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Italy's AI framework: Operationalizing the EU AI Act

As member states operationalize the EU AI Act, Italy has emerged as one of the first jurisdictions to establish a complete national AI regulatory architecture.

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Contributors:

Giovanna Fragala

AIGP, CIPP/A, CIPP/E

Senior Legal Counsel, Privacy and AI

The integration of the EU artificial intelligence framework into national legal frameworks marks a pivotal phase in AI regulation and governance. As member states operationalize the EU AI Act, Italy has emerged as one of the first jurisdictions to establish a complete national AI regulatory architecture. Italy's AI framework is built on Law No. 132, which entered into force in October 2025 and lays down general principles, sector-specific rules, governance models and public investment strategies for AI systems. It is also supported by subsequent implementing decrees, including Legislative Decree No. 160 of 9 Sept. 2026, which regulates police use of AI, introduces statutory criminal sanctions, expands corporate administrative liability and establishes specialized civil litigation mechanisms. The legislative decree will enter into force by 30 Sept. 2026. 

Italy's AI framework represents one of the first national regulatory initiatives to assign criminal and organizational significance to the governance of AI systems. The legislature's focus extends not only to the technological security of the tools adopted but also to a company's ability to ensure adequate controls, human supervision and risk management. Particularly noteworthy are the new evidentiary rules introduced by Article 17, which strengthen the principle of accountability. Companies must be able to demonstrate in concrete terms that their safeguards are functioning correctly, through comprehensive, up-to-date documentation that can be readily produced in the event of a dispute. 

Italy's AI law: institutional governance and sectoral directives

Contributors:

Giovanna Fragala

AIGP, CIPP/A, CIPP/E

Senior Legal Counsel, Privacy and AI

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