Italy’s competition and market authority, the AGCM (Autorità garante della concorrenza e del mercato), said in a notice published on 6 October 2026 that it has opened an investigation, an istruttoria, into Suno Inc., the US company behind the generative-AI music service of the same name. The proceeding concerns the clauses in the Terms of Service that Suno applies to consumers, which the Authority says may be unfair under Article 33 of the Italian Consumer Code.
The notice is written mostly in the conditional: it says the terms “would” create a significant imbalance between the rights and obligations of consumers and the company. It announces an investigation. It does not announce a finding or a penalty.
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The key insight: The notice sets a general legal test next to a list of specific clauses. The test is Article 33 of the Consumer Code: a significant imbalance between the rights and obligations of consumers and the company. The clauses are the four groups the Authority describes, and it frames most of them as what the terms “would” do. So the notice announces an investigation into whether Suno’s Terms of Service create that imbalance, not a finding that they do.
The notice, headed in Italian “AI, avviata istruttoria nei confronti di Suno per clausole vessatorie” (in our translation, “AI, investigation opened into Suno over unfair clauses”), says the Authority has opened an istruttoria against Suno Inc., “a US company that provides the generative artificial-intelligence service of the same name, specialised in creating music” (our translation).
It says the proceeding concerns the clauses in Suno’s Terms of Service. In the Authority’s words, as we translate them, the clauses examined “would present” unfair-terms (vessatorietà) profiles under Article 33 of the Consumer Code, because they are capable of causing, to the consumer’s detriment, a significant imbalance in the rights and obligations arising from the contract.
The four groups of clauses the AGCM describes in Suno’s Terms of Service, in the order its notice of 6 October 2026 gives them. The summaries are ours, condensed from the Italian notice.
The Clauses It Describes
The release groups its concerns in four parts. First, it says the Terms of Service would give Suno wide discretion to change the contract, the service and the subscription prices unilaterally, without stating a justified reason, and would let the company suspend, disable or delete a user’s account, together with its content, at any time, for any reason and without notice.
Second, it says the clauses would extend the consumer’s consent to further conditions that cannot be known when the contract is signed, and would limit the company’s liability in a very broad and generic way, including in cases of personal injury.
Third, the release says the contractual treatment of copyright “deserves particular attention” (our translation). It says the licence imposed on the consumer in order to use the platform’s services (our translation) has an object that is too indeterminate, being generic and all-encompassing, and comes with a waiver of moral rights that, in the Authority’s words, is contrary to Articles 20 and following of Law No. 633/1941.
Fourth, it says the Terms of Service would require consumers to go to mandatory arbitration administered in the United States, with narrow time limits for filing complaints and a waiver of class actions, and would set the courts of the State of Massachusetts as the exclusive forum.
What Happens Next, as the Release Describes It
The release says that in the coming weeks the Authority will publish, in the dedicated section of its website, the text of a public consultation. It says the consultation is ordered under Article 7, paragraph 1, of the Authority’s regulation on investigative procedures in consumer protection and misleading and comparative advertising, adopted by resolution of 5 November 2024, No. 31356.
According to the release, national trade associations and chambers of commerce (or their unions) interested in the clauses may take part, given their experience in the sector, as may nationally representative consumer associations listed under Article 137 of the Consumer Code. The notice is dated Rome, 6 October 2026.
The Structural Read
The Authority’s test is a general one. It says the clauses would cause, to the consumer’s detriment, a significant imbalance in the rights and obligations arising from the contract (our translation), and it then lists the clauses it has in mind.
Several of the clauses it lists concern who can change or end the relationship: changes to the contract, the service and subscription prices without a stated reason, suspension or deletion of an account and its content at any time without notice, and consent extended to conditions that cannot be known at signing. The notice puts these in the conditional.
The copyright point is framed differently. The notice says the contractual treatment of copyright deserves particular attention, and states without the conditional that the licence has an object that is too indeterminate and comes with a waiver of moral rights contrary to Articles 20 and following of Law No. 633/1941. The arbitration and venue points are in the conditional like most of the others: the terms would require arbitration in the United States and would set Massachusetts as the exclusive forum.
The AGCM notice of 6 October 2026, in our translation from the Italian
“The Terms of Service would reserve to Suno wide discretion to change the contract, the service and the subscription prices unilaterally, without stating a justified reason.”
Three Implications
THE TEST IS ABOUT CONTRACT BALANCE The notice rests on Article 33 of the Consumer Code and a significant imbalance of rights and obligations. In the text we read it cites no other legal basis than the Consumer Code and, for copyright, Law No. 633/1941.
COPYRIGHT APPEARS AS CONTRACT TERMS The notice raises copyright only as the scope of the licence imposed on the consumer and a waiver of moral rights. It says nothing about how Suno trains or builds its models.
WHAT COMES NEXT IS A CONSULTATION The notice says the text of a public consultation will be published in the coming weeks and that trade associations, chambers of commerce and consumer associations may take part. It gives no deadline for the proceeding.
What Is Not Established
We read the Authority’s notice in Italian, in full. It does not give a case number, a deadline for the proceeding, or any reference to inspections or requests for information, and it does not report any response from Suno. It describes what the terms “would” do; it does not report a finding that any clause is unfair, and it announces no sanction.
We did not read Suno’s Terms of Service, so we cannot say whether the clauses the Authority describes appear as it describes them. We did not contact the Authority or Suno. The notice raises copyright only as a question of contract terms (the scope of the licence and the waiver of moral rights); it says nothing about how Suno trains or builds its models, and we draw no conclusion about that.
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Italy’s AGCM said on 6 October 2026 that it has opened an investigation into Suno Inc. over the clauses in its Terms of Service, which it says may be unfair to consumers under Article 33 of the Consumer Code. It groups the clauses into four parts: unilateral changes and account suspension, consent and liability, the copyright licence and waiver of moral rights, and mandatory arbitration in the United States with Massachusetts as the exclusive forum.
The notice is written mostly in the conditional and announces no finding, no penalty and no deadline; it says a public consultation text will be published in the coming weeks.
A note on sourcing. This piece rests on the AGCM’s press notice of 6 October 2026, read in full in Italian. We haven’t checked the Authority’s description of Suno’s terms independently, we did not read Suno’s Terms of Service, and we did not contact the Authority or Suno. We draw no conclusion beyond what the Authority itself says. Nothing here predicts anything or is legal, consumer-protection or investment advice.
Gennaro is the creator of FourWeekMBA, which reached about four million business people, comprising C-level executives, investors, analysts, product managers, and aspiring digital entrepreneurs in 2022 alone | He is also Director of Sales for a high-tech scaleup in the AI Industry | In 2012, Gennaro earned an International MBA with emphasis on Corporate Finance and Business Strategy.
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