Italy’s newly effective artificial intelligence law means U.S. companies operating in Italy or serving Italian customers must now meet European Union Artificial Intelligence Act obligations as well as Italy-specific requirements, creating a dual compliance burden. The law brings foreign employers, platforms and service providers squarely within its scope if they deploy artificial intelligence tools in Italian workplaces or offer artificial intelligence driven services to Italian users. Companies that previously focused only on European Union level compliance must now track both the European Union Artificial Intelligence Act framework and Italy’s national implementation choices.
The new regime is characterized by immediately enforceable criminal penalties that significantly raise enforcement risk. The presence of criminal exposure is designed to deter noncompliance with obligations around the development, deployment and governance of high risk artificial intelligence systems. Organizations using artificial intelligence for worker surveillance, automated decision making in hiring and firing, or other sensitive employment functions must carefully map their tools to the European Union Artificial Intelligence Act risk categories and Italy’s implementing rules, and they must ensure that documentation, testing and human oversight measures meet the higher of the applicable standards. Noncompliance can now trigger both administrative and criminal consequences within Italy’s jurisdiction.
Italy’s law also introduces designated national authorities and sector specific mandates that interact with the European Union Artificial Intelligence Act architecture. National regulators are tasked with supervision, guidance and enforcement, which means multinational employers may face direct engagement with Italian agencies in addition to European Union institutions. Sector rules are expected to be particularly important for industries that make intensive use of workplace monitoring, algorithmic management or automated performance evaluation. U.S. companies are encouraged to inventory their artificial intelligence use cases touching Italian employees or customers, align governance policies with the combined European Union and Italian requirements, and prepare for more frequent audits, investigations and potential litigation arising from artificial intelligence use in employment and related contexts.
