In short
Art. 13 of Law 132/2025, in force since 10 October 2025, tells anyone in an intellectual profession two things: AI may only be a support tool, with the professional's own intellectual work prevailing, and the client must be told which systems are used, in clear, simple and exhaustive language. The law sets no form and no penalty; putting it in writing is the prudent choice.
Key points
- Paragraph 1 limits AI to instrumental and support activities, with the intellectual work behind the service prevailing.
- Paragraph 2 requires you to tell the client about the AI systems you use, in clear, simple and exhaustive language.
- The text sets no mandatory form and no specific penalty. Write the disclosure down anyway, so you can show you gave it.
- Whether the rule applies to a consultant who is not a member of a professional order is not obvious. Put that question to your own adviser.
- To answer a client you need to know which AI was used, on what, and with which checks. A written record of the work makes that simple.
If you use AI to prepare an analysis, a proposal or a report for a client, the client has one more reason to ask which AI you use. Since 10 October 2025 the question also has a legal reference: art. 13 of Law 132/2025 (Italy’s national law on artificial intelligence).
This is general information, not legal advice. The text is short, and it is worth reading before you form an opinion.
What art. 13 says
The article has two paragraphs.
Paragraph 1. The use of AI systems in intellectual professions is aimed only at instrumental and support activities, with the intellectual work behind the service prevailing. AI helps; the professional thinking stays with the professional.
Paragraph 2. To protect the relationship of trust between professional and client, information on the AI systems the professional uses is given to the client in clear, simple and exhaustive language.
So there are two duties of conduct: use AI as support, and tell the client.
What it does not say
This is worth stating, because people read more into the law than is written there.
- It sets no form. The text says “communicate”. It does not say “in writing” and it does not require a form.
- It provides no specific penalty in the article. The practical risk is different: a client who finds out about your AI use on their own, and difficulty proving you informed them.
- It does not settle by itself who is covered. The text speaks of “intellectual professions”. For professions with an order, such as lawyers, professional bodies and firms have already circulated disclosure templates. For consultants and Fractional Managers outside a professional register, applicability is less clear: ask your adviser. As good practice with the client, it holds in any case.
Why write it down anyway
Telling the client out loud leaves no trace, and one line in the engagement letter costs less than an argument later. The client knows from day one what AI does and what you do. Trust, which is the stated purpose of the rule, is built before the first deliverable.
What to put in a disclosure
Four things, in plain words:
- Which AI systems you use (name of the tool and provider).
- For which activities: research, drafts, data analysis, meeting summaries. Always in a support role.
- How you check the output: every result is reviewed and signed off by you.
- What happens to the client’s data when AI reads it: files an AI system processes are handled by the model provider, so you state what you let AI read and what you keep out.
Template (to adapt and have reviewed)
In carrying out the engagement I may use artificial intelligence systems (state tool and provider) for support activities, such as research, drafting and document analysis. The intellectual work and the decisions remain mine: I check every result produced with AI before it is delivered. I do not give AI systems the client’s confidential data without the client’s consent (state any exceptions). If you have any question about the tools I use, you can write to me at any time.
How to answer without rebuilding everything from memory
An honest answer requires knowing what was done with AI, for which client and under which rules. Anyone who works with several clients and several chats often does not know precisely. The context is scattered across different conversations.
Fabio Armellini, who works with AI for several clients, puts it well:
“I trust the result, and then afterwards you have to explain it to whoever sees the result” — Fabio Armellini, call of 22 October 2026 (translated from Italian)
The disclosure is the first step of that explanation. The second is being able to tell, when needed, what AI did on that client’s work.
So the point is not only the document. It is having a written record of the work: one project per client, rules on what AI may read and what it may not, and a log of what was produced. With that record, you write the disclosure once and update it when a tool changes. If the client asks, the answer already exists. This is one of the reasons we build the Second Brain with file-based memory.
What to do this week
- List the AI tools you use with clients, and what for.
- Decide what you will never let AI read without consent.
- Add a clause to your engagement letter, or prepare a short disclosure.
- If you doubt it applies to your activity, ask your adviser or your professional order.
To see where AI has already entered your work, the free diagnostic takes a few minutes. If you want to work on a real case with me, the next step is the Strategic Compass. For companies, the wider picture is in AI policy for SMEs: operational checklist.
Primary sources and references
Frequently asked questions
What does art. 13 of Law 132/2025 provide?
Two things for intellectual professions. AI may be used only for instrumental and support activities, with the intellectual work prevailing. And information on the AI systems the professional uses must be given to the client in clear, simple and exhaustive language. The law has been in force since 10 October 2025.
Does the AI disclosure have to be in writing?
Art. 13 speaks of communicating the information and sets no form. To be able to show you did it, the prudent choice is to put it in the engagement letter or in an attached disclosure.
Does a Fractional Manager or a consultant without a professional register have to give it?
The law refers to intellectual professions. For regulated professions, such as lawyers, professional bodies and firms have already circulated templates. For consultants outside a professional order, check applicability with your own adviser. Either way, stating up front which AI you use is good practice with clients.
What goes into an AI use disclosure?
Which systems you use, for which support activities, how you check the output, and how you handle client data when you let AI read it. A template is in this article; adapt it and have it reviewed.