Italy’s National AI Law Becomes Operational for Employers

LEGISLATIVE UPDATE | Law no. 132/2025

Law no. 132/2025 of 23 September 2025 entered into force on 10 October 2025, establishing Italian principles and institutional arrangements for artificial intelligence. Employment is one of the areas in which human dignity, transparency and oversight have immediate practical importance.

The law operates alongside the EU AI Act (Regulation (EU) 2024/1689), data-protection rules, anti-discrimination legislation and Article 4 of the Workers’ Statute. The same tool may therefore trigger several assessments: whether it is high-risk, whether personal data are processed lawfully, whether it monitors employees and whether its output produces unequal effects.

A multinational may procure an AI service outside Italy and deploy it through a global platform. The local employer nevertheless needs to understand how the system ranks candidates, flags performance or influences employment decisions. Contractual assurances from the supplier do not replace local due diligence.

Employers should establish an AI register, require impact information from vendors and give HR the authority to suspend a tool that has not passed employment review. Decision-makers must be trained to challenge outputs and to record the independent reasons for consequential decisions.

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