Il tool ACOI per lo screening del conflitto d’interessi e il gap italiano da colmare nei sistemi AI di prevenzione della corruzione

Abstract

The ACOI tool for conflict-of-interest screening and the Italian gap to be closed in AI-based corruption prevention systems
This article examines, through the case study of the PNRR project “ACOI – Assessing Conflicts of Interest”, the conditions that would make an AI-based conflict-of-interest prevention system operationally viable in Italy. ACOI — developed in partnership by the University of Perugia and Transcrime (Università Cattolica del Sacro Cuore), in collaboration with the Ministry of the Interior — empirically tested an automated screening tool on 485 public managers, cross-referencing data from the National Population Register, the Companies Register, the Land Registry, and Orbis, confirming the model’s feasibility. The analysis identifies the enabling conditions still required for the transition to systematic operation: legislative designation of authorised data sources and specification of AI-based processing under the functional legality standard (Art. 2-ter Privacy Code); structured access through the National Digital Data Platform (PDND); and compliance with AI Act requirements for high-risk systems, including embedded pseudonymisation and meaningful human oversight. The conclusion — also from a comparative perspective — is that Italy’s gap is not technological but normative and organisational, and that closing it is an obligation imposed by Directive (EU) 2026/1021 on the prevention and combating of corruption.