Since October 2025, Italy’s Law 132/2025 has been in force, and its Articles 10 and 11 introduce information obligations toward employees when a company uses AI systems that affect work organisation. For many Italian SMEs this obligation gets less attention than the EU AI Act, but it is just as concrete and already applicable today.
This article explains in practical terms what the law requires and how to start documenting it, without getting lost in legal technicalities.
What Articles 10 and 11 require
Articles 10 and 11 of L.132/2025 require, in summary, that employees be informed when a company uses AI systems that may affect their tasks, performance evaluation, or work organisation more broadly. The law has been in force since October 2025 — this is not a future obligation, it already applies today.
Why it matters for Italian SMEs
Many small and medium Italian businesses already use AI tools in HR, productivity, customer support, or marketing — often without having formalised anything toward staff. L.132/2025 asks companies to make explicit and documented what often remains informal: which AI tools are used, who is involved, and for what purposes.
Doing nothing exposes the company to a documentation risk more than a “technology” risk: the issue isn’t so much the use of AI itself, but the lack of a clear notice and evidence that employees were properly informed.
A practical checklist to get started
- Identify the AI tools used in the workplace. AI-assisted recruitment software, productivity tools with built-in AI features, monitoring or evaluation systems: make an honest, complete list.
- Identify the affected employees and roles. Which departments or roles are touched by these tools? HR, sales, production, customer support?
- Prepare an employee AI information notice. A clear, understandable document explaining which AI tools are in use and how they affect the work of the people involved.
- Keep acknowledgement evidence. A signature, an email confirmation, a read log: any form of record showing the notice was actually communicated.
- Review vendor and third-party tool use. If an external vendor introduces AI features into their tools (e.g. a CRM adding an AI assistant), assess whether the notice needs updating.
How the Compliance Pack helps
Our Compliance Pack includes a dedicated Employee Notification support module, designed to help you quickly structure this document starting from your AI inventory. It doesn’t replace personalised legal advice, but it gives you a concrete, organised starting point.
What we are not
This article, like the support we offer, is intended for readiness and documentation purposes — it is not legal advice. For complex situations (specific collective agreements, union representation, particular cases) we always recommend consulting a qualified employment or legal advisor.
This article is for general information and is not legal advice.