AI for labor consultants: the firm, the clients and the new rules on algorithms at work

Labor consultants (in Italy, consulenti del lavoro: the regulated professionals who handle payroll, employment contracts and HR compliance for companies) have a double relationship with AI, which sets them apart from almost every other professional. On one side they use it in their own firm, like accountants or lawyers. On the other, they are the people companies ask: "Can we use software that screens résumés? Do we have to tell employees?". In this analysis we lay out both roles, the rules that matter today and those on the way.

The Ciompi and rules written by others

Florence, summer 1378. Wool is the city's engine, and the industry is governed by the Wool Guild (Arte della Lana), the guild of the wool merchants, that is, the entrepreneurs. Thousands of workers (carders, combers and other wage earners) work inside it without belonging to it: they are "subordinates," subject to the guild's rules but with no guild of their own and no say in those rules. They're called the Ciompi.

In July they rise up. For a few weeks they get what they asked for: a carder, Michele di Lando, becomes Gonfalonier of Justice, and three new guilds are created for those previously excluded. It doesn't last. By the end of August the most radical Ciompi are defeated, their guild dissolved, and in the following years the other gains fade. But the question they raised stays in the history of work: who writes the rules that decide my work, and can I know them?

You may ask: what do carders have to do with shift-scheduling software? That question returns every time a decision about work is made by a system the worker can't see. An algorithm that ranks candidates, assigns shifts or rates productivity is a piece of company rulebook. Recent laws say something simple: that rulebook must be made visible. And this is where the labor consultant comes in.

Role one: AI in the consultant's own firm

Like every intellectual professional, Italian labor consultants are subject to Article 13 of Law 132/2025: AI is allowed for instrumental and support activities, intellectual work must prevail and clients must be informed about the systems used. The national council of the profession restated these principles in a notice to provincial orders in October 2025.

Where AI really helps a labor consultancy:

The criterion is the same as for any firm: automate what's repetitive and verifiable, never the final legal judgment. And client employees' data, which often include health information (sick leave, injuries, disability), must not go into tools without a GDPR Art. 28 contract and a training exclusion.

Role two: guiding client companies

Here the consultant becomes truly valuable, because the rules are scattered across several texts.

Informing workers

Article 11 of Law 132/2025 requires employers to inform workers about the use of AI in the cases and ways set by Article 1-bis of Legislative Decree 152/1997, the rule on automated decision-making and monitoring systems introduced by Italy's "transparency decree." The same article requires AI at work to respect workers' dignity and fundamental rights, without discrimination. In practice: if a company uses automated systems affecting hiring, management, task assignment, surveillance, evaluation or termination, workers must know.

Remote monitoring

An AI system analyzing workers' activity may also allow remote monitoring. In that case Article 4 of Italy's Workers' Statute applies, with its procedures of union agreement or authorization. Consultants know this check well; with AI it becomes more frequent.

The AI Act: high risk for HR

The EU AI Act classifies as high-risk systems used to select candidates, decide promotions and terminations, allocate tasks based on behavior or personal traits, and monitor and evaluate performance. Deployers (the companies) must ensure human oversight, keep logs and inform workers. With the digital Omnibus package approved in 2026, these obligations were postponed to 2 December 2027. More time, not an exemption: now is the time to take inventory.

Automated decisions

GDPR Article 22 still protects people from decisions based solely on automated processing that produce legal or similarly significant effects. Automatically rejecting a candidate with no human involvement is the classic case to avoid.

A path for client companies

A typical scenario: a fifty-employee company that adopted shift software with "smart" features and is considering a résumé screening tool.

1. Inventory. Which HR software contains automated or AI features? Often the company doesn't know: they're modules switched on by the vendor.
2. Classification. Does each one affect hiring, management, evaluation, termination? Does it allow remote monitoring? Is it a high-risk use under the AI Act?
3. Disclosure. Update the worker notice under Art. 1-bis of Legislative Decree 152/1997, as referenced by Law 132/2025.
4. Safeguards. Always provide human review of decisions that matter, and document it.
5. Vendors. Ask for documentation on how the system works: it will be needed for the 2027 obligations anyway.

What changes for the profession

You can see AI as a threat to labor consultants: ever more automatic payslips, standard answers in seconds. Or as a shift in value. A correct payslip increasingly becomes a given; what companies pay for is the ability to read the rules, combine them and say "you can do it, this way" or "not like that." AI-at-work rules are new advisory territory, and it needs exactly the consultant's skills: employment law, privacy, industrial relations.

The Ciompi asked to see and discuss the rules of their work. Seven centuries later, the law asks the same for algorithms. The labor consultant is the person who can make that transparency real, before it becomes litigation.

Going further

This analysis is part of our dossier on AI for professional firms. If you work alongside an accountant, read AI software for accountants.

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