I strongly share @gvdr’s concerns. The documentation alone, albeit undoubtedly a first step, is not enough any more: not with a release deadline for the executable app so close in time.

Making the code available as early in the process as possible (i.e., NOW), is sensible for two reasons:

  1. there do exist a legal requirement by art. 69 of the Italian Codice dell’Amministrazione Digitale, as well as mandatory compliance with the Guidelines published by AGID
  2. this is a legit case for open innovation: releasing the code is a good way of summoning the relevant communities both in Italy and abroad, which will be happy to provide suggestions and improvements not just on the wording of a few sentences in the documentation itself but on functional and non-functional requirements, design, code quality, privacy- and security-related vulnerabilities, inclusiveness and accessibility and so forth.

As Immuni ultimately amounts to a policy implementation, I expect transparency and openness to be pivotal. What the Italian government should not do in any case is to destroy mutual trust with all involved stakesholders.