Italy Enacts National AI Law No. 132/2025 Aligned with EU AI Act, Effective October 2025

Italy enacted Legge 23 settembre 2025, n. 132 ("Disposizioni e deleghe al Governo in materia di intelligenza artificiale"), which entered into force on 10 October 2025. The law establishes a national governance structure for the development, deployment, and supervision of AI systems in Italy. It operates as a framework law intended to complement, not replace, Regulation (EU) 2024/1689 (EU AI Act), which entered into force on 1 August 2024 and applies directly throughout EU member states. The Italian law explicitly requires that its provisions be interpreted in conformity with the AI Act, ensuring full alignment with the European regulatory architecture.

Law No. 132/2025 designates two existing agencies as national competent authorities under Article 19 of the AI Act: (i) the Agenzia per l'Italia Digitale (AgID), responsible for technical governance, conformity assessment body accreditation, and certification mechanisms; and (ii) the Agenzia per la Cybersicurezza Nazionale (ACN), entrusted with market surveillance, enforcement powers, inspection activities, and the exercise of sanctioning powers for non-compliance. The law sets foundational principles including human oversight, algorithmic transparency, prevention of discriminatory outcomes, and proportionality. It identifies regulated sectors including public administration, healthcare, the justice system, employment, regulated professions, and intellectual property.

Providers and deployers of AI systems operating in Italy must now comply with both the directly applicable EU AI Act and the Italian implementing structure under Law No. 132/2025. AI systems deployed in critical sectors — public administration, healthcare, justice, and employment — face additional sector-specific safeguards. Companies using AI-based automated decision tools in Italian workplaces must implement worker protection safeguards. Operators of AI-enabled judicial assistance tools must ensure that such tools support, but do not substitute, judicial discretion. This dual-layer compliance requirement applies to any entity established in Italy or whose AI system produces effects in Italy.

Law No. 132/2025 grants the Government power to adopt implementing legislative decrees within twelve months from entry into force (by October 10, 2026) to detail enforcement mechanisms, administrative sanctions, liability regimes, and sector-specific regulatory rules. The law also provides for specific additional protections for minors under 14 years old with respect to AI systems — a provision that goes beyond the EU AI Act's own text. ACN is designated to complete registration of "NIS obliged" entities and their incident notification obligations by October 2026 under Italy's implementation of Directive (EU) 2022/2555 (NIS2) through Legislative Decree No. 138/2024.

Source: Legge 23 settembre 2025, n. 132, "Disposizioni e deleghe al Governo in materia di intelligenza artificiale," Gazzetta Ufficiale n. 223 del 25-09-2025, entered into force 10/10/2025. Available at: https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:legge:2025-09-23;132. EU AI Act: Regulation (EU) 2024/1689, OJ L 2024/1689, 12.07.2024. Confirmed March 12, 2026.

The information provided is not legal, tax, investment, or accounting advice and should not be used as such. It is for discussion purposes only. Seek guidance from your own legal counsel and advisors on any matters. The views presented are those of the author and not any other individual or organization. Some parts of the text may be automatically generated. The author of this material makes no guarantees or warranties about the accuracy or completeness of the information.