On 8 October 2026 Legislative Decree No 179 of 7 October 2026 was published in the Official Gazette; it aligns national legislation with Regulation (EU) 2024/1689, the AI Act, and enters into force on 23 October 2026 (Official Gazette (Gazzetta Ufficiale)). Chapter III concerns AI in training pathways, in the professions and in employment; Article 47 is addressed directly to professionals, implementing the delegation criterion in Article 24(2)(f) of Law No 132 of 23 September 2025 (Normattiva). Competence in AI thus becomes part of the training obligations of the professions, rather than being left to individual choice. We consider it useful to read the provision together with the instruments that already exist to make that competence verifiable: the certification of persons under accreditation and the twelve professional AI profiles defined by UNI 11621-8.
The training obligation of professional orders: three content areas and six months for the regulations
Article 47(1) provides that the initial professional training and continuing education courses run by professional orders “include literacy and training pathways in the use of artificial intelligence systems” (our translation). Paragraph 2 sets three content areas: technical aspects, concerning the functioning, “including with regard to querying and instruction techniques”, the potential and the limits of the systems used in the relevant professional sector; legal aspects, with particular regard to the AI Act and the national implementing provisions; deontological aspects, concerning the professional’s responsibilities, the duties to inform the client and the anthropocentric principle in Article 1(1) of Law No 132/2025. Paragraph 3 provides for “a minimum number of hours for each assessment period of continuing education”, without quantifying it, and refers the determination of content, delivery methods and frequency to the procedures in paragraph 5 (Official Gazette (Gazzetta Ufficiale)).
Within six months of the decree’s entry into force, the national councils of the professional orders and colleges, or the bodies that regulate training for the profession, are to adapt their regulations or organisational acts in accordance with the sectoral procedures, “including, where provided for, obtaining the opinion or approval of the supervising authority”. For the health professions, an agreement in the State-Regions Conference makes provision within the same time limit (paragraph 6); Article 51 also entrusts the National Commission for Continuing Education (Commissione nazionale per la formazione continua) with defining, within six months, “a specific percentage of the individual three-year training obligation” to be devoted to these pathways, a quantification criterion that Article 47 does not offer the other orders (see NicFab). Article 43(2) adds that literacy and training activities aimed at professionals “may be carried out by professional orders or trade associations, including under agreements with universities, public research bodies and AFAM institutions”, the latter being the higher education institutions for art, music and dance. The addressees of the obligation are the orders; we consider, however, that the minimum number of hours directly affects the training requirement of each registered member.
Non-regulated professions: grafting onto the system of Law No 4/2013
Article 47(4) extends the rules in paragraphs 1, 2 and 3 to the training pathways promoted by the umbrella organisations of associations (forme aggregative) referred to in Article 3 of Law No 4 of 14 January 2013, “where, in relation to the sector of activity and the specific features of the professional activity, issues linked to the use of artificial intelligence systems are relevant”. The last sentence of paragraph 5 provides that the umbrella organisations, also through the professional associations, “make known the training pathways and the arrangements for verifying actual fulfilment of the obligation, pursuant to Article 5 of Law No 4 of 2013” (Official Gazette (Gazzetta Ufficiale)).
The system referred to has a precise shape (Official Gazette (Gazzetta Ufficiale)). Professional associations, private and voluntary, promote the lifelong training of their members (Article 2); umbrella organisations have functions of promotion and qualification and, on a mandate from the associations, may monitor their conduct in order to verify professional and quality standards (Article 3). Among the elements whose full knowability the associations ensure are the obligation of constant professional updating and the “provision of suitable tools to verify actual fulfilment of that obligation” (Article 5(1)(e); our translation). The law promotes voluntary self-regulation and bases the qualification of the professional service on conformity with UNI technical standards (Article 6). Associations may issue their members a certificate, which is not a requirement for practising and also states any accredited certification of conformity with the UNI technical standard (Article 7). Bodies accredited under Regulation (EC) No 765/2008 may issue the certificate of conformity with the UNI standard at the request of the individual professional, even one not registered with any association (Article 9(2)). The decree grafts a training obligation onto a framework built around voluntary membership and qualification through technical standards.
Accredited certification of competences: ISO/IEC 17024 and the profiles of UNI 11621-8
The verification referred to in paragraph 5 concerns fulfilment of the obligation, that is, participation in the pathways; Article 47 does not mention the certification of competences. The instrument that measures competence, rather than attendance, is the certification of persons under ISO/IEC 17024, whose architecture and new features we described in our analysis of how professional competences are certified under ISO/IEC 17024:2026. The third edition was published in March 2026, and the public ISO page notes that the revision also addresses AI-based assessment tools (ISO). As we explained there, an accredited certificate attests a competence assessed by an independent third party, which is itself verified: this is what distinguishes it from a certificate of attendance.
UNI 11621-8:2026, in force since 30 April 2026, defines the “third-generation professional role profiles relating to the activities carried out in the field of Artificial Intelligence (AI)” (our translation) (UNI). In our overview of the standard we noted that its scope covers those who design, develop, integrate and manage AI systems, excluding the mere user of existing tools. Certification under UNI 11621-8 is not the instrument for demonstrating the literacy in use required by Article 47. It serves those who have made AI the subject matter of their activity: consider the AI Consultant profile under UNI 11621-8, who supports organisations in integrating AI, or the Chief AI Officer, the AI governance role described in the same standard. For these profiles Law No 4 of 2013 already offers the pathway: UNI technical standard, certificate from an accredited body, possible mention in the association’s certificate. Two distinct levels follow, literacy in use, mandatory for members of professional orders and, within the limits of paragraph 4, for the non-regulated professions, and specialist competence, verifiable through accredited certification: keeping them separate avoids treating a certificate of attendance as proof of specialist competence.
Critical aspects: the reference to Article 4 of the AI Act, fair compensation and the quality of training
The first issue is coordination with European law. Article 46(1), concerning the staff of the justice administration, provides that the pathways “ensure compliance with the literacy obligations laid down in Article 4 of the AI Regulation” (Official Gazette (Gazzetta Ufficiale)). That Article, in its original version, required providers and deployers to take measures “to ensure, to their best extent, a sufficient level of AI literacy” (European Commission). Regulation (EU) 2026/1744, the Digital Omnibus on AI, in force since 27 July 2026, replaced it: providers and deployers “shall take measures to support the development of AI literacy” and “This obligation does not require providers or deployers to guarantee any specific level of AI literacy of any individual” (EUR-Lex). As Nicola Fabiano observes, the rewording did not turn an obligation of result into an obligation of means, because the original text already required measures to be taken, but it removed the benchmark of a “sufficient level” (NicFab): in our view the reference in Article 46 now points to an obligation without a threshold. The decree does not refer to Regulation 2026/1744, and the wording of Article 46 reflects the language that preceded the rewriting of Article 4 of the AI Act in the Digital Omnibus, which we examined at the time. Article 47, by contrast, contains no reference to Article 4: in our view the obligation for the professions has an autonomous national basis and is unaffected by the European lightening.
The second issue is Article 49: the use of AI systems by the professional “may entail an adjustment of fair compensation” according to parameters that take into account “the risk classification of the artificial intelligence system used”, to be defined within twelve months by supplementing the decrees on parameters. Under the AI Act, classification as high-risk depends on the intended purpose, that is, the use of the system intended by the provider (Article 3, point (12)), and on falling within the cases in Article 6, which include the systems listed in Annex III (Article 6(2)) (European Commission). In our view most of the tools used in ordinary professional activity are not high-risk systems, so the criterion risks drawing few distinctions; moreover, the text does not indicate in which direction the adjustment is to operate.
The third issue concerns content and oversight. Beyond the three areas in paragraph 2, Article 47 sets no learning outcomes, assessment tests or requirements for trainers, and leaves the number of hours to the regulations of each profession. For the orders, oversight passes through the sectoral procedures and, where provided for, the supervising authority; for the non-regulated professions the instrument indicated is knowability under Article 5 of Law No 4 of 2013, alongside the supervision that Article 10 of the same law entrusts to the Ministry of Economic Development. None of the provisions examined entrusts an independent third party with verifying the quality of individual pathways.
Conclusions
The orders must adapt their regulations within six months of the decree’s entry into force, defining hours, content and methods; the umbrella organisations and associations of the non-regulated professions must make known the pathways and the verification arrangements where AI is relevant to the sector; within twelve months the decrees on parameters referred to in Article 49 must be supplemented. What is missing is a uniform minimum quantification, quality criteria for training and the coordination of Article 46 with the new Article 4 of the AI Act. We consider it advisable for orders and associations to provide, already in their regulations, for a final assessment of learning, and for professionals whose activity consists in designing, integrating or governing AI systems to consider accredited certification against the profiles of UNI 11621-8: mandatory training ensures a common foundation, while specialist competence is documented through accredited certification.
Author: Valentina Grazia Sapuppo
