On August 12, 2025, CIO.com published an in-depth article by Patrizia Licata entitled “AI Act, new obligations take effect: implications for CIOs (and for companies hoping for a delay)”, focusing on the entry into force of the first operational provisions of the EU Regulation 2024/1689 – AI Act.
In the article, Avv. Alessandro Del Ninno, Partner at FIVERS Studio Legale e Tributario, was frequently quoted for his analysis of the concrete impact of the regulation on companies, software providers, and AI users. In particular, he emphasized that:
as of August 2, 2025, strict transparency obligations apply to all AI systems that interact with users or generate digital content, even if not classified as “high-risk”;
providers of General Purpose AI (GPAI) models must prepare comprehensive technical documentation, publish a summary of training data, and adopt copyright compliance policies;
supply, licensing, and distribution contracts will need to be revised to clearly reflect the obligations of disclosure, liability, and copyright management required under the AI Act.
Del Ninno highlighted the need for a restructuring of contractual relationships across the AI supply chain, so that providers, distributors, and deployers can ensure regulatory compliance, transparency, and proper allocation of responsibilities.
