Diritto intelligente – Issue N. 15

December is traditionally a time to pause, look back, and look ahead. This issue of Diritto Intelligente does all three, offering a snapshot of how European digital law is moving from rule-making to execution, just as we enter what will likely be the first fully operational year of AI governance.

At the policy level, the Digital Omnibus proposal on AI training based on legitimate interest signals a pragmatic shift. It acknowledges that innovation needs legal certainty, while still anchoring AI development within GDPR safeguards. At the same time, the broader Package on Simplification shows a clear political direction: fewer overlapping rules, clearer interfaces between GDPR, the AI Act, data and cybersecurity laws, and a stronger focus on efficiency without lowering protection standards.

This transition from theory to practice is echoed in the EDPS guidelines on AI risk management. Here, compliance is framed as a continuous governance process, covering explainability, bias, security, data subject rights and vendor accountability. It confirms that AI risk management is no longer a technical niche, but a board-level responsibility.

The same practical approach emerges in sector-specific contributions. EUIPO’s Early TM Screening illustrates how AI can concretely support professionals without replacing legal judgement. The Italian Council of State decision on AI in public procurement clarifies that innovation is welcome, but only under informed authorization, transparency and human oversight. In insurance, AI appears both as a powerful anti-fraud tool and as a new source of risk, requiring careful alignment with the AI Act and supervisory expectations.

Taken together, these contributions tell a coherent story. Europe is not slowing down AI. It is asking for maturity, responsibility and proof. As holiday season and the new year approach, the message is clear: 2026 will be less about announcing AI strategies and more about showing that they work, legally, ethically and operationally.

Warm wishes for the holiday season and for a new year where innovation and trust grow together.