I followed this from two angles: as a special education teacher who uses AI every week to adapt materials, and as a PNRR trainer who has to explain these rules to colleagues without scaring anyone out of the room. Here I try to do the same thing in writing: what the regulation actually says, and what it means for daily work with learning disabilities, special educational needs and disability.

Three acronyms, three different levels

The confusion comes from three distinct things overlapping:

  • AI Act (EU Regulation 2024/1689): the European framework. From August 2, 2026, the obligations on high-risk systems are fully applicable — a category that includes AI used to assess or guide students.
  • Italian Ministerial Decree 166/2025: the guidelines from Italy's Ministry of Education, published on August 9, 2025. The first Italian document that translates the AI Act into concrete obligations for schools.
  • PUIA — institutional AI plan: the operational document every school must integrate into its three-year educational offer plan (PTOF) for the 2026-27 school year, implementing Ministerial Decree 166/2025.

In practice: the AI Act sets the principle, Ministerial Decree 166/2025 applies it to Italian schools, and the PUIA is the document your specific school must write and approve in its School Council.

What the PUIA must contain (and why it concerns special education)

Ministerial Decree 166/2025 asks every school for three concrete things by the 2025/2026 school year: approve an AI Acceptable Use Policy, appoint an internal AI officer, and include AI training modules in the Staff Training Plan.

The resulting PUIA is organized into thematic areas. Area B explicitly covers support for students with special educational needs — text-to-speech, text simplification, automatically generated concept maps, social stories for augmentative communication. It's not a footnote: it's the area where AI already has the largest measurable impact in the classroom, and the one where school leaders have the fewest practical examples to draw on.

What to actually do before Monday

If you're a special education teacher, the question that matters isn't philosophical — it's operational:

  1. Check whether your school has already approved its AI Acceptable Use Policy. If you don't know, ask the principal or the AI officer (if one hasn't been appointed yet, that's already useful information to bring to a class council meeting).
  2. Never paste a student's identifying data into a cloud chatbot without knowing what the policy says — name, class, specific diagnosis. A well-built Student Profile describes needs and strategies without naming anyone: "difficulty with long texts and subordinate clauses, learns better with numbered sequences" works better than a name and a diagnosis, and it's also the only way to stay comfortable with the GDPR.
  3. Document what you use and why. If your school asks you to report on AI use for the 2026-27 AI Operational Project, already having a record of "which prompt, for which need, with which result" saves you hours.
  4. Bring Area B to the attention of whoever is writing the PUIA. The people drafting these documents often lack concrete examples of what "AI support for special educational needs" actually looks like day to day — a special education teacher bringing real cases (not theory) speeds up the work for everyone.
The most underrated part of these obligations isn't the paperwork: it's that, for the first time, a ministerial document recognizes that AI applied to learning disabilities and special educational needs isn't an "informal" use to be tolerated, but an area that needs to be planned, trained for and monitored like any other.

Where I gathered the method

In the book "Intelligenza Artificiale per la Didattica Inclusiva" (Italian) I dedicate an entire section to exactly this: how to build a Student Profile that respects your school's policy from the start, without ever having to name or diagnose anyone in the prompt. It's the fastest starting point I've found for bringing something concrete — not just theory — into the special-needs section of your school's PUIA.

Frequently Asked Questions

What is the PUIA?
The operational document every Italian school must integrate into its PTOF for the 2026-27 school year, implementing Ministerial Decree 166/2025. It translates the AI Act's principles into concrete obligations for the school.

When does the AI Act become fully applicable for schools?
From August 2, 2026, for the obligations on high-risk systems — a category that includes AI used to assess or guide students.

What must the institutional AI plan contain?
An AI Acceptable Use Policy, an internal AI officer, staff training. Area B explicitly covers support for special educational needs.

What should a special education teacher do before using a chatbot with a student's data?
Check whether the school's policy is already approved, never paste identifying data, and use an anonymous Student Profile — more effective and safer under the GDPR.

Conclusion

August 2 doesn't change overnight what you can do in the classroom. What changes is that, from now on, doing it well or doing it randomly with AI stops being a single teacher's personal choice and becomes part of a plan the school must write, approve and — sooner or later — verify.

Better to arrive with a method already tested than with a document to fill in at the last minute.