REGULATORY UPDATE | Ministerial Decree no. 180/2025
On 17 December 2025, the Ministry of Labour adopted guidelines for implementing artificial intelligence in the world of work. The measure formed part of Italy’s national response to the EU AI Act and to Law no. 132/2025.
The regulatory direction is clear: workplace AI must be introduced with attention to human oversight, dignity, data protection and the employment consequences of automated decisions. Recruitment, performance scoring, scheduling and monitoring are particularly sensitive because they may affect access to work or the conditions under which it is performed.
Multinational employers often deploy tools selected centrally, but Italian employment rules still apply locally. A vendor assurance or group-level AI policy does not by itself resolve questions under the Workers’ Statute, the GDPR, anti-discrimination law or information duties towards employees and unions.
Before deployment, the Italian employer should document the purpose and data flows of the tool, assess monitoring implications, define meaningful human review and prepare local information. Existing tools should be audited rather than assumed to fall outside the rules because they were introduced before the guidance.
