Drinking water: Decree 102 does NOT replace Decree 18
There is a growing misuse of regulatory terminology in the field of water for human consumption, particularly the phrase “drinking water analysis according to Legislative Decree 102/2025.”
Technically and legally, this wording is incorrect and requires clarification.
In fact, Legislative Decree No. 102 of June 19, 2025, is a measure containing supplementary and corrective provisions to Legislative Decree No. 18 of February 23, 2023, which remains the current regulatory reference for the quality of water for human consumption
As a result, the regulatory framework has not been replaced, but updated. Therefore, analytical activities continue to be conducted in accordance with Legislative Decree 18/2023, as amended.
Correct regulatory framing
| Reference standard | Legislative Decree 18/2023 |
| Role of Legislative Decree 102/2025 | Corrective and supplementary |
| Corrected technical formula | Analysis pursuant to Legislative Decree 18/2023, as amended. |
| Improper formula. | “Analysis according to Legislative Decree 102/2025.” |
The distinction is substantive, not just formal: it affects the correctness of technical documentation and alignment with regulatory requirements.
The main changes introduced by Leg. 102/2025
The changes introduced do not redefine the analytical system, but increase its level of technical and managerial complexity, directly affecting control, monitoring and risk management activities.
1) Evolution of parameters and emerging contaminants.
The decree strengthens control over emerging contaminants, with particular reference to per- and polyfluoroalkyl substances(PFASs) and the introduction of the parameter on trifluoroacetic acid(TFA), for which progressive monitoring and compliance obligations are envisaged starting in 2027
This update involves an adjustment of sampling strategies and analytical methods, with an increasing focus on sensitivity and robustness of the data.
2) Centrality of materials in contact with water.
The decree introduces a harmonized system for the evaluation of materials and reagents that come into contact with water intended for human consumption.
Filter materials, chemical reagents and devices must meet requirements defined at the European level(ReMaF), with procedures for authorization, compliance and marking. There are also transitional phases for compliance, including in relation to limits on metals such as lead
Control thus extends from water to the technological system that treats and distributes it.
3) Structuring of controls, data and transparency.
The control system is made more structured through centralized information tools and data reporting requirements.
The AnTeA platform takes a central role in information collection and management, while stricter timelines for reporting noncompliance and transparency obligations to end users are introduced
The evolutionary model is that of a continuous, traceable and accessible system.
4) Strengthening the preventive approach and risk management
Water Security Plans (WSPs) are being strengthened and tightened, with an extension of the risk-based approach throughout the entire drinking water supply chain.
In this context, the management of microbiological risk, including Legionella, also becomes important and becomes a structural element in control protocols for specific categories of high-occupancy buildings.
The approach is no longer limited to compliance verification, but oriented toward systemic risk prevention and control.
5) Redefinition of responsibilities along the supply chain.
The decree clarifies and expands the scope of responsibilities of stakeholders to include hydropotable managers, economic operators and internal distribution systems.
Water quality is then followed all the way through to the point of use, with an integrated view between network, facilities and end users.
Operational implications for laboratories and operators
| Scope | Technical implication |
|---|---|
| Analytical activities | Updating parameters and methods |
| Interpretation of the data | Increased integration with the regulatory environment |
| Materials and installations | Compliance verification of contact components |
| Risk Management. | Strengthening PSAs and microbiological control |
| Data and reporting | Reporting and tracking requirements |
Legislative Decree 102/2025 does not introduce new analyses in the strict sense, but it does change the technical context in which they are designed and interpreted.
Conclusions
Legislative Decree 102/2025 is a relevant update of the drinking water regulatory framework, but it does not change the basic reference.
The system remains the one defined by Legislative Decree 18/2023, now evolved to a more integrated model geared toward risk prevention and consistent with the European regulatory environment.
The LAC approach
We at LAC operate in this context by providing analytical and technical/regulatory support, with an approach that integrates data, method and legislative interpretation.
The activity is not limited to analysis, but includes establishing monitoring plans, critically reading the results, and supporting the management of critical issues.
Because, in an increasingly complex system, quality depends not only on the measured parameter, but on the ability to interpret it correctly.
