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.