The European Data Protection Board (EDPB) has published a statement setting out the data protection challenges raised by smart glasses, devices that typically combine cameras, microphones and other sensors with features such as recording, live streaming or real-time analysis of their surroundings.
The statement is aimed at manufacturers, developers and deployers of smart glasses, as well as at individuals who may be recorded or otherwise affected by their use without having consented to it. The EDPB's concern centres on the continuous, often inconspicuous, collection of personal data about bystanders who are not the device's user.
Smart glasses that incorporate AI-based functions, such as facial recognition, object identification or audio transcription, may also fall within scope of the EU AI Act, depending on how those functions are used. Some use cases, for example remote biometric identification in publicly accessible spaces, attract specific restrictions and conditions under the Act.
The EDPB's statement focuses on data protection obligations rather than the AI Act directly, but the two frameworks are likely to overlap for any organisation developing or deploying AI-enabled wearables. Data protection impact assessments and AI Act conformity processes will often need to be considered together rather than in isolation.
Organisations building or integrating smart glasses technology should, as a compliance matter, review how image, audio and biometric data are captured, processed and retained, and whether any embedded AI functions trigger additional obligations under the AI Act.
For providers and deployers already mapping their AI Act compliance programmes, this statement is a reminder that wearable and ambient AI devices sit at the intersection of several regulatory regimes, and that data protection authorities are actively scrutinising this category of product.