Complying with Italy’s AI law

The three Italian texts, briefly

• Law 132/2025

  Italy’s AI law supplements the AI Act with principles for healthcare, employment and the professions, and names the national authorities (AgID and ACN). It does not replace the Regulation and does not classify risk. Law 132/2025 and AI in healthcare.

• Legislative Decree 179/2026 — Article 41

  AI-assisted decisions about staff must be taken by a natural person with effective authority to decide, and the worker is entitled to an explanation.

• Legislative Decree 179/2026 — Article 42

  AI enters the workplace risk assessment (DVR) under Legislative Decree 81/2008 when it affects work organisation, pace or safety, together with information and training for workers.

• Legislative Decree 160/2026

  Adds a new AI-related predicate offence to Legislative Decree 231/2001. For companies, the organisational model under 231/2001 has to be reviewed.

Each text is analysed article by article, with official sources, in the Normativa section (in Italian).

What the work covers

• Map of AI touchpoints with staff

  Recruitment, shifts, task allocation, appraisals, disciplinary measures: where an AI system intervenes, how much weight it carries and who signs the final decision.

• Decision and explanation procedure

  Who holds effective authority, how it is exercised, how the explanation owed to the worker is recorded — written so that HR can actually follow it.

• Risk assessment update

  With the employer, the health and safety officer and the occupational physician: which AI systems enter the DVR, which measures, which training.

• Model 231 review

  With the supervisory body and the company’s lawyers: AI-related risk areas, control protocols, reporting flows.

• Alignment with the AI Act and GDPR

  The same systems also fall under the AI Act (role, risk class, literacy) and the GDPR (automated decisions, information duties). One inventory, several regimes.

• Evidence

  Records showing who decided, on what basis and with which system — what an employment dispute, an inspection or the supervisory body will ask for.

How this fits with the AI Act

The Italian rules add to the Regulation; they do not replace it. A recruitment system, for example, is classified under the AI Act and must also respect Article 41 of Legislative Decree 179/2026 in final decisions. That is why the work runs on a single inventory of systems.

The full service is described under AI Act consulting in Italy; sector pages cover healthcare and pharmacy and logistics and manufacturing.

Frequently asked questions

Does Law 132/2025 replace the AI Act in Italy?

No. The AI Act is an EU regulation and applies directly. Law 132/2025 supplements it with sector principles and names the national authorities; risk classification remains that of the Regulation.

What does Legislative Decree 179/2026 change for decisions about staff?

Article 41 requires AI-assisted decisions about the employment relationship to be taken by a natural person with effective authority, and the worker to receive an explanation. Who decides, and on what basis, has to be documented — including when the tool is bought from a vendor.

Does AI have to be in the workplace risk assessment?

Yes, when an AI system affects work organisation, pace or safety-relevant decisions: Article 42 of Legislative Decree 179/2026 brings it into the risk assessment under Legislative Decree 81/2008, together with worker training.

Why does Legislative Decree 160/2026 matter for Model 231?

Because it adds an AI-related predicate offence to Legislative Decree 231/2001. A company that wants to rely on its 231 model has to have updated it for that risk.

Do I need a lawyer or a technical consultant?

Usually both. Dynamics Consulting handles the technical and organisational side — systems, procedures, evidence — and prepares the material for the organisation’s lawyers, who remain responsible for legal opinions.