Services for regulated sectors

Services for Telecommunications Operators

Operational and regulatory support for fixed and mobile telephony operators, ISPs, MVNOs and resellers: we review activations and migrations, contracts, billing and complaints, oversee obligations towards AGCOM, the Italian communications authority, and measure results with management.

What we do

Our areas of work

Activation, migration and number portability

We review activation, migration and number portability on fixed and mobile networks: timescales, migration code and SIM identification data, handling of rejected orders, coordination with the donor operator and the wholesale provider, so as to reduce service failures and compensation payments.

Contracts and tariff transparency

We check general terms, the contract summary, pre-contractual information, recorded voice orders and unilateral variation notices against the Italian Electronic Communications Code, the AGCOM regulation on contracts (resolution 307/23/CONS) and the Italian Consumer Code.

Billing and debt recovery

We review billing frequency, charges for unsolicited services, withdrawal and deactivation costs, credit notes and refunds; we design the reminder, suspension and recovery process in line with the rules protecting end users.

Customer care, complaints and conciliation

We structure complaint handling within the timescales of the service charter, the conciliation stage on ConciliaWeb and before the CoReCom, the regional communications committees, the calculation of automatic compensation and the analysis of recurring causes.

Obligations towards the Ministry and AGCOM

We oversee the general authorisation and administrative fees due to the Italian Ministry of Enterprise and Made in Italy (MIMIT), ROC registration and its updates, the annual AGCOM contribution, periodic reporting to the Authority, the service charter and the publication of quality indicators.

Integration with GDPR, NIS2 and Decree 231

We bring into a single system of controls the retention of traffic data, telemarketing and the Italian public opt-out register (Registro pubblico delle opposizioni), the network security that NIS2 requires of digital infrastructure, and the predicate offences under Italian Legislative Decree 231/2001.

The regulatory context

Companies selling electronic communications services operate in one of the most heavily regulated markets in Italy. The Electronic Communications Code (Italian Legislative Decree 259/2003, reformed by Legislative Decree 207/2021 implementing the European Code) sets the conditions for market access and the rights of end users. Access runs through the general authorisation, obtained by filing a declaration with the Italian Ministry of Enterprise and Made in Italy (Article 11), and through registration with the ROC, the register kept by AGCOM under Law 249/1997. End-user rights cover pre-contractual information and the contract summary, duration and withdrawal, switching provider and number portability, and deactivation costs.

On this basis AGCOM has built a detailed body of regulation that touches every commercial process. Contracts and their transparency follow the regulation approved by resolution 307/23/CONS, which brought the earlier 519/15/CONS into line with the reformed Code; quality and service charters, with the maximum times for responding to complaints, are governed by resolution 179/03/CSP. Compensation operates on two levels: the automatic payments provided for by the service charters, and the amounts awarded in the resolution of disputes (resolution 347/18/CONS), which run through ConciliaWeb and the CoReCom (resolution 203/18/CONS). The renewal and billing cycle, monthly or a multiple of the month, derives from resolution 121/17/CONS and from Article 19-quinquiesdecies of Decree-Law 148/2017, converted by Law 172/2017; freedom of choice of modem and the migration procedures complete the picture.

Then there are the Consumer Code and the oversight exercised by AGCM, the Italian competition authority, over unfair commercial practices, the rules on telemarketing and the public opt-out register, and the protection of minors in premium-rate services. On the data and security side, the burden lies in the retention of traffic data, the mandatory services for the judicial authorities and the security obligations for networks and services, now largely brought within the NIS2 regime, which applies to providers of electronic communications networks and services regardless of their size.

The result is that a process error (a late migration, an unclear invoice, a complaint left unanswered) quickly becomes a compensation payment, a conciliation claim or enforcement proceedings.

Our approach

We do not simply read the resolutions: we go into the processes. The work starts from mapping the real flows, from order to termination, and the systems that support them: CRM, billing, provisioning and ticketing platforms. We compare what actually happens with what the rules require, measure where complaints and costs arise, and act first on the causes, then on the documents.

We work alongside customer care, back office, administration, IT and sales, because an operator’s compliance is spread across different functions and no single one of them governs it alone. Where the operator relies on wholesale providers or outsourcers, we extend the analysis to the relevant contracts and service levels, which often determine the timescales perceived by the end customer.

We combine regulatory oversight with data protection (traffic data, retention, telemarketing), with the security of networks and services and, where one exists, with the 231 Model: a single system of procedures, records and controls, and a single point of contact for management.

What sets our service apart

  • Processes before documents: we start from activations, migrations, billing and complaints as they actually happen in the systems, and update the service charter and the procedures only at the end.
  • Measurability: quality indicators, response times, conciliation claims and compensation payments become a dashboard that management reads every month.
  • The wholesale chain within scope: we extend the analysis to the contracts and service levels of wholesale providers and outsourcers, because that is often where the activation and migration times perceived by the end customer originate.
  • An integrated approach: AGCOM regulation, GDPR, NIS2 and Decree 231 read with the same logic we apply to electricity and gas retailers, without several procedure manuals having to coexist.

Our method

How we work

  1. Kick-off and scope

    We meet management, customer care, back office and IT; we collect contracts, the service charter, procedures and data on complaints and conciliation claims; we set priorities, timescales and contact people.

  2. Regulatory and operational assessment

    We compare processes and documents with the Electronic Communications Code, the AGCOM resolutions and the Consumer Code; we analyse the activation, migration, billing and complaint flows and the systems that support them.

  3. Gap analysis and action plan

    We deliver a report setting out non-conformities and inefficiencies ranked by risk and economic impact, together with an agreed plan naming owners, deadlines and verification indicators.

  4. Supported implementation

    We rewrite procedures, contracts and customer care scripts; we support changes to the billing and CRM systems and train front and back office staff on the new rules.

  5. Monitoring and updating

    A KPI dashboard on quality, complaints and conciliation claims, periodic checks, updates as the AGCOM resolutions change and support in proceedings opened by the Authority.

Benefits

What the business gains

  • Fewer complaints, conciliation claims and compensation payments thanks to more reliable activation and billing processes
  • Compliant contracts and customer communications, with less exposure to penalties from AGCOM and AGCM, the Italian competition authority
  • Regulatory deadlines managed in advance: ROC, the annual contribution, periodic reporting and quality indicators
  • Quality indicators and response times measured and comparable with the publication obligations
  • A single point of contact for regulation, processes, privacy and security, without duplicating controls and procedures

Deliverables

What we deliver

  • Regulatory and operational assessment report with a prioritised action plan
  • Revised general terms and conditions, contract summary and pre-contractual information
  • Service charter and procedures for complaints, compensation and conciliation (ConciliaWeb, CoReCom)
  • Operating procedures for activation, migration, portability and termination
  • Billing, reminder, suspension and debt recovery procedure
  • Calendar of obligations towards AGCOM and the Ministry: ROC, annual contributions, reporting and quality indicators
  • Dashboard of quality indicators and response times, with periodic reporting for management
  • Training for customer care, back office and sales, with materials and certificates of attendance

Frequently asked questions

Answers to the questions we hear most often

Many service failures depend on our wholesale provider: what can you do?

We analyse the wholesale contract and the service levels, measure where orders stall and for what reasons, and build the evidence the operator needs in order to pursue claims for the rejected orders attributable to the provider. As far as the end customer is concerned, however, it is the operator that must respond within the timescales of the service charter: this is why we also work on the internal processes for monitoring orders and communicating with the customer.

We receive a large number of ConciliaWeb claims: how can we reduce them?

Conciliation claims are almost always the last link in a chain: late activations, unclear invoices, complaints left unanswered within the deadlines. We analyse the claims by cause, act on the processes that generate them and structure complaint handling so that cases are closed at the first stage. The result is measured in the fall in claims and compensation payments.

Can we hand over the management of reporting and contributions to AGCOM and the Ministry?

Yes. We build a calendar of obligations (general authorisation and administrative fees, ROC, the AGCOM contribution, periodic reporting, quality indicators, the service charter) and prepare the filings together with the operator’s administrative and legal contacts. Responsibility remains with the operator; we bring method, firm timescales and supporting documentation.

We already have a DPO and a security manager: how do you work with them?

We do not replace them. We share the map of processes and systems with the DPO and the security manager, so that the risk analysis, the incident management procedure and the registers remain single documents that serve the AGCOM, GDPR and NIS2 obligations together. Where these roles are missing or need strengthening, we can support them through our outsourced DPO and NIS2 compliance services.

What happens if AGCOM or AGCM open proceedings against us?

We support the operator, alongside its lawyers, in reconstructing the facts, gathering the documentation and preparing the written submissions. Above all, we support the definition of the corrective measures to be presented to the Authority. An orderly system of procedures and records makes it far easier to demonstrate the diligence of the operator.

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.