For creators using Suno commercially: Italy opens a public consultation on the terms (not a finding of unlawfulness). Commercial limits and the moral-rights waiver are in scope

What happened

On 14 October 2026 Italy’s Competition and Market Authority (AGCM, which also handles consumer protection) published a public consultation on alleged unfair terms (clausole vessatorie) in case “CV278 – SUNO – VARIE PROBLEMATICHE.” It was put to the Authority’s meeting (adunanza) of 13 October 2026. The target is Suno Inc.’s Terms of Service (3 September 2026 edition) and the app. The procedure itself opened on 15 September 2026.

What changed

The 6 October opening notice said the consultation text would follow in the coming weeks. What is new is the concrete list of clauses under review and the rules for who may file and by when. This site’s earlier note (https://getkominami.com/en/ai-music/2026-10-06-italy-agcm-suno-terms-probe) covered the opening of the probe. This is the consultation, not a finding that the clauses are unlawful.

• A) Unilateral changes to the terms, prices, and the service
• B) Account suspension (including for any reason and without notice)
• C) Extending consent to additional terms the user could not know at signup
• D) Limitation of liability (including the indemnity in 8.1)
• E) Copyright and commercial use (6.5, 6.7, 6.10: Output, Submissions and Voice Model as Content; a worldwide, perpetual, royalty-free, sublicensable, irrevocable license to Suno; waiver of moral rights; free or Basic personal/non-commercial only; commercial use only for permitted Downloads on a paid plan)
• F) Mandatory individual JAMS arbitration, class-action waiver, staged mass-arbitration procedures, claim deadlines (one year / 60 days to dispute a charge)
• G) Massachusetts law and exclusive court jurisdiction
• Written comments within 30 days of publication to [email protected]. Eligible filers are national trade associations, chambers of commerce, and registered national consumer associations. Individual users are not listed as participants.

Whose work this affects

This hits commercial license, training use, and credit (moral rights). In the terms the consultation quotes, users grant Suno a license to use Content (output, submissions, voice models) in connection with providing, monetizing, and improving its products and related machine-learning models, and irrevocably waive moral rights. Free or Basic output is personal and non-commercial only. Commercial use is limited to permitted Downloads on a paid plan. AGCM writes that the clauses “appear unfair” (appaiono vessatorie). That is not a finding of unlawfulness. An Italian consultation is not a conclusion under Japanese law. This is not legal advice.

Do this today

Record, for each track you plan to use commercially, your Suno plan (free / Basic / paid), the generation date, and whether you obtained a permitted Download.

Sources

Primary: AGCM consultation document (Rome, 14 October 2026) and the targeted Terms of Service (suno.com/terms-of-service, effective 3 September 2026). Opening press release: AGCM (Rome, 6 October 2026). Clickable URLs follow.