Suno’s Terms of Service may create a significant imbalance of consumer rights and obligations.

The Italian Competition Authority has launched an investigation into Suno Inc., a US company that provides generative AI services specialising in music creation. The proceedings focus on Suno’s Terms of Service. According to the Authority, the terms under investigation may be unfair pursuant to Article 33 of the Consumer Code since they may create a significant imbalance in the rights and obligations under the contract, to the detriment of consumers.

In particular, the Terms of Service seem to give Suno broad discretion to make unilateral changes to the contract, the service and the subscription prices, without having to provide any justification. The Terms appear to allow the company to suspend, discontinue or terminate user accounts – as well as any associated content – at any time, for any reason and without prior notice. Moreover, the Terms of Service seemingly require users to consent to additional terms, which they have no direct access to before entering into the contract. They also appear to limit the company’s liability in very broad and generic terms, including in relation to personal injury.

The contractual provisions on copyright deserve particular attention. The scope of the license imposed on consumers as a condition for using the platform services seems to be insufficiently defined, as it is framed in generic and all-encompassing terms, and imposes the waiver of moral rights contrary to Articles 20 et seq. of Law 633/1941.

Lastly, the Terms of Service appear to require consumers to pursue claims through binding individual arbitration administered in the United States, subject to tight deadlines for doing so and a waiver of class actions. The Terms also seemingly establish the exclusive jurisdiction of the Commonwealth of Massachusetts.

In accordance with Article 7(1) of the “Regulation on investigation procedures relating to consumer protection and misleading and comparative advertising” adopted by AGCM decision 31356 of 5 November 2024, over the next few weeks, the Authority will launch a public consultation on the terms under investigation in a dedicated section of its website. The consultation is open to trade associations representing traders at national level and to chambers of commerce, or their associations, affected by the contractual terms under investigation due to their specific experience in the sector concerned. Consumer associations that are representative at national level and are recognised and included in the list referred to in Article 137 of the Consumer Code may also participate.

 Rome, 6 October 2026

Authority previously accepted three commitments offered by the company. Extension strictly linked to transitional nature of two commitments, to be implemented pending approval of new regulatory framework

In its meeting of 22 September 2026, the Italian Competition Authority extended the deadline for the conclusion of its proceedings, launched last May, aimed at reviewing some of the commitments made binding on Rete Ferroviaria Italiana S.p.A. (“RFI”).  The commitments closed the Authority’s investigation into a possible abuse of a dominant position by the national railway infrastructure manager in breach of Article 102 of the TFEU (case no. A575).

RFI’s conduct, which centred on the procedures for allocating capacity on high-speed national rail infrastructure, raised specific competition concerns due to its potential to hinder access to the rail network by new operators. 

Following a complex investigation, which involved both the infrastructure manager and all rail operators concerned, the Authority deemed the commitments offered by RFI capable of addressing its competition concerns.  The Authority identified concerns regarding the procedures and criteria for allocating infrastructure capacity which, if unchanged, would have hindered access to the network by new operators.  This, in turn, would have hindered effective competition in the provision of high-speed rail network services, to the detriment of consumers.

The commitments also took into account the Transport Regulation Authority’s stated intention to review the rules governing the allocation of framework capacity.  However, the prospect of regulatory reform did not provide grounds for the Authority to delay its intervention, as its powers require it to act promptly to address identified competition concerns and restore effective market access.

Of the three commitments accepted by the Authority, the one assigning the new entrant a package of train time slots is not affected by the review.  On the other hand, the Authority’s extension is strictly linked to the transitional nature of the other two commitments under review (Commitments 2 and 3), to be implemented pending approval of the new regulatory framework governing the allocation of capacity to rail operators.  The commitments are designed to prevent the continued reliance, pending new rules, on allocation methods that restrict competition.

The review therefore focuses on coordinating the transitional measures with the new regulatory framework currently being developed, without calling into question the need for antitrust intervention or the measures already adopted to enable effective entry by new operators into the high-speed market.

Rome, 30 September 2026

Text of the decision

An administrative judge and lawyer, he has extensive professional experience in competition law and the regulation of public utility services.

Ciro Daniele Piro is the new Head of Cabinet of the Italian Competition Authority. Mr. Piro is an administrative judge and has served at the Regional Administrative Court of Lazio. Formerly a lawyer, he has worked primarily in the fields of competition law and the regulation of public utility services.

Prior to joining the judiciary, he worked as an official at the Authority and later at the Presidency of the Council of Ministries, where he was Head of the Secretariat of the Council of Ministers and Head of Staff of the Secretary General.

As part of his institutional duties, he also served as member of the strategic assessment and analysis unit for the exercise of special powers within the Presidency of the Council of Ministries.

He is the author of publications on administrative law and competition law, focusing on the golden power regime and the judicial review of the investigation and enforcement activities of independent administrative authorities.

Rome, 28 September 2026

Procter & Gamble S.r.l. has removed claim that its device delivers lasting results for two years and extended for a further 6 months its 100-day full purchase-price refund guarantee if the product is returned

The Italian Competition Authority has closed with commitments its investigation into Procter & Gamble S.r.l. The case concerned the adverts used in the marketing campaign for the Braun Skin i-Expert IPL hair removal device, which highlighted the product’s effectiveness through the claim “hair-free for two years” (or similar).

The Authority made binding a number of commitments offered by Procter & Gamble to address the concerns raised during the investigation. In particular, the company agreed to remove the claims under scrutiny from all forms of product advertising. It also agreed to use wording that makes no specific reference to the time required to achieve the intended effects or to their duration, removing any promise to deliver results lasting two years. Particularly noteworthy is the commitment to extend the “100-day money back guarantee” until 31 December 2026 (otherwise valid until 30 June 2026), to allow consumers to return the hair removal device within 100 days, without any restrictions, and receive a full refund of the purchase price.

Rome, 25 September 2026

Text of the decision

Text of the commitments

Professor Bagnai was appointed on 4 August 2026

Professor Alberto Bagnai has today taken office as a member of the Board of the Italian Competition Authority. Mr. Bagnai, Professor of Economic Policy at the “Gabriele d’Annunzio” University of Chieti-Pescara and a former Member of Parliament, was appointed on 4 August 2026 by the President of the Senate of the Republic, Ignazio La Russa, and the President of the Chamber of Deputies, Lorenzo Fontana.

The Board of the Authority is therefore composed of the President, Saverio Valentino, and the two Commissioners, Professor Elisabetta Iossa and Professor Alberto Bagnai.

Rome, 22 September 2026

Authority to assess the possible effects on competition across a large number of different local and national banking and insurance markets

On Monday, 14 September, the Italian Competition Authority opened an investigation, pursuant to Article 16(4) and (6) of Law 287/1990, into the transaction by which Intesa Sanpaolo S.p.A. intends to acquire sole control over Banca Monte dei Paschi di Siena S.p.A. The transaction takes the form of a takeover and exchange bid launched on 8 June 2026.

Given the significance of the parties to the transaction and the range of competitive dimensions at play, the Authority’s investigation aims to assess the possible effects on competition across a large number of different local and national banking and insurance markets.

Rome, 15 September 2026

Text of the decision

The Authority commissioned an impact analysis of its advocacy interventions in the local public services sector, focusing particularly on municipal waste management and local public transport.

The Italian Competition Authority commissioned the consulting firm Lear to develop an ex ante impact assessment methodology designed to estimate the potential benefits of its advocacy interventions in the local public services sector. The methodology focuses particularly on municipal waste management and local public transport (“LPT”). The Authority’s advocacy reports in these sectors mainly involve cases where the granting authority chose not to use a competitive tendering procedure to select the concessionaire, failing to provide adequate justification for this decision.

The analysis shows a clearly positive potential ex ante impact on the quality of municipal waste management services, when considering the Authority’s advocacy reports issued between 2023 and 2025. These interventions could result in an average increase of around 16% in the overall separate waste collection rate, with an estimated saving on the average aggregate cost of collecting and transporting separately collected waste of 20%, equivalent to approximately € 120 million. Lear’s analysis estimated the potential benefits of these interventions from an ex ante perspective, measuring them in terms of lower costs for society and improvements in service quality. The methodology is based on a comparison between a group of granting authorities that received an advocacy report or warning letter from the Authority (so-called “non-virtuous” authorities) and a group that used efficient awarding methods (so-called “virtuous” authorities). The difference in outcomes between these two groups therefore provides an estimate of the potential ex ante benefit of the Authority’s intervention. The breadth, granularity, and standardisation of the data available in the waste management sector made it possible to compare the outcomes of the two groups of contract awards through detailed and robust econometric analysis.

As regards the LPT sector, two case studies were developed – again based on a comparison between non-virtuous and virtuous granting authorities – to provide useful information for a qualitative assessment of the potential ex ante impact of the Authority’s advocacy interventions. These comparisons, which covered awards with comparable socioeconomic and territorial characteristics, revealed a potential ex ante benefit consisting primarily in the virtuous authority’s greater ability to attract per capita demand (i.e., the annual number of passengers carried per inhabitant) and to manage expenditure efficiently.

Rome, 9 September 2026

Introduction and summary

Final Report

Commitments include the discontinuation of coordinated pricing and a EUR 30 million redress package for consumers

The Italian Competition Authority has concluded, by accepting commitments, the proceedings opened in July 2025 against Federconsorzio Dolomiti Superski and its adhering twelve valley consortia (Consorzio esercenti impianti a fune Cortina d’Ampezzo, S. Vito di Cadore, Auronzo/Misurina; Consorzio esercenti impianti a fune Skirama Plan de Corones - Kronplatz; Consorzio impianti a fune Alta Badia; Consorzio esercenti impianti a fune Val Gardena - Alpe di Siusi; Consorzio impianti a fune Val di Fassa e Carezza; Consorzio esercenti il trasporto di persone a mezzo impianti a fune Alpe Lusia - San Pellegrino; Consorzio impianti a fune Civetta; Consorzio impianti a fune Arabba - Marmolada; Consorzio 3 Zinnen Dolomites; Consorzio impianti a fune Val di Fiemme - Obereggen; Consorzio impianti a fune San Martino di Castrozza e Passo Rolle; Consorzio Rio Pusteria - Bressanone) for an alleged infringement of Article 2 of Italian Law No. 287/1990 and Article 101 of the Treaty on the Functioning of the European Union (TFEU).

The investigation concerned provisions of Federconsorzio's by-laws that could have resulted in two appreciable restrictions of competition: first, the setting within Federconsorzio of the prices for local consortia's ski passes; second, restrictions imposed on valley consortia on the sale of their ski passes through third-party. Fully addressing the competition concerns identified in the opening decision, Federconsorzio and its adhering twelve valley consortia have committed, first, including through amendments to their by-laws, to remove any future form coordination in pricing and distribution policies for valley ski passes. They also offered substantial financial redress measures for consumer skiers. Consumers who purchased one-day or multi-day valley ski passes during the 2022/2023, 2023/2024 and 2024/2025 ski seasons will be eligible for financial redress totalling EUR 30 million, comprising EUR 18 million in discount vouchers and EUR 12 million in direct refunds. Consumers will be able to choose between a discount voucher for future purchases equal to 30% of their previous expenditure or a direct refund equal to 20% of the amount previously paid. In addition, promotions and concessions already introduced for the Dolomiti Superski ski pass will be maintained for the next five winter seasons, with an overall value of approximately EUR 20 million.

For further information on the procedures and eligibility criteria for accessing these measures, consumers are invited to consult the websites of Federconsorzio Dolomiti Superski and the adhering valley consortia, as well as the notices displayed at all ticket offices throughout the ski area and in local newspapers in North-Eastern Italy. The Authority considered these compensatory measures capable of mitigating any adverse effects on consumer skiers arising from the alleged agreement.

Rome, 7 August 2026

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Text of the commitments

Bird, Dott and Lime hindered access to the free ride packages reserved for subscribers to Rome’s local public transport system.

The Italian Competition Authority has concluded the investigations, launched in November 2025, into three operators authorised to provide micromobility services (e-bikes and e-scooters) within the territory of the Roman municipality for the 2023-2026 period.

Bird, Dott and Lime were fined a total of almost EUR 2.7 million for preventing holders of the Metrebus card (the annual pass for Rome’s local public transport system) from using the free ride packages (so-called Passes) that the operators had undertaken to provide when bidding for the service.

In particular, the Authority found that the three companies had adopted inadequate measures and organisational arrangements for handling users' requests. This made the activation process burdensome, caused lengthy delays in issuing the Passes and, consequently, reduced the period during which users could benefit from them.

In the case of Bird, the Authority also established a further unfair commercial practice consisting of the arbitrary deactivation of user accounts, without providing prior information about the circumstances that could justify such action or giving users an opportunity to be heard.

The practices had a significant impact on consumers, as the three companies restricted access to a more sustainable mobility service that complements local public transport through to the use of less polluting vehicles.

Rome, 6 August 2026

Text of the decision Lime

Text of the decision Dott

Text of the decision Bird