Telecommunications Sector
Regulatory and operational support for fixed and mobile telephony operators, ISPs, MVNOs and resellers: obligations towards AGCOM (the Italian communications authority), activations and migrations, billing, complaints and conciliation, privacy and network security.
Sector challenges
Contract transparency, service charters and compensation, migrations and portability, billing frequency, free choice of modem, withdrawal and deactivation costs: every AGCOM resolution affects contracts, systems and processes, and has to be implemented within short deadlines.
Activations, migrations and portability run into the thousands every month. A delay or a rejected order (KO) turns into a service failure, a compensation payment and a complaint: orders need precise monitoring along the whole chain, wholesale partners included.
Complaint handling is a regulated process, with response deadlines and record-keeping duties. Disputes run through ConciliaWeb and the CoReCom; AGCOM and AGCM (the Italian competition authority) oversee billing, commercial practices and service quality.
In a mature market, holding margins depends on customer care, debt recovery and effective sales channels. Telemarketing and teleselling must respect the Registro pubblico delle opposizioni (the Italian public opt-out register) and the consents collected, while the appointed call centres have to be governed.
Operators fall within the scope of NIS2 and must apply the anti-spoofing filters on inbound traffic required by AGCOM (resolution 106/25/CONS). Traffic and location data follow the special rules of the Italian Privacy Code, with breaches notified to the Garante within 24 hours.
ROC registration and updates, annual fees payable to AGCOM and MIMIT, periodic reporting, changes to the general authorisation and to numbering, requests for information from the authorities: different deadlines, often owned by different functions, which without a single calendar risk being overlooked.
Areas of work
We compare contracts, service charters, processes and customer communications with the applicable resolutions and set out the non-conformities, ranked by priority of action, in a remediation plan agreed with management. We then oversee the regulatory calendar: registration with the ROC (the Italian register of communications operators), annual fees payable to AGCOM and MIMIT, periodic reporting and responses to requests for information from the authorities. We formalise procedures and controls, re-engineer the critical processes and build KPIs and dashboards for senior management.
We review order management: order statuses, timescales, rejections (KO) and their causes, and relations with donating operators and wholesale providers, following the AGCOM procedures for migration (resolution 274/07/CONS and subsequent additions) and for fixed and mobile number portability, so as to reduce service failures and automatic compensation.
We draft and update general terms, the contract summary, pre-contractual information and sales scripts, consistent with the Electronic Communications Code, the Italian Consumer Code and the AGCOM regulation on contracts and transparency (resolution 307/23/CONS, which replaced 519/15/CONS).
We analyse billing cycles and frequency, charges, and suspension and termination for non-payment. We build credit management and recovery procedures that respect notice periods, compensation duties and the rights of end users.
We structure complaint handling with deadlines, traceability and standard responses. We support the team in ConciliaWeb procedures (resolution 203/18/CONS as amended), in hearings before the CoReCom and in quantifying compensation, whether automatic or awarded in dispute proceedings (resolution 347/18/CONS).
We bring the sector privacy rules (GDPR and the Italian Privacy Code: traffic and location data, telemarketing, data breaches), NIS2, anti-spoofing measures and technical security testing into a single system of procedures, with training targeted at each function.
The Italian electronic communications market is mature and competitive. Price pressure, the shift to fibre and 5G and the growth of virtual operators and resellers have squeezed margins and moved competition onto the quality of the customer experience. In this setting every process, from order to invoice, weighs directly on the profit and loss account: a late activation is a compensation payment, a disputed invoice is a complaint, a complaint left unhandled is a conciliation claim.
Regulation both frames and complicates that picture. The Electronic Communications Code (Italian Legislative Decree 259/2003, reformed by Legislative Decree 207/2021 implementing Directive (EU) 2018/1972) governs the general authorisation, the rights of end users and information duties. AGCOM resolutions turn those principles into operating rules that reach contracts, billing, migrations and customer support. Alongside AGCOM (the Italian communications authority) sit MIMIT, the Italian Ministry of Enterprise, for authorisations and numbering; AGCM (the Italian competition authority) for unfair commercial practices under the Italian Consumer Code; the Italian Data Protection Authority (Garante) for traffic data and telemarketing; and the CoReCom, the regional committees that handle the conciliation of disputes with users. To this has been added the NIS2 regime (Italian Legislative Decree 138/2024), which brings the security and incident notification obligations of electronic communications operators within a single framework.
The result is a body of obligations that changes frequently, involves almost every corporate function and is checked by several authorities with distinct powers of sanction. For a mid-sized operator, keeping pace through fragmented internal oversight is difficult; for a small operator it is often impossible.
We work with management and the operating functions, not in their place. The starting point is always a close look at the processes as they actually run: how an order comes in, who follows it, where it stalls, how an invoice is produced, how a complaint is handled. On that basis we compare what happens with what the rules require and build an action plan with priorities, owners and timescales.
The work can be one-off (a resolution to implement, proceedings to manage, a process to redesign) or continuous, with periodic oversight of obligations, regulatory indicators and new rules. Either way the method does not change: short, usable procedures; controls built into the systems and into daily activity; training for the people who have to apply the procedures; and indicators that let senior management measure results.
We integrate regulatory compliance with data protection, network security and process efficiency, because in a telecoms operator these themes are intertwined: the same system that handles an activation processes traffic data, feeds commercial campaigns and produces the evidence required in a conciliation. Treating them separately multiplies procedures and controls; treating them together makes them sustainable.
Frequently asked questions
By starting from the data: we measure where orders stall, for what rejection causes and with what timescales, and compare the results with the standards set in the service charter. We then act on process, systems and customer communication. Automatic compensation becomes an indicator monitored every month, not a surprise at the end of the quarter.
As a rule the operator that sells the service: it is the party that signed the contract that answers to the end customer, so the automatic compensation remains its responsibility, subject to any right of recourse against the provider. This is why we work on two fronts: traceability of order statuses, so that every delay can be attributed to its real cause, and revision of the wholesale contracts, with service levels, penalties and information flows consistent with the operator’s obligations towards users.
Yes, subject to precise rules: consultation of the Registro pubblico delle opposizioni, the Italian public opt-out register (Italian Presidential Decree 26/2022), before every campaign, with a result valid for 15 days; valid and documented consents (Article 130 of the Italian Privacy Code); contracts and controls over partner call centres; compliant scripts and traceability of calls, in line with the code of conduct on telemarketing and teleselling approved by the Garante. The Garante has fined telecoms operators several times on this point: we support the company in setting the process up beforehand, rather than defending it afterwards.
Yes. Italian Legislative Decree 138/2024 includes among digital infrastructure the providers of public electronic communications networks and of publicly available electronic communications services, in principle regardless of size. This brings registration with ACN, risk management measures, governance duties and incident notification obligations. We check the scope of application for the individual operator and build the compliance plan.
No. We work with the company’s own people: those who know the systems and the customers stay at the centre, while we bring method and regulatory insight. To start we need a contact person for each function and access to data on orders, invoices and complaints; the first output is an assessment setting out the priorities for action. We can then take on specific activities, such as conciliation, with responsibilities and timescales defined at the outset.
Related services
Specialist support for telephony and telecoms operators: AGCOM obligations, activation and migration processes, billing and complaint handling.
Find out moreCompliance with EU Regulation 2016/679 and the Italian Privacy Code: assessment, record of processing, DPIA, policies and training.
Find out moreAlignment with EU Directive 2022/2555 and Italian Legislative Decree 138/2024: scope, gap analysis, security measures, governance and incident notification.
Find out moreTechnical security testing of networks, applications and infrastructure: we find vulnerabilities before an attacker does.
Find out moreMapping, analysis and redesign of business processes: we remove waste, reduce operational risks and prepare the ground for digitalisation.
Find out moreLet’s talk
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.