Italy’s Autorità Garante della Concorrenza e del Mercato (AGCM) has opened an investigation into Suno Inc.’s Terms of Service, saying the clauses may be unfair under Article 33 of Italy’s Consumer Code because they may create a significant imbalance in rights and obligations to consumers’ detriment. The authority’s English-language press release is dated Rome, October 6, 2026. Music Business Worldwide reported the same day. A follow-on public consultation on the clauses opened October 14 and runs through November 13, 2026, according to Digital Policy Alert’s timeline of the AGCM process.
Suno is a U.S. generative AI company specializing in music creation. The AGCM said the terms under review appear to give Suno broad discretion to make unilateral changes to the contract, the service, and subscription prices without justification; to suspend, discontinue, or terminate user accounts and associated content at any time for any reason without prior notice; to bind users to additional terms they cannot directly access before signing up; and to limit the company’s liability in broad, generic terms, including for personal injury.
Copyright license, moral rights, and U.S. arbitration
Copyright clauses drew particular attention. The AGCM said the license imposed on consumers as a condition of using the platform seems insufficiently defined, framed in generic and all-encompassing terms, and imposes a waiver of moral rights contrary to Articles 20 et seq. of Law 633/1941, Italy’s copyright statute. On disputes, the terms appear to require consumers to pursue claims through binding individual arbitration administered in the United States, with tight deadlines and a class-action waiver, and to establish exclusive jurisdiction in the Commonwealth of Massachusetts.
MBW noted that Suno’s current terms took effect September 3, 2026 (published August 10), and that the AGCM did not say which version it examined. MBW quoted language from the current terms under which users “irrevocably waive any and all so-called ‘moral rights’” tied to content or voice models, and under which Suno may suspend or terminate accounts “for any reason in Suno’s sole discretion.” MBW said it reached out to Suno for comment. The AGCM said eligible trade associations, chambers of commerce, and recognized consumer associations could take part in the consultation. Fines for unfair contract terms, MBW reported from the authority’s site, can range from €5,000 to €10 million.
Why Italian consumer terms land on a global AI fight
Suno is already deep in copyright litigation and partnership deals elsewhere: MBW noted UMG and Sony’s September 2026 Boston suit, Warner’s November 2025 settlement and v6 partnership, a July 2026 Munich GEMA loss Suno said it was evaluating for appeal, and Denmark’s Koda suit. The Italian probe is a consumer-contract front, not a training-data suit, but it lands alongside other AI-music storylines, from Suno’s Songkick live-discovery hire to the consent debates in artist voice and likeness coverage, and platform labeling moves such as YouTube Music’s AI labels. For Italian subscribers, the next checkpoint is what the AGCM does after the November 13 consultation window.