Italy's antitrust regulator has opened an investigation into Suno Inc., a US-based company that provides generative AI music services, over concerns that its Terms of Service may be unfair to consumers. The Italian Competition Authority, known as AGCM, announced the proceeding on Tuesday, October 6, 2026, from Rome and cited possible violations of Article 33 of the Consumer Code. The review focuses on whether the contract creates a significant imbalance in rights and obligations to the detriment of users.
Suno's AI Music Platform
Suno Inc. is a US-based company that offers generative AI tools specializing in music creation for consumers and creators. The platform enables users to generate musical works through automated processes, placing it among a growing number of AI-driven creative applications. Its Terms of Service have now attracted regulatory scrutiny in Italy because of their potential effect on consumer rights.
Unilateral Contract Changes
According to the AGCM, Suno's terms give the company broad discretion to modify the contract, the service, and subscription prices without providing any justification. The regulator said this could leave consumers exposed to unexpected changes that they cannot reasonably anticipate. Such unilateral powers are central to the authority's broader consumer fairness concerns under Article 33 of the Italian Consumer Code.
Account Suspension and Additional Terms
The authority also noted that the Terms of Service appear to allow Suno to suspend, discontinue, or terminate user accounts and associated content at any time and for any reason. Consumers may not receive prior notice before these actions are taken, which could leave them without access to their own created content. In addition, the terms seemingly require users to consent to additional conditions that they cannot access before entering into the contract.
Liability Limitations and Copyright Licensing
The investigation extends to clauses that limit the company's liability in broad and generic terms, including claims related to personal injury. Copyright provisions are receiving particular attention because the license imposed on consumers is framed in all-encompassing and insufficiently defined language. The terms also require users to waive moral rights, which the AGCM said may conflict with Articles 20 and following of Italy's Law 633/1941.
Arbitration and Jurisdiction Requirements
Suno's Terms of Service require consumers to resolve disputes through binding individual arbitration administered in the United States, with tight deadlines for filing claims. Users must also waive class action rights and accept the Commonwealth of Massachusetts as the exclusive jurisdiction for legal claims. The regulator indicated that these clauses could restrict the legal protections and remedies available to Italian consumers.
Public Consultation and Stakeholder Participation
The AGCM will launch a public consultation in the coming weeks through a dedicated section of its website, in line with procedures adopted in November 2024. The consultation is open to national trade associations representing businesses, chambers of commerce, and their associations affected by the contractual terms under review. Recognized national consumer associations listed under Article 137 of the Consumer Code may also participate in the process.
The investigation reflects increasing regulatory attention on generative AI platforms and their relationships with consumers, especially in creative sectors such as music. Suno was not immediately available for comment following the announcement from Rome. The final outcome could influence how AI music services structure their terms across Italy and potentially the wider European Union.