Italy opens an unfair-terms investigation into Suno over its moral rights waiver and US arbitration clause

Suno’s terms of service say every user “irrevocably waive[s] any and all so-called ‘moral rights’” in what they make. Italy’s competition authority now says that clause may break Italian law.

The Autorità Garante della Concorrenza e del Mercato (AGCM) opened investigation CV278 into Suno Inc. on October 6, 2026. According to its press release, parts of Suno’s terms may be unfair under Article 33 of Italy’s Consumer Code, because they create a significant imbalance between Suno and its users.

The floor is €5,000. No fine has been set yet, because this is the start of an investigation, not a ruling.

What Italy’s AGCM flagged in Suno’s terms of service

The AGCM lists 6 problems. Here they are in plain words:

• Suno can change the contract, the service and subscription prices on its own, without giving a reason.
• Suno can suspend, disable or delete your account, and the songs in it, at any time, for any reason, without notice.
• You agree to extra terms you can’t read when you sign up.
• Suno limits its liability in very broad terms, including for personal injury.
• Disputes go to binding individual arbitration in the US, with tight deadlines and no class actions, and Massachusetts courts get exclusive jurisdiction.
• The license you give Suno over your content is too broad, and it comes with a moral rights waiver.

The AGCM said the copyright clauses “deserve particular attention,” as Music Business Worldwide translated it. It called the license “generic and all-encompassing” and said the waiver runs against Articles 20 and following of Law 633/1941, Italy’s copyright act.

Moral rights are the part of copyright that stays with the author even after a song is sold or licensed. They cover the right to be named as the author and to object when someone distorts the work, and Italian law treats them as something you can’t sign away.

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The scope of the license imposed on consumers as a condition for using the platform services seems to be insufficiently defined, as it is framed in generic and all-encompassing terms, and imposes the waiver of moral rights.

So what does the license actually say? Suno’s current terms, effective September 3, 2026, give Suno a “perpetual, irrevocable” license to “any and all Content.” Content covers both what you upload and the output Suno generates from it.

Suno published those terms on August 10, together with the new download caps. The AGCM didn’t say which version of the terms it examined.

What happens next in the AGCM’s Suno investigation

The AGCM will publish a public consultation on Suno’s terms on its website in the coming weeks. National trade associations, chambers of commerce and recognised consumer groups can take part.

This isn’t the AGCM’s first AI case. Earlier this year it closed investigations into DeepSeek, Mistral and Nova AI after the three companies agreed to warn users about hallucinations, The Next Web reported.

And it lands on a company already fighting in Europe and the US:

• GEMA beat Suno in the Munich Regional Court on July 31, 2026, and Suno said it was weighing an appeal.
• Denmark’s Koda sued Suno in Copenhagen in November 2025.
• Universal and Sony filed a second lawsuit against Suno in Boston on September 18, 2026.

The difference is who is complaining. GEMA, Koda and the labels sued over the music Suno trained on, while the AGCM is looking at the deal Suno offers its own paying users.

Under the September 3 caps, a Pro plan gets 20 downloads a month. If your catalogue lives only inside your Suno account, that’s the number to plan around while Italy works through the consultation.