Where we use artificial intelligence, and where we do not
Italian AI law requires service providers to declare whether and how they use artificial intelligence tools. This is our declaration. It is written to be read, not merely to exist.
In our own work
We use artificial intelligence tools in parts of our work. Here is the list, with equal attention to what we do not do: that is the half usually left undeclared, and it is the half that actually matters to anyone trusting us with a project.
- Scrittura di codice — we use it. Coding assistants during development. Every line that reaches production is read and understood by a person: if none of us can explain what it does, it does not ship.
- First drafts of copy — we use it. Drafts of descriptions, emails and documentation. What we publish is rewritten and checked by us, and the editorial responsibility is ours.
- Internal analysis and summaries — we use it. Summaries of technical documents and meeting notes, for internal use.
- Decisions about people — we do not use it. No automated system screens applications, assesses colleagues or decides anything about an employment relationship. People are chosen by a person.
- Automated replies to clients — we do not use it. There is no conversational assistant on this site: when you write, one of us is on the other end. If we ever added one, it would say so in its first message.
- Content that could pass as genuine — we do not use it. We do not publish generated images, audio or video that could be mistaken for real footage of people, places or events. Project renders are labelled as renders.
In client projects
When we build an automation or an assistant for a client, five rules apply. They are not a moral commitment: they go into the project document, and anything not written there does not get built.
- Client data trains nothing — The data you entrust to us is not used to train models, ours or anyone else's. It is in the contract, not a verbal promise, and we choose providers based on what theirs say.
- L'assistente dice cosa è — Every system that converses with a person declares that it is automated at the first exchange. It has been an obligation since 2 August 2026, and it is the first thing we write regardless.
- Generated content is marked — Content produced by a generative system ships with the machine-readable marking the regulation requires.
- There is always a human checkpoint — In processes touching money, contracts or people, the automation prepares and proposes; a person confirms. This is not caution: it is the point where a mistake becomes visible before it becomes a problem.
- It can be switched off — Every automation we deliver can be turned off without stopping the rest of the system. An automation you cannot switch off is a constraint, not a tool.
On this website there is no conversational assistant. The animations showing an AI answering — on the AI and Automation page — are examples we designed, not a live system: none of the sentences they show is generated on the spot.
What changes from 2 August 2026
From that date the transparency obligations of Article 50 of the European AI regulation apply. They cover those who build AI and — this is the part that catches people out — those who merely use it. In short:
- a system that converses with a person must declare that it is automated, clearly, at the first exchange at the latest, unless it is already obvious from context;
- content generated by a generative AI system must be marked in a machine-readable format;
- anyone publishing a deepfake must declare that the content is generated or manipulated, perceptibly;
- anyone using emotion recognition or biometric categorisation systems must inform the people affected.
Systems already on the market before 2 August 2026 have until 2 December 2026 to comply. Penalties for breaching the transparency obligations reach 15 million euro or 3% of worldwide annual turnover — whichever is higher — with reduced caps for small and medium enterprises.
The high-risk obligations in Annex III follow later: 2 December 2027, and 2 August 2028 for systems embedded in already-regulated products. They do not cover the kind of work we normally do, but if a project fell inside them we would say so before starting it, not after.
Legal references
This page is not legal advice. It describes how we work and sets out the rules that apply to us, with dates. Anyone deciding for their own company should speak to their own adviser: the position changes considerably depending on whether you are a provider or a deployer of a system, and that distinction turns on the specific case.
Who is accountable
Fymera Srl is answerable for the choices described here. For questions about this page, or to work out whether one of your systems needs declaring, write to contatti@fymera.it: a person replies.
If you have an assistant running and do not know whether it is compliant, the check takes half an hour and commits you to nothing.
