REGULATORY UPDATE | Italian Observatory on AI Systems in the Workplace
In March 2026, by means of Ministerial Decrees nos. 28, 29 and 30 of 6 and 9 March 2026, the Italian Ministry of Labour appointed the principal bodies of the Observatory on the adoption of artificial intelligence systems in the workplace, including its steering committee, ethics commission and social-partner consultation body. The appointments are institutional, but the message for employers is practical: workplace AI is moving from a technology project to a regulated employment issue.
AI may already be present in recruitment platforms, CV screening, shift allocation, productivity monitoring, performance scoring, fraud detection and decisions about training or promotion. In many organisations, HR does not control every tool that uses automated or predictive functions. Systems may be introduced by procurement, IT, a global parent company or an external payroll and workforce-management provider.
That fragmented adoption creates legal risk. Employment decisions must remain compatible with anti-discrimination rules, data-protection principles and the Italian restrictions on remote monitoring. Under Article 4 of the Workers’ Statute, tools capable of monitoring employees may require a trade-union agreement or administrative authorisation unless they fall within a statutory exception. Transparency duties may also arise when automated decision-making or monitoring systems materially affect the employment relationship.
The EU AI Act, Regulation 2024/1689. adds a further layer. Certain employment-related systems are classified as high-risk, and prohibited practices cannot be treated as acceptable merely because a supplier offers them. Human oversight must be real: asking a manager to approve a result is not enough if the manager cannot understand, challenge or depart from the system’s recommendation.
International employers should begin with an inventory of workplace AI, identifying the purpose, data, vendor, affected employees and decision produced by each system. Legal review should take place before procurement or rollout. Once a tool has shaped working practices, redesigning the process, communications and employee-relations strategy is usually more difficult than building appropriate safeguards at the outset.