AI Smart Glasses: Risk Management Realities for a Rapidly Expanding Technology

According to an article by Joseph J. Lazzarotti of Jackson Lewis, AI smart glasses have shifted decisively into the mainstream, driven by explosive market growth and expanding enterprise use. Global shipments surged 210% in 2024, led by Meta’s Ray-Ban products, alongside industrial and developer-focused devices. These tools can record audio and video, analyze visuals in real time, generate transcripts and summaries, and transmit data to cloud-based AI systems, often without obvious notice. For risk management teams, this combination of ubiquity and invisibility creates immediate compliance and governance concerns.

Lazzarotti explains that the core risk centers on biometric data. AI smart glasses may capture facial geometry, voiceprints, eye movements, and other identifiers that trigger heightened obligations under laws such as Illinois’ Biometric Information Privacy Act, California’s Consumer Privacy Act, and the EU’s GDPR. He points to the 2024 Charlotte Tilbury settlement, which treated virtual try-on facial analysis as biometric data collection, as a warning sign for wearable technologies that process images or voices. Use cases span retail, healthcare, security, and industrial settings, where employees, customers, or bystanders may be recorded without proper consent.

The financial exposure is significant. Lazzarotti notes that BIPA allows statutory damages of $1,000 to $5,000 per violation, and large-scale cases like the 2025 Clearview AI settlement demonstrate how liability can reach tens of millions of dollars. Similar biometric regimes are spreading across states and cities, increasing complexity.

For risk leaders, deploying AI smart glasses requires formal policies, privacy impact assessments, technical safeguards, vendor due diligence, training, and clear accountability. Lazzarotti concludes that organizations can capture the productivity benefits of AI smart glasses, but only if they manage biometric, surveillance, and regulatory risks with discipline and foresight.