Energy Sector

Electricity and Gas Retail Companies

Regulatory and operational support for electricity and gas retailers on the free market: compliant sales processes, back office, credit management, customer care and oversight of the obligations towards ARERA (the Italian energy regulator), AGCM and the Italian Data Protection Authority (Garante).

  • ARERA (Italian energy regulator)
  • AGCM (Italian competition authority)
  • Garante (Italian data protection authority)
  • MASE (Italian energy ministry)
  • Acquirente Unico – SII
  • ACN (Italian cybersecurity agency)
  • Italian Consumer Code
  • Registro pubblico delle opposizioni (public opt-out register)
  • GDPR – Reg. (EU) 2016/679
  • NIS2 – Italian Legislative Decree 138/2024

Sector challenges

Where competitiveness is won

Constantly evolving regulation

Code of commercial conduct, TIQV, TIF, TIMOE and TIMG, bill contents, the end of the regulated price arrangements: the resolutions of ARERA, the Italian energy regulator, change frequently, and every amendment feeds through to contracts, scripts, systems and billing documents.

Exposure to fines and reputational damage

Unrequested activations, aggressive telemarketing, inadequate pre-contractual information: AGCM, the Italian competition authority, penalises unfair commercial practices and ARERA penalises breaches of regulation, with fines, remedial measures and compensation payments to customers that also weigh on the brand.

High back-office volumes

Switching through the SII, changes of contract holder, supply takeovers, reconciliations, billing corrections: repetitive, high-volume processes in which every error generates complaints, automatic compensation payments and rework costs.

Arrears and credit risk

Thin unit margins and customers who do not pay: credit management calls for procedures aligned with TIMOE and TIMG, correct use of the CMOR indemnity system and a balance between recovery and the customer relationship.

Customer care, complaints and sales channels

Complaint response times, mandatory conciliation procedures, agencies and indirect channels to be governed: service quality is measured by the regulator and felt by the customer at every contact.

Authorisation requirements to be maintained over time

Authorisation to sell natural gas (Article 17 of Italian Legislative Decree 164/2000) and entry in the register of electricity retailers (Italian Law 124/2017): requirements to be overseen and documented over time, not only on entering the market.

Areas of work

How we work alongside your company

ARERA regulation and sales processes

We review contracts, scripts, bills and procedures against the code of commercial conduct, the TIQV, TIF, TIMOE and TIMG, and work alongside the sales network, back office and customer care on the changes required. This is the core of our service dedicated to electricity and gas retailers.

Engineering high-volume processes

We map switching on the SII, changes of contract holder, reconciliations, payment reminders and complaints, identify the points where errors arise and introduce controls and indicators, with the aim of reducing rework and automatic compensation payments and of meeting the deadlines set by the TIQV.

Data protection, telemarketing and consumption data

We oversee the contact-data chain (calling lists, consents, the Italian public opt-out register, agreements with call centres and agencies) and the processing of consumption data from second-generation meters, with an outsourced DPO where appropriate.

NIS2 and systems security

We check whether the company is one of the supply undertakings subject to Italian Legislative Decree 138/2024, then handle registration with the ACN, the risk management measures and incident notification, and put customer portals, CRM and billing systems through security testing.

Decree 231 Model and internal controls

We analyse the predicate offences relevant to a retailer (computer crime, private-sector bribery, tax offences, self-laundering), integrate the protocols with the regulatory procedures and set up audit plans covering sales and credit.

Acquiring and disposing of customer portfolios

Regulatory and operational due diligence for buyers, preparation of evidence for sellers: compliance of customer acquisitions, pending disputes, arrears and the CMOR indemnity system, ongoing investigations. After closing, integration of processes and systems.

The context

The retail supply of electricity and gas to end customers in Italy is a market open to competition, yet one in which regulated arrangements remain. The end of the regulated price arrangements, first for small businesses and then for non-vulnerable household customers (gas from January 2024, electricity from July 2024), has moved millions of customers onto the free market, while vulnerable customers continue to be served under the protected regime. Household customers who have not chosen a supplier are guided towards the free market by the Servizio a Tutele Graduali, the gradual protection service that runs for the period set by the regulator. Competition is played out on price, service quality and the ability to win customers properly. At the same time, volatility in wholesale prices has made margins more fragile and the management of credit risk more important.

The regulatory framework is dense and changes frequently. ARERA, the Italian energy regulator, governs commercial conduct, the quality of retail services, billing, arrears, bill contents and automatic compensation payments; AGCM, the Italian competition authority, acts on unfair commercial practices and unrequested supplies under the Italian Consumer Code; the Italian Data Protection Authority (Garante) oversees telemarketing, the public opt-out register and the processing of consumption data, which second-generation meters make ever more granular. The Ministry for the Environment and Energy Security (MASE) issues the authorisation to sell natural gas (Article 17 of Italian Legislative Decree 164/2000) and keeps the register of parties authorised to sell electricity provided for by Italian Law 124/2017: requirements that have to be maintained over time, not merely demonstrated on entry.

Acquirente Unico, the Italian single buyer, operates the Integrated Information System (SII), through which switching, changes of contract holder and metering flows pass. It also runs the consumer help desk for energy and the environment, together with the conciliation service (Servizio Conciliazione), where an attempt at conciliation is a mandatory step for the customer before going to court. For information security the competent authority is the ACN, under Italian Legislative Decree 138/2024 (NIS2), which places energy among the highly critical sectors. The detail of the resolutions and of our operational work is set out in Services for the energy sector.

For a retail company this means that every process, from the first sales contact to the final invoice, has a rule to comply with and a figure to report.

Our hands-on support

We do not simply deliver opinions and documents: we work inside the processes. A single point of contact who knows both the regulation and the systems works with the sales department, back office, credit, customer care, IT and the legal function to turn resolutions into procedures, controls and everyday practice.

We always begin by looking at how the processes actually run and at the data: complaints received, compensation paid, activation times, arrears rates, disputes traceable to the agencies. Priorities are built from there. In high-volume processes we apply the techniques of business process engineering: flow mapping, identification of the points where errors arise, automated controls, indicators that management can read every month.

The sales network is the most exposed point. Besides training and checking agents and telesellers, we help management govern the indirect channels: agency agreements, incentive schemes that reward compliant selling, handling of customer disputes and of requests for information from the authorities.

The scope is defined together: a single topic (a resolution to be implemented, an investigation to be handled, a process that generates complaints), periodic oversight of obligations and indicators, or operational support during back-office peaks. In every case the decisions remain with the company’s own people: we bring regulatory insight, method and the ability to deliver, with responsibilities and timescales agreed at the outset.

Every engagement is proportionate to the company: procedures and controls are calibrated to volumes, systems and the people available, with the same standards of fair dealing towards customers and authorities that are expected of a large operator.

Why a single partner

  • One point of contact for every authority: ARERA, AGCM, the Garante and the ACN ask for different things; we answer with a single system of procedures and evidence.
  • From the rule to day-to-day operations: compliance is measured in processes, not in documents; that is why we work with the back office, the sales network and customer care, down to daily operations where needed.
  • Measurable results: we agree indicators with the client on complaints, compensation payments, handling times and arrears, and track them over time through shared dashboards.
  • Continuity: the rules change; we stay alongside the company to update procedures, train its people and manage relations with the authorities when required.

Frequently asked questions

Answers to the questions we hear most often

Which service is the best starting point if we have never carried out an overall assessment?

The regulatory assessment of the sales processes and of customer management: this is the area most exposed to fines, compensation payments and complaints, and it produces the data needed to set priorities. Data protection, NIS2 and internal controls then enter the same plan, with timescales calibrated to the structure of the business, so as to avoid parallel projects and overlapping documents.

We intend to sell the company or a customer portfolio: how do we prepare for the buyer’s due diligence?

By first putting in order what the buyer will examine: evidence of how the contracts were acquired, marketing consents, the register of complaints and conciliation proceedings, the state of the flows on the SII, exposure to arrears and compensation payments, open investigations before ARERA and AGCM. We correct what can still be corrected and document the rest: a portfolio with well-ordered evidence is easier to defend in the negotiation over price and contractual warranties.

Can the support extend to the day-to-day running of the back office?

Yes. Beyond designing the processes, we can work alongside the company’s own people in the daily handling of switching, changes of contract holder, reconciliations and complaints, or provide cover during workload peaks. The scope is defined together on the basis of volumes, information systems and the existing organisation.

How is telemarketing handled in relation to data protection and the public opt-out register?

We review the whole data chain: the origin of the calling lists, consents, consultation of the Registro pubblico delle opposizioni (the Italian public opt-out register) before every campaign, agreements with call centres and agencies, scripts and call recordings. We align procedures with the GDPR, with the rules governing the register (Italian Law 5/2018 and Italian Presidential Decree 26/2022), with the measures adopted by the Garante and, for operators that have signed up or intend to, with the code of conduct for telemarketing and teleselling.

Does NIS2 also apply to a company that sells energy without operating networks?

Italian Legislative Decree 138/2024 includes energy among the highly critical sectors and expressly refers to undertakings carrying out the supply of electricity and gas: medium-sized and large enterprises are as a rule within scope, but the decree also sets out criteria independent of size. Applicability has to be checked case by case: we work alongside the business in establishing whether it falls within scope and, if it does, in handling registration with the ACN, the security measures and incident notification.

Let’s talk

Together, let’s build your tomorrow.

Tell us your business priorities: in a first meeting with no obligation we look at your context and propose a concrete way forward, with clear timescales and measurable results.