The process has started and MASE is responsible for it. Timing is unpredictable because three Po Valley regions challenged Law No. 91/2025, which delegated transposition to the Government. The draft legislative decree has been prepared and it has been submitted to the legislative service, but the Constitutional Court case could void the process and require it to restart.

Italian law generally prevents transposition measures from exceeding minimum EU directive requirements unless exceptional circumstances are justified through a regulatory impact assessment. This might create a structural barrier to going beyond AAQD minimum requirements, in spite of art. 193 TFEU, stating that "The protective measures adopted pursuant to Article 192 shall not prevent any Member State from maintaining or introducing more stringent protective measures. Such measures must be compatible with the Treaties. They shall be notified to the Commission." More geneal consideration should be given to the ratio of this national provision setting implicit limits to the level of ambition that Italy could set when transposing EU legislation, also in environmental and health protection matters.

There has not been, and is not expected to be, a public consultation. Engagement appears limited to informal meetings with NGOs. Cittadini per l'aria initiated dialogue with MASE and joined with other NGOs; so far, there has been one online multilateral meeting.

No information is available on whether implementation tools such as modelling, supersites, updated monitoring networks or other processes have been finalised.