On March 18, 2026, the Court of Rome ruled in OpenAI’s favor, annulling a €15 million fine and an order requiring OpenAI to conduct a media campaign about AI model training that had been imposed by the Italian Data Protection Authority (Garante).

The original enforcement action—one of the first major regulatory moves against a generative AI provider—alleged a set of GDPR issues from ChatGPT’s early days. OpenAI challenged the decision.

On appeal, the Court of Rome annulled the Garante’s decision in its entirety, setting aside the fine and the media campaign order. 

Wilson Sonsini’s Data, Privacy, and Cybersecurity group represented OpenAI, providing guidance on strategy and leadership and partnering closely with Italian counsel Chiomenti on the appeal. 

The team included Cédric Burton, Laura Brodahl, Michael Kern, Sebastian Andre Thess, with support from colleagues across the Brussels office.

For more information, please see news coverage from Reuters.