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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 innovation with disclosure duties, requiring professionals to conduct a thorough review of internal procedures and client engagement documentation.

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 liability. Through the human reserve principle, lawmakers impose strict oversight, defining the boundaries between algorithmic assistance and professional drafting. Special focus is placed on privacy protection and the duty of care required by the Code of Ethics, addressing both accountability benefits and compliance costs.

  1. 1.

    The Facts: The 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 rather than 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 extend to court filings, where the lawyer's intellectual authorship remains primary.

  3. 3.

    Advantages of Transparency (PRO)

    Clarity regarding AI use protects the client and mitigates reputational risks associated with potential software errors, such as so-called hallucinations. Transparent communication enhances accountability and facilitates the traceability of professional decisions in liability disputes.

  4. 4.

    Critical Issues and Disadvantages (CONTRO)

    Compliance involves an administrative burden that weighs especially heavily on smaller firms. Furthermore, there is a risk that the perceived value of legal services may decrease if the client attributes the outcome to the software rather than to human professional assessment.

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    5.

    Practical Implications: From the Engagement Letter to the Register

    Law firms must update engagement letters and, in more structured 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 disclosure is not yet defined: are research tools or advanced grammar checkers equated with full drafting systems? The lack of specific regulatory distinction creates operational uncertainty.

  7. 7.

    Liability: The Human Reserve Principle

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

  8. 8.

    What to Expect: Towards Standardization

    Specific guidelines are expected from AgID and the Data Protection Authority to clarify the use of Large Language Models (LLMs). Law firms will need to invest in training to ensure transparency becomes a benchmark of professional quality rather than a mere formal 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·ICAM

Frequently asked questions

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

Yes, under Article 7 of Law 132/2025, any assistance from AI systems must be expressly declared in the professional 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 court filings and legal documents, regardless of the technology used.

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

The firm may face administrative sanctions imposed by competent national authorities (AgID/ACN) for violating Article 50 of the AI Act, as well as potential ethical misconduct complaints and breaches of privacy regulations.

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