Having a model read over a draft conveyance is a reasonable request: the clauses repeat, one more check costs little, and the machine does not get tired on the third pass. The problem is not the question being asked. It is the document attached to the question.
For a notary the rule is not the one other professionals live under
Article 622 of the Italian criminal codeopens in a new tab, the professional secrecy offence, carries up to a year in prison or a fine, and is prosecuted only on the complaint of the injured party. That is the provision that applies to a lawyer or an accountant.
A notary also holds the other one. Acting as a public officer, which is what receiving a deed means, Article 326 applies: a public officer who discloses official information that must remain secret, or who facilitates knowledge of it in any way, faces six months to three years. The dividing line is the public function on one side and advisory work on the other: Article 326 for the first, Article 622 for the second.
Two things change, and neither is a detail. The minimum sentence is no longer zero. And that offence is not prosecuted on complaint: nobody has to object for it to be pursued. “Facilitates knowledge of it in any way” is, as drafted, a wide formula: it covers an upload to a third party service long before it covers something said out loud.
The anti-money-laundering file is a separate case
Customer due diligence records are not documents like the others. They have a purpose set by law, a ten-year retention period running from the operation or the end of the relationship, and an access regime thatLegislative Decree 231/2007opens in a new tab governs in full. A model reading them to answer a question is not that purpose, and it does not become that purpose because the answer is useful.
Then there is Article 39, which is where this stops being theoretical. It forbids anyone under a duty to report a suspicious transaction, and anyone else who knows of it, from telling the client or any third party that a report has been made, that the Financial Intelligence Unit has asked for more, or that investigations exist or may be coming. The exceptions are listed, and they are other professionals in the same firm or group applying equivalent measures.
An AI supplier is not on that list. If pasted text carries any trace of the assessment that led to a report, the communication to a third party has happened, and Article 39 has no exception for “I put it in a program to get it summarised”.
What a draft contains, value by value
A conveyance carries the name, place and date of birth, tax code, address and marital status of every party; the matrimonial property regime; the price and payment details with the transfer references; the chain of title; and the land registry references, meaning the municipality, sheet, parcel and unit number.
That last line is the one people underrate. A land registry reference is an address, and in Italy an address is publicly searchable: taking the names out of a deed while leaving the sheet and parcel leaves a two-step route back to the people. In the order of values to remove, the registry data does not come after the names. It comes with them.
Which questions do not need the deed at all
Before asking how to get a draft out safely, it is worth asking how often it needs to go out at all, and the answer is surprising: hardly ever. Most of what gets asked of a model in a notarial office is about form, and form contains no parties.
These need nobody’s data: rephrasing a warranty against defects; comparing two versions of a retention of title clause; asking how a right of way over landlocked land is usually framed; having the difference between two matrimonial property regimes explained; asking which planning declarations a sale of a building has to carry; having a generic clause drafted to be adapted afterwards. Those are questions about the precedent bank, and the precedent bank is the part of the craft that has always been shareable.
These do need the document: checking that the recitals and the operative part agree, comparing two versions of the same draft, pulling out the declarations already present, verifying that a value appears identically in every occurrence. Those are the cases where the text has to leave whole, and that is exactly where you want text with placeholders rather than text with names. How the two get separated is its own piece.
The signature stays with the notary, and the statute says so
There is a condition in Article 13 of Italian Law 132/2025opens in a new tab which for most professionals is a limit to respect and for a notary is a description of the job: the person’s intellectual work has to stay predominant over the machine’s (the statute in full is here).
Responsibility for the deed sits in the signature, and the signature belongs to a person: that is the whole point of a public officer. A tool that prepares, checks and orders does not move it an inch, and no supplier’s clause takes it on. If one did, it would be the first thing not to sign.
The striking part is that for the notarial profession that condition was already written down, and had been for a hundred and twelve years. Article 47 of the Italian notarial statuteopens in a new tab (Law no. 89 of 16 February 1913) requires the notary to investigate the parties’ intention and to see to the full drafting of the deed under their own direction and responsibility. It is a rule written for something else entirely, and it answers the artificial intelligence question better than almost everything written since: investigating an intention is something you do with people in front of you, and directing the drafting is not a thing that can be handed to a tool, however good.
Read the other way round, that is also the permission. If the direction stays with the notary, the aid is allowed. Article 47 never banned the precedent bank, has never banned the practice management system, and does not ban a model that proposes text. It separates whoever proposes from whoever decides, and that is the only distinction needed.
Take it out first, not afterwards
The workable route is the same one other firms have, with a longer list of values. The text that leaves carries stable placeholders where the data was: [FULLNAME_1] is the same person throughout, so the model still understands who sells and who buys, and the answer can be read back onto the real matter by putting the values back.
The condition is that the substitution happens on the office computer, before the text moves. Omissia is built for that: the analysis and the model that recognises the values run locally, land registry references sit in the vocabulary alongside tax codes, VAT numbers and IBANs, and the mapping between placeholders and real values stays encrypted on the machine and disappears with the case file.
The difference between redacting and substituting, which decides whether the model’s answer can be used or only read, is in its own piece.