1. REGULATIONS AND DEFINITION

The new Law no. 132, entered into force on October 10^th, 2025 and aims at promoting the correct, transparent, and responsible use of artificial intelligence (AI) in the workplace.

According to EU Regulation No. 2024/1689, the term “‘AI system’ means a machine-based system that is designed to operate with varying levels of autonomy and that may exhibit adaptiveness after deployment, and that, for explicit or implicit objectives, infers, from the input it receives, how to generate outputs such as predictions, content, recommendations, or decisions that can influence physical or virtual environments”

The new obligation to provide information on the use of AI also aims to expand the range of information of the second type (‘digital information’ as provided for in Article 1 bis of Legislative Decree 152 of 1997), which employers and clients, both public and private, are required to provide when they use it.

2. INTERESTED PARTIES

Employers and clients must inform workers and collaborators about the use of artificial intelligence.

Employers and clients must inform workers about the use of artificial intelligence in the management of the employment relationship, bearing in mind that its use in the workplace must be safe, reliable, transparent and cannot be carried out in a manner that is contrary to human dignity or violates the confidentiality of personal data.

This obligation, which applies to both the private and public sectors, arises if and when artificial intelligence is used to obtain information relevant to recruitment or job assignment, the management or termination of the employment relationship, the assignment of tasks or duties, as well as for the monitoring, evaluation, performance and fulfilment of contractual obligations of employees and collaborators.

3. COMPLIANCE WITH THE INFORMATION REQUIREMENT

The employer and the client are required to provide the above information on the use of AI in a transparent manner, using clear, simple, comprehensive and legible language.

Information on the use of AI must be provided in writing, preferably in the employment contract, letter of appointment or professional mandate, or in company regulations or as a supplement to existing company regulations.

Information on the use of AI must also be communicated to the relevant RSA or RSU (trade union representatives), or, failing that, to the local offices of the trade unions that are comparatively more representative at national level.

Based on the date of introduction of AI in the employment relationship at the moment, and pending more precise and detailed instructions from the National Labor Inspectorate we may have different scenarios:

• AI already in use on 10 October 2025:

–    in the case of new hires/assignments, employers and clients are required to provide information on the use of AI together with other information regarding the employment relationship before the start of the same.

–    in the case of existing employees, employers and clients are obliged to provide information upon request by the interested parties, in writing, within 30 days.

• AI introduced after 10 October 2025:

–    employers and clients will be obliged to inform all employees, with 24 hours’ notice for existing employees.

Finally, it should be noted that, in the case of professional activities, AI systems may only be used for activities that are instrumental and supportive to an intellectual profession. This means that, in any intellectual service, the contribution of AI must remain ancillary and auxiliary to the intellectual work of the professional, who retains the primary role and responsibility.

UHY Associati remains available for further clarification on this matter and to assist companies in drafting specific dispositions or company regulations on the use of artificial intelligence.

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