AI disclosure requirements in Italy: what applies since 2 August 2026
The EU AI Act's transparency obligations are a Union-wide regulation, so the substance is the same in Italy as everywhere in the EU: from 2 August 2026, AI systems that interact with people must disclose they're AI, synthetic media must carry machine-readable marking, and deepfakes and certain AI-generated public-interest text must be labeled. What differs country by country is who enforces it, in what language your users encounter it, and how quickly complaints turn into questions.
Enforcement in Italy
Italy was the first EU member state with a broad national AI law: Law No. 132/2025, in force since 10 October 2025. It designates AgID (Agency for Digital Italy) as notifying authority and the ACN (National Cybersecurity Agency) as market surveillance authority with inspection and sanctioning powers, the pairing that will supervise Article 50 duties for most operators. On 10 June 2026 the Council of Ministers gave preliminary approval to two implementing legislative decrees, the first of which details the national authorities' powers. Article 50 applies from 2 August 2026 with the EU penalty ceiling of €15M or 3% of worldwide turnover, and Law 132/2025 layers national provisions, including criminal-law measures around harmful deepfakes, on top of the EU framework.
The four duties, as they show up on your site
- Article 50(1): chatbot disclosure
- Any AI system interacting with visitors must make that clear no later than the first interaction, in a clear and distinguishable way.A line in your terms doesn't satisfy it.
- Article 50(2): machine-readable marking
- AI-generated audio, images, video, and text must be marked in a machine-readable, detectable format.For generative systems already on the market before 2 Aug 2026, this specific duty has a transition until 2 Dec 2026; the rest does not.
- Article 50(3): emotion recognition & biometric categorisation
- People exposed must be informed the system is operating.
- Article 50(4): deepfake and AI-text labels
- Visible disclosure for deepfakes, and for AI-generated or manipulated text published to inform the public on matters of public interest.
Italy-specific practicalities
- Italy's supervisor is a cybersecurity agency (ACN), expect technically literate inspection: machine-readable marking (50(2)) and provenance metadata are checks it is equipped to run, not paperwork it will skim
- Law 132/2025 introduced criminal liability around malicious deepfakes, synthetic media labelling (50(4)) carries sharper national teeth in Italy than in most member states
- The implementing decrees approved in June 2026 are filling in procedure; watch AgID/ACN guidance through 2026 rather than assuming the rulebook is finished
- Keep the Italian-language first-interaction screenshot in your evidence file; a notice your Italian users can't read is a weak notice
Disclosure language should match your user-facing language. For a site serving Italy in Italian, a first-message line such as "Stai chattando con un assistente IA" (you're chatting with an AI assistant) is the pattern to aim for, at first interaction, not in the note legali.
Common questions
Italy has its own AI law, do we comply with that or with Article 50?
Both, and they mostly point the same way. Law 132/2025 designates who supervises in Italy (AgID and ACN) and adds national measures such as criminal provisions on harmful deepfakes; the transparency duties themselves come from Article 50 of the EU regulation and apply from 2 August 2026. Evidence that your disclosures were live covers you under both frameworks.
Who would inspect us in Italy?
The ACN (Agenzia per la Cybersicurezza Nazionale) holds market surveillance, inspection and sanctioning powers under Law 132/2025, with AgID as the notifying authority. The June 2026 implementing decrees flesh out their procedures, and because the ACN is a technical agency, checks like machine-readable marking are realistic inspection items, not theoretical ones.