The Audit File Is a Provenance Record of Labor
In May this institution published a study on the Milan prosecutor's investigation of luxury supply chains. Between January 2024 and July 2025 Italian courts had placed five fashion houses under judicial administration, a preventive measure under article 34 of the anti-mafia code, for negligently allowing labor exploitation in the workshops that made their goods. That study read the court decrees and set out what they said.
This is a continuation, and it opens with a correction. All five of those administrations have since been lifted. Alviero Martini in October 2024, Armani Operations in February 2025, Manufactures Dior on 28 February 2025, Valentino Bags Lab on 7 April 2026, and Loro Piana on 17 April 2026. Every one ended early. The Loro Piana and Dior decrees both use the phrase percorso virtuoso, a virtuous path, for what the company had done under supervision. As of the date of this study no luxury fashion house is under article 34 administration in Milan. The only fashion company under such a measure anywhere in Italy is a fast-fashion retailer, placed there by a court in Florence in January.
So the instrument that made the May study's headline has been put down. What replaced it is the subject here, and it is closer to this institution's work than the one it replaced.
Not counterfeits. Their own chain.
The point that needs stating first, because the coverage keeps losing it, is that none of this is about fakes. Every workshop in every decree was making the real thing, for the real house, on the house's own order. The Armani decree records the brand's quality inspector in the workshop when the police arrived, there to check the glue. The Dior decree records a code of conduct signed the day after the inspection. What the prosecutor is examining is the chain of hands the house itself set up, and what the house knew about it.
A subcontracting chain is a custody chain of the making. The object passes from the house to a contractor to a sub-contractor to a workshop, and at each step the name of the person who actually did the work drops out of the record, until the label says only the house. This institution has written elsewhere that the maker is the author, not the facility, and that a record deletes what it cannot vouch for. The Italian decrees are that argument in a court file.
The instrument changed
The May study ended in July 2025 with Loro Piana. What happened after is not another administration. It is a change of method.
On 4 December 2025 the Milan prosecutor served document orders on thirteen fashion houses: Dolce & Gabbana, Versace, Prada, Gucci, Missoni, Ferragamo, Saint Laurent, Givenchy, Pinko, Coccinelle, Adidas, Alexander McQueen and Off-White. Not a raid, not an administration. A demand for paper.
On 16 and 17 July 2026 the same office, through the Carabinieri labor unit, did it again, this time to nine more: Brunello Cucinelli, Moncler, Chanel, Bulgari, Etro, Stefano Ricci, Goyard, Jacob Cohën and Owenscorp, the company behind Rick Owens. One outlet counted ten by adding a supplier to the list; nine is the number that holds. None of the nine is under investigation, and no administration has been sought against any of them. What was demanded was two years of their supplier and sub-supplier audits, and the organizational models Italian law requires a company to keep under Legislative Decree 231 of 2001.
Read those two orders together and the shift is plain. The prosecutor has stopped taking the company and started taking its file. Taking the company needs a court, a hearing and an administrator, and reaches one house at a time. Asking for the audit file needs a letter, reaches twenty-two houses in eight months, and produces the thing the next case will be built on. Because an audit that found the problem is evidence of two things at once: that the problem existed, and that the house was told.
Intentional blindness
Tod's is where that theory is being tested, and it is the case in this line where the house itself, not only its workshops, is under investigation.
The sequence, from the record. In December 2024 the Milan prosecutor, Paolo Storari, asked for Tod's to be placed under article 34 administration. The Milan court refused in March 2025, on jurisdiction and not on the evidence; the Court of Appeal in May found there was material to proceed but that the right venue was Ancona; and on 19 November 2025 the Court of Cassation agreed. The administration request died on which courthouse. It did not die on the facts.
The next day the prosecutor opened a second track. On 20 November 2025 Tod's and three of its executives were placed under investigation, and the prosecutor asked a judge for a six-month ban on the company advertising its products. The allegations, as reported that day: at least fifty-two workers in six workshops, paid two euros seventy-five an hour, working mostly at night and on holidays, Christmas included.
What makes it different from the five decrees is the audits. Il Sole 24 Ore reported that Tod's had outsourced its supply-chain auditing to Bureau Veritas, that the inspections found numerous indications of exploitation, and that the company, in the prosecutors' words, commissioned the audits without taking them into account. An auditor is reported saying he had contested the violations in December 2023, and again in an audit of May 2024 that found piecework and pension contributions at less than half the collective agreement. The prosecutors' phrase for this, quoted by Il Fatto Quotidiano, is cecità intenzionale. Intentional blindness. The charge moved from negligence to knowledge, and the evidence of knowledge is the company's own audit file.
The hearing on the advertising ban has been postponed three times: on 3 December 2025, on 23 February 2026, and on 20 April 2026, each time at the company's request and each time with the company listing new controls, a revised organizational model, surprise inspections, an outside consultant. What the judge decided after April is still not reported anywhere this institution can reach, re-swept in Italian and English on 15 October 2026. That is stated as an absence with a date, not as an outcome. A granted advertising ban would be the first remedy in this line aimed at what a house says rather than how it is governed.
What the files already said
The May study's figures were verified line by line against the decrees in August, and the decrees turned out to carry something better than figures. They carry the prosecutor's own account of what an audit is for, and it is worth setting beside the Tod's case.
From the Armani decree, in the prosecution's submission as the court reproduced it: the commissioning company had organizational models and a supplier code of ethics, and had carried out formal audits at its contractors, but had never noticed that those contractors had no production department to make the product they were contracted for. It audited the middleman and did not notice the middleman had no factory. And the closing line of that submission: ethical codes, management models and sustainability certifications are worth nothing when maximum profit at lowest cost is pursued through a chain built on exploited labor.
From the Loro Piana decree: an internal audit system the court called fallace, flawed. And the court's own observation that the company outsourced most of its production, as, in its words, do many other producers of the so-called luxury fashion brands.
From the Florence decree of January 2026, the first of its kind issued outside Milan: the administrator is ordered to re-examine every supplier contract against the labor-exploitation statute and report to the judge every two months. The remedy is a record.
The state's question is now the record's question
This institution publishes a provenance record whose purpose is to say who held an object, when, and what is not known. The four things it refuses to do are to leave a blank unlabeled, to let a gap pass for a fact, to let a guess pass for a finding, and to let an examination that found nothing pass for an examination that was never made.
The Milan prosecutor's instrument now asks the same four questions of a house's supply chain. Who made it. Where. Whether anyone looked. And, in the Tod's case, whether what they found was written down and then left where it was. The audit file is a provenance record of labor, and intentional blindness is a legal name for a gap that was looked at and left blank.
That is why the change of instrument matters more than any raid. A raid finds a workshop. An audit order finds whether the house already knew about the workshop, in the house's own hand, dated. The labor density of a luxury object, the hours and hands that went into it, is exactly what the chain of subcontracts is built to make invisible, and the audit file is the one document in which the house wrote it down for itself. The hollowed object is not only an object emptied of its maker's name. It is an object whose maker's name sat in a file the owner chose not to open.
None of this is a claim that any court has adopted this institution's record or its vocabulary. It is the narrower observation that two instruments built for different purposes have arrived at the same question, and that the question is about the file, not the fake. The Custodian's Contract asks a holder to write down what they know about an object and what they do not. The Milan prosecutor is now asking twenty-two houses for the same thing, and reading the answer.