Insights

Transparency Obligations for Law Firms Using AI: Compliance with EU Regulation 2024/1689 and Law 132/2025

3 min read · Updated July 2026 · Editorial oversight: Avv. Federico Papa

The adoption of artificial intelligence (AI) systems within Italian law firms is undergoing a decisive regulatory transformation. The regulatory framework is now defined by the intersection of Regulation (EU) 2024/1689, known as the AI Act, and national implementing legislation, Law 132/2025. These provisions introduce strict transparency obligations aimed at ensuring that technological integration does not compromise client protection or the integrity of professional services. The core of the legislation rests on balancing automated tools' innovation with the duty of disclosure, requiring professionals to conduct a thorough review of internal procedures and retainer agreements.

In brief

The integration of AI in law firms is now governed by EU Regulation 2024/1689 and Law 132/2025. This analysis explores disclosure obligations toward clients, transparency in generated content, and professional civil liability. Through the human reserve principle, lawmakers impose strict oversight, defining the boundaries between algorithmic assistance and professional drafting, with special focus on privacy protection and the duty of care required by the Code of Ethics.

  1. 1.

    The Facts: Combined Regulatory Framework

    Article 50 of Regulation (EU) 2024/1689 imposes the obligation to inform natural persons when interacting with AI systems, such as chatbots. Simultaneously, Law 132/2025 designates AgID and ACN as supervisory authorities, introducing in Article 7 a specific obligation for lawyers to disclose the use of decision-making or generative AI in the engagement letter.

  2. 2.

    Interpretations: Assistant or Substitute?

    The Italian National Bar Council (CNF) interprets AI as a mere assistant, never a substitute for the professional, integrating these obligations into the Code of Ethics. Legal scholars debate whether text labeling obligations apply only to public content or also to legal filings, where the lawyer's intellectual authorship remains paramount.

  3. 3.

    Advantages of Transparency (PRO)

    Clarity regarding AI use protects the client and reduces reputational risks related to potential software errors, such as hallucinations. Transparent communication increases accountability and facilitates the traceability of professional decisions in the event of liability disputes.

  4. 4.

    Critical Issues and Disadvantages (CONTRO)

    Compliance involves administrative burdens that weigh heavily on smaller law firms. Furthermore, there is a risk that the perceived value of legal services may diminish if the client attributes the outcome to the software rather than to the final human validation.

  5. Apply this research directly with edit.legal

    Legal research and drafting with citations checked against official databases. Try edit.legal for free, no credit card.

    Try edit.legal
    5.

    Practical Implications: From the Letter to the Register

    Firms must update engagement letters and, in larger organizations, establish an AI activity register. Law 132/2025 also requires the person responsible for AI systems to possess certified skills to monitor bias and malfunctions.

  6. 6.

    Controversial Points: The Relevance Threshold

    The threshold beyond which AI use requires mandatory disclosure is not yet defined: are search tools or advanced grammar checkers equated with full document drafting systems? The lack of regulatory clarity creates operational uncertainty.

  7. 7.

    Liability: The Human Reserve

    Law 132/2025 reaffirms that using AI does not exempt the lawyer from civil liability. The human reserve principle governs the duty of care under Article 1176 of the Civil Code, holding the professional directly liable even for artificially generated content.

  8. 8.

    What to Expect: Towards Standardization

    The issuance of specific guidelines by AgID and the Data Protection Authority is expected to clarify the use of Large Language Models (LLM). Law firms will need to invest in training to ensure that transparency becomes a hallmark of professional quality rather than a mere administrative requirement.

References: Regolamento (UE) 2024/1689Legge 132/2025Articolo 1176 c.c.Articolo 26 Codice Deontologico ForenseArticolo 50 AI Act

Avv. Federico Papa
Editorial oversight: Avv. Federico Papa·ICAMContent drafted with AI support and subject to editorial source checks. Despite these controls, inaccuracies may remain: reports and rectification requests are welcome. Report a correction

Frequently asked questions

Must a lawyer always declare the use of AI to the client?

Yes, pursuant to Article 7 of Law 132/2025, any reliance on AI systems must be expressly indicated in the engagement letter.

Does declaring the use of AI limit professional liability?

No. The human reserve principle established by Law 132/2025 and Article 1176 of the Civil Code confirm that the lawyer remains fully responsible for the accuracy of filings, regardless of the technologies used.

What are the risks for a firm that fails to correctly inform about chatbot use?

The firm may face administrative sanctions imposed by competent national authorities (AgID and ACN) for violating Article 50 of the AI Act, in addition to potential ethical disciplinary actions and privacy law violations.

Verified legal research and drafting with edit.legal

Legal research and drafting with citations checked against official databases. edit.legal is free to try, no credit card.

Try edit.legal for free