls
• Cross-border transfer: complete TIAs, minimize fields, pair SCCs/BCRs with audits
• Opaque outputs: use human review, DPIAs, and tamper-proof logs to support admissibility under the Law of Evidence

Contracting, Vendor Due Diligence and a Compliance Checklist for Saudi Arabia

Your DPA is the front line. Include purpose limitation, lawful basis, data-subject rights handling, RoPA, DPO contact, sub-processor approval, audit rights, and breach timelines (72 hours is common practice). Require annual attestations and third-party audits.

For cross-border processing, use SDAIA-aligned SCCs or BCRs and attach a documented TIA and minimization plan. Without them, your deployment can be paused before go-live.

• DPA aligned to PDPL: scope, legal bases, data rights, RoPA, DPO, breach notice
• Sub-processors: prior approval, flow-down terms, right to audit
• Cross-border: SCCs/BCRs + documented TIA; update records and retention schedules
• Security: technical and organizational measures, immutable logs, annual pen tests
• Incidents: 72-hour notice operations, forensic logging, regulator and data-subject templates
• Liability: clear indemnities for PDPL breaches, caps, and minimum cyber-insurance

Conclusion: Next Steps for Legal Professionals Using AI in Saudi Arabia in 2025

Treat PDPL and the draft Global AI Hub Law as operational constraints, not white papers. Map sensitive data, run TIAs linked to hub types, and harden DPAs, SCCs, and audit rights. Build a human-in-the-loop roster so outputs are court-ready.

If you need structured training, the AI Essentials for Work bootcamp is 15 weeks and costs $3,582 (early) / $3,942 (after). Pair that with a clear internal playbook: document every transfer, require immutable logs, and secure vendor attestations before rollout.

Explore practical learning paths and certifications here: AI courses by job | Popular AI certifications

Frequently Asked Questions

Who regulates AI and data in Saudi Arabia, and what guidance should lawyers follow?

SDAIA leads on strategy and regulation for data and AI, overseeing NDMO, NCAI, and NIC. Track SDAIA's AI ethics principles, generative AI guidelines (government and public), PDPL implementing regulations, and transfer risk assessment guidance. ISO 42001 alignment is influencing procurement and compliance expectations.

What are the PDPL cross-border rules and the penalties?

PDPL requires controller registration, DPOs in many cases, data-subject rights, RoPA, and strict transfer controls. SDAIA's four-phase framework makes TIAs essential, with SCCs or BCRs permitted only alongside TIAs and recipient controls. Penalties can reach SAR 5,000,000; unlawful disclosure of sensitive data can bring criminal sanctions, and repeat offenses may see penalties doubled.

What is the draft Global AI Hub Law and how do hubs change risk?

CST's draft defines Private, Extended, and Virtual hubs that allow hosting in KSA under foreign legal regimes. Expect cross-jurisdiction orders, Competent Authority oversight, and wind-down windows (e.g., 120 days for canceled virtual approvals). Contracts, audits, and incident playbooks need cross-border logic built in.

What contracts and controls should be in place before deploying AI?

Use a PDPL-aligned DPA with sub-processor controls, audit rights, and 72-hour breach commitments. For exports, attach SCCs/BCRs plus a documented TIA and minimization plan. Operationalize DPIAs, immutable logs, vendor attestations, regular audits, cyber-insurance, and clear indemnities and liability limits. These measures convert AI outputs into defensible, court-ready evidence.

How should legal professionals upskill for compliant AI use?

Focus on prompt craft, tool workflows, compliance-aware processes, and procurement due diligence. A 15-week AI Essentials for Work program builds these skills efficiently. For additional structured options, see Complete AI Training.