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  • Writer's pictureBergs&More


Late last November, the Italian Council of Ministers approved the Strategic Program on Artificial Intelligence (AI) 2022-2024, the result of the joint work of the Ministry of University and Research, the Ministry of Economic Development and the Minister for Technological Innovation and Digital Transition.

Starting from the national current position in the international context, which sees Italy placed in a non-competitive position in the AI sector, and taking the steps from the correlated need for a radical update of the national strategy for AI, the Program outlines the twenty-four policies that Italy intends to implement over the next three years in order to strengthen the Italian AI system in the three areas of intervention: (i) of skills creation and enhancement (Talents and Skills), (ii) of research (Research), and (iii) of development programs and applications of AI in Public Administration and the private sector (Applications). With a view to the effective concretization of the pursued aims, for each of the 24 policies, the objectives, the possible actions to be carried out to achieve them, the relative sources of investment and, where appropriate, the recommended areas of intervention are detailed.

Of particular interest, for obvious reasons, are the policies defined in relation to Italian companies, broken down into the five initiatives listed below:

  1. to make AI a pillar that supports the enterprises in the “Transition 4.0”, whose objectives include increasing R&D expenditure in relation to GDP and improving intellectual protection of AI solutions in order to increase the competitiveness of companies and, among possible actions, introducing of tax credits or vouchers for the recruitment of STEM profiles and updating the list of software and hardware expenses eligible for Transition 4.0 incentives [Investment source: NRRP M1C2 Investment 1: Transition 4.0 (€13.38 billion)];

  1. supporting the growth of innovative spin-offs and start-ups, whose objectives include increasing the number of AI start-ups by 30% and their average revenues by 50% in the domestic market and 30% in exports while detecting and supporting scale-ups and unicorns, and among the possible actions those of promoting the recruitment of graduates by scale-ups, fostering tax incentives for growth and co-creating flagship projects to connect the players in the start-up ecosystem [Investment source: CDP Venture Capital – Fondo Nazionale Innovazione, established by the Ministry of Economic Development, with a starting budget of €1Bn and with the mission of unifying and multiplying public and private resources dedicated to the strategic topic of innovation];

  1. to promote the go-to-market of AI technologies, which aims to increase by 30% the number of AI products and services tested through controlled and authorized experimentation through the promotion of the “Sperimentazione Italia” Project, a sandbox that allows companies, universities and research centers to experiment with their own innovative project for a limited period of time through a temporary exemption from the rules in force under current art. 36 of D.L. n. 76/2020, as converted by L. n. 120/2020, thus testing AI technologies under real or close to real conditions before their potential introduction on the market.

  1. to support companies in AI Product Certification, which aims to increase by 30% the number of AI products and services certified by the EU through the definition of a national governance system supporting the certification of AI products going to the market in areas with higher risk profile, particularly for health, safety or rights, in line with the European Commission’s recent proposal for a Regulation on Artificial Intelligence of April 21, 2021 (COM(2021)206) and, in the health sector, with the Medical Devices Regulation, i.e., Regulation (EU) 2017/745, which became fully applicable last May 26, 2021 and with the In Vitro Diagnostic Medical Devices Regulation, i.e., Regulation (EU) 2017/746, which will become fully applicable starting next May 26, 2022.

  2. to promote AI information campaigns on AI for enterprises, one of the objectives being to promote awareness of the benefits of AI products and services by reaching at least 80% of trade associations, 30% of members of trade associations, 80% of Competence Centers and Digital Innovation Hubs [Investment source: NRRP M1C2 Investment 1: Transition 4.0 (€13.38 billion)].

It should be pointed out that the five initiatives listed above should be read in synergy with the other policies defined in the Strategic Programme, as it is evident that also the other policies set out therein (and concerning, for example, Public Administration or Research), can have a direct impact on the business world and be functional to the satisfaction of its needs. In this regard, one can think, as an example, of the possibilities that will be opened up by the effective implementation of interoperability mechanisms and usability of open data held by Public Administrations for the development of AI software by private companies.

This example also makes clear the importance of the role that management consultancy, including legal and business consultancy, can once again play in supporting companies wishing to take advantage of the opportunities offered by AI in terms of increased productivity, technological development and advanced analytical activities in all sectors. These opportunities, in fact, will have to be taken in compliance with the existing and future regulatory framework under penalty of exposing the private sector to strong criticalities from the point of view of (non) compliance with the relevant discipline and the related implications of sanctions (by way of example, think of the due compliance with the provisions on personal protection, those of the recent Legislative Decree n. 200 of 2021, bearing “Implementation of Directive (EU) 2019/1024 of the European Parliament and of the Council of 20 June 2019 on the openness of data and the re-use of public sector information”, to those of the future European Regulation on artificial intelligence, etc.), with the not unusual and untimely rush to recover legality in the face of a precipitous and unguarded flight forward.


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