Italian Law No. 132/2025 as the First National Implementation Act of the AI Act: A Critical Analysis from a Comparative Legal Perspective

The article analyzes the Italian Artificial Intelligence Law No. 132/2025, the first national implementation of the European AI Act. The Law No. 132/2025 introduces innovative sector-specific regulations in healthcare, employment, and the judiciary, and establishes new criminal law provisions addressing deepfakes and the use of artificial intelligence as an aggravating circumstance. At the same time, it is marked by serious structural weaknesses: it abandons regulatory autonomy, adopts the AI Act as a maximum standard, and creates a polycentric yet fragmented and underfunded supervisory model. Furthermore, it fails to address crucial issues such as environmental impact, civic participation, and the interaction with personal data protection. These shortcomings are exacerbated by broad legislative delegations, which contribute to legal uncertainty. Comparative legal analysis suggests that Law No. 132/2025 functions as a test of the limits of the AI Act’s flexibility and a potential driver of regulatory asymmetry within the Single Market of the European Union. Nevertheless, the Italian regulation serves as an important, albeit imperfect, laboratory for the future development of EU law on artificial intelligence