Services for regulated sectors
Operational and regulatory support for companies selling electricity and gas on the free market: sales processes, back office, billing, credit and customer care aligned with the rules of ARERA, the Italian energy regulator, and overseen through measurable indicators.
What we do
We review contracts, forms, scripts and the materials used by agencies, teleselling and digital channels in the light of the ARERA code of commercial conduct and the Italian Consumer Code, with targeted controls on unrequested activations.
We work alongside the operational teams on activations, switching, changes of contract holder, takeovers and terminations handled through the SII operated by Acquirente Unico, with procedures, controls over rejected flows and orderly management of master data and meter readings.
We check billing cycles, balancing adjustments, recalculations and bill contents against the TIF and the new ARERA bill (resolution 315/2024/R/com), identifying the upstream causes of error: metering data, master data, system configuration.
We structure the credit management process in line with TIMOE and TIMG: reminders, formal notice of default, suspension, the CMOR indemnity and recovery, balancing the protection of collections against compliance with regulatory deadlines.
We organise complaints, requests and corrections in line with the TIQV: a reasoned reply to written complaints within 30 calendar days, billing corrections within 60, automatic compensation where the specific standards are missed. We oversee proceedings before the Servizio Conciliazione, ARERA’s dispute resolution service, and other ADR bodies.
We prepare the periodic communications to ARERA and to the other institutional bodies, build the system of commercial quality KPIs and integrate procedures and controls with the GDPR, the 231 Model required by Italian Legislative Decree 231/2001 and, for those within scope, NIS2.
Selling electricity and gas to end customers is among the most heavily regulated activities in Italy. ARERA (Autorità di Regolazione per Energia Reti e Ambiente), the Italian energy regulator, governs the relationship between retailer and customer in detail. The code of commercial conduct (resolution 366/2018/R/com) sets the rules for offers, contracts and communications and has been updated several times in recent years, in particular on distance selling and on information duties towards the customer. The TIQV establishes the quality standards for complaints, requests and corrections, and the automatic compensation owed to the customer where the specific standards are missed. The TIF and the new bill introduced by resolution 315/2024/R/com, which replaced Bolletta 2.0, govern billing and transparency; TIMOE and TIMG regulate the handling of arrears in the two sectors. Switching, changes of contract holder and takeovers pass through the Integrated Information System (SII) operated by Acquirente Unico, the Italian single buyer, with deadlines and formats that admit no exceptions.
Operating on the market also requires entry in the Register of Electricity Retailers (EVE) kept by the MASE, the Italian ministry for the environment and energy security, with technical, financial and good-standing requirements to be maintained over time, and ministerial authorisation for the sale of natural gas. This framework also takes in the end of the regulated price arrangements, with the Gradual Protection Service and the rules on vulnerable customers, and the mandatory attempt at conciliation required by the TICO, which the customer may bring before the Authority’s Servizio Conciliazione or before the other admitted ADR bodies. Then there are the checks carried out by AGCM (the Italian competition authority) on unfair commercial practices and the ARERA rules on unsolicited contracts, with the associated reinstatement procedure. Telemarketing has rules of its own: the public opt-out register, the code of conduct for telemarketing and teleselling approved by the Italian Data Protection Authority (Garante) in 2023, and the provisions of the code of commercial conduct on distance selling and teleselling. For a retailer, an error in a process almost always translates into a direct cost: compensation payments, fines, irrecoverable receivables, customers lost.
We work alongside the retailer’s operational functions: sales, back office, billing, credit and customer care. We begin with a reading of the processes as they actually run, not with organisation charts: how a contract comes into being, how it enters the systems, how it is billed, what happens when the customer fails to pay or complains. On that basis we compare every step with the applicable rules and measure how the commercial quality indicators hold up.
The solutions are operational: short procedures, contracts and scripts rewritten, controls placed at the points where errors arise, training tailored separately to the sales network, the back office and customer care. Where necessary we handle complex cases ourselves (corrections, ADR proceedings, regulatory investigations) and turn them into lasting process corrections. We also oversee the requirements for entry in and continued listing on the Register of Retailers. We integrate sector regulation with personal data protection (telemarketing, consumption data, profiling) and with the 231 Model required by Italian Legislative Decree 231/2001. For retailers within the scope of Italian Legislative Decree 138/2024, which places the supply of electricity and gas among the highly critical sectors, we add the security and incident notification obligations under NIS2. The company then works with a single system of rules and controls instead of parallel sets of obligations.
Our method
We meet management, sales, back office and customer care; we reconstruct channels, systems, volumes and pending disputes, and define the scope of work together.
We compare processes, contracts and communications with the code of commercial conduct, the TIQV, TIF, TIMOE and TIMG and the Italian Consumer Code; we measure the commercial quality indicators and how they hold up over time.
A report setting out the gaps classified by regulatory, financial and reputational risk, together with an action plan with owners, priorities and deadlines.
We rewrite procedures, contracts and scripts, support the changes to billing and CRM systems, train the sales network and the back office, and handle complex cases ourselves.
A KPI dashboard, periodic sample checks on files and complaints, updates as ARERA resolutions change, and support during investigations and in contacts with the authorities.
Benefits
Deliverables
Frequently asked questions
Yes. We analyse the contracts and acquisition channels behind the portfolio, pending complaints and ADR proceedings, exposure to compensation payments and arrears, the validity of marketing consents, the flows on the SII and the requirements for remaining on the Register of Retailers. From this we draw an assessment of regulatory risk that feeds into the due diligence, together with an integration plan for the period after closing, alongside our business valuation and acquisition service.
With an analysis of the causes, not of individual cases. We classify complaints by type and channel, cross-check them against the compensation paid and trace them back to their origin: metering data, master data, billing configuration, unclear communications. A handful of causes usually explains most of the volume, and those are the ones we address first. In the meantime we bring the response times set by the TIQV under control, so as to stop automatic compensation.
Through clear agency agreements, approved scripts and materials, checks of calling lists against the public opt-out register (Registro pubblico delle opposizioni), recording and sample review of sales, and prompt handling of withdrawals within the cooling-off period. The retailer remains answerable for the conduct of its own network: the controls must be documented and continuous.
It depends on the retailer’s role. Those that have been awarded lots under the Gradual Protection Service (Servizio a Tutele Graduali) must comply with regulated economic and contractual conditions and with specific information duties. For everyone, the market itself has changed: customers to be won with transparent offers, attention to the rules on vulnerable customers, correct communications about the transition. We act on contracts, processes and systems so that the transition takes place without disputes.
We support the company in preparing the periodic communications, in responding to requests for information and in regulatory investigations, gathering the facts and supporting documentation. Where the proceedings require it, we work in coordination with the company’s lawyers: our contribution is to reconstruct processes and evidence and to correct whatever gave rise to the finding.
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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.