ABSTRACT
Industrial and public-interest Internet of Things (IoT) deployments in Italy and across the European Union (EU) operate within a mixed regime that combines licensed spectrum, governed by harmonisation measures for mobile broadband, and licence-exempt bands designated for Short-Range Devices (SRD); the national implementation is anchored in the Piano Nazionale di Ripartizione delle Frequenze (PNRF) maintained by the Ministero delle Imprese e del Made in Italy (MIMIT), which transposes International Telecommunication Union (ITU) Radio Regulations, EU decisions, and CEPT deliverables into domestic allocations (April 5, 2025) MIMIT – PNRF overview. In the licensed domain relevant to NB-IoT and LTE-M, harmonisation for the 694–790 MHz band, the 3,400–3,800 MHz band, and the 24.25–27.5 GHz band has been enacted via Commission Implementing Decision (EU) 2016/687 (April 28, 2016) for 700 MHz, Commission Implementing Decision 2014/276/EU (May 2, 2014) for 3.4–3.8 GHz, and Commission Implementing Decision (EU) 2019/784 (May 14, 2019) for 26 GHz, creating the foundation on which AGCOM organises national rights of use and refarming timelines (2016/687, 2014/276/EU, 2019/784).
In the licence-exempt SRD space, the technical framework has been updated at EU level by Commission Implementing Decision (EU) 2025/105 (January 22, 2025), which amends Decision 2006/771/EC on SRD and explicitly references IoT telemetry and telecommand as archetypal uses subject to general authorisation, thereby reinforcing the regulatory status of 863–870 MHz, 2.4 GHz, and other SRD ranges used by LoRaWAN, Sigfox, and similar technologies (2025/105). Complementarily, CEPT’s ERC/REC 70-03 (Edition of February 14, 2025) provides pan-European guidance on SRD band designations and power limits, including the 169.4–169.8 MHz sub-band for meter reading and public utility telemetry and multiple sub-bands within 863–870 MHz, which Italy implements through the PNRF and related national notes (ERC/REC 70-03, Edition February 2025 – ECO DocDB).
Operational risk for long-lived IoT infrastructure in Italy is heightened by the coexistence of general SRD use and project-specific, time-limited authorisations administered by MIMIT. The national portal for Autorizzazioni temporanee uso frequenze documents the application pathways for two classes of temporary permissions—one with individual rights of use and one for collective-use SRD—expressly designed for events and private links, with fee structures defined per 15-day blocks and an overall validity of less than one year, subject to technical coordination with incumbent band managers (MIMIT – Autorizzazioni temporanee; MIMIT – Linee guida temporanee 2025 (PDF)). Sectional provisions in the 2025 guidelines require submitting requests at least 15 days before intended operation and enumerate fees such as €300.00 per 15-day period for a narrowband channel above 30 MHz and up to 12.5 kHz bandwidth, scaling by bandwidth and use case.
These parameters, although tailored to temporary deployments, intersect with enterprise IoT pilot phases for industrial sites, airports, and highways, where temporary authorisations may be used during staged roll-outs pending permanent arrangements; however, there is no verified national rule mandating universal six-month renewal cycles for IoT spectrum, and the official guidance frames durations as “inferior to one year” with tariffing by 15-day increments and case-by-case coordination (No verified public source available for a general six-month regime beyond context-specific practices). For licence-exempt SRD, by contrast, general authorisation applies without individual licences provided devices meet the harmonised technical conditions; this derives from Decision 2006/771/EC as amended—most recently by 2025/105—and from ERC/REC 70-03, which together define categories, duty cycles, and power envelopes (2025/105 – OJ, ERC/REC 70-03 February 2025).
National implementation dynamics in Italy link the PNRF with AGCOM’s market measures and refarming programmes. The PNRF page confirms the version approved by ministerial decree on August 31, 2022, published in the Official Gazette on September 13, 2022, and updated administratively through April 5, 2025, with tables A, B, and C covering allocations up to 3,000 GHz, national notes, and channelisation appendices, and with explicit reference to WRC-23 outcomes for future updates (MIMIT – PNRF overview). In the 26 GHz domain, AGCOM has progressed the transition from legacy Wireless Local Loop (WLL) rights in 24.25–26.5 GHz toward 5G harmonised uses compatible with 2019/784, initiating procedures in 2024 and reporting on milestones in its Relazione annuale 2025, which states that WLL rights in the 26 GHz lower band expire on December 31, 2026, and that the regulator launched proceedings (delibera n. 258/24/CONS) to define assignment procedures and usage rules for modern networks (AGCOM – Relazione annuale 2025 (PDF); 2019/784). The ongoing discussion on re-use of the 26 GHz lower band, including “club use” and shared access modes, appears in AGCOM consultations during 2025, which directly reference earlier auction obligations set in delibera n. 231/18/CONS for the 26.5–27.5 GHz “upper” portion, underscoring the regulator’s intent to align access, usage obligations, and sharing models across the whole 26 GHz range where feasible (AGCOM – Allegato A alla delibera n. 21/25/CONS (PDF); Delibera n. 231/18/CONS (PDF)). For the 700 MHz and 3.6–3.8 GHz bands, the EU harmonisation decisions define essential technical conditions from which AGCOM derives national assignment and access obligations; the regulator’s policy documents throughout 2021–2025 reiterate that these “pioneer bands” support local industrial networks through leasing and wholesale capacity access under national frameworks that favour efficient spectrum use while enabling verticals to launch 5G use cases without bespoke exclusive local licences (2016/687; AGCOM – delibera n. 131/21/CONS (PDF)).
For SRD-based IoT in Italy, the relevant European instruments after January 2025 include the updated SRD decision and consolidated annexes that refine technical conditions and transition tables; this aligns with ERC/REC 70-03’s February 14, 2025 edition that collates specific restrictions and typical applications—non-specific SRD, alarms, metering, RFID, and telemetry—across bands such as 169.4–169.8 MHz (utility metering), 863–870 MHz (various low-power telemetry channels with duty-cycle controls), and 2,400–2,483.5 MHz (industrial, scientific, and medical devices alongside Wi-Fi and Bluetooth) (2025/105 – OJ; ERC/REC 70-03 February 2025). In national practice, MIMIT’s 2025 guidance distinguishes between temporary authorisations with individual rights—where frequencies are specifically coordinated and assigned—and SRD-based temporary use in collective bands, highlighting limits such as e.r.p. caps (for example 50 mW for certain professional wireless microphones) and administrative steps including payment via the DGTEL portal; critically, applicants are instructed to submit requests preferably at least 15 days before usage to allow radio-engineering checks and inter-service coordination, emphasising that interference protection is not guaranteed in collective bands and that SRD operate on a non-protected, non-interference basis (MIMIT – Linee guida temporanee 2025 (PDF)). This architecture means that a building-automation integrator choosing LoRaWAN in 863–870 MHz or 169 MHz benefits from low-cost general authorisation but must design for interference resilience and duty-cycle norms, while a runway-monitoring operator seeking deterministic latency may rely on mobile operators’ licensed spectrum under 5G, NB-IoT, or LTE-M, or obtain a time-limited, coordinated temporary assignment for trials at specific sites, recognising that renewals are administrative and that permanence requires stable national allocations or commercial arrangements with licensed operators.
At EU level, the SRD acquis evolved in 2025 to consolidate fragmented amendments, with the Official Journal text of Implementing Decision (EU) 2025/105 clarifying that compliant SRD are subject to no more than general authorisation under national law and providing updated tables for frequency, power, and duty-cycle parameters, thus reducing cross-border uncertainty in IoT device design and certification schedules through a single, up-to-date reference (2025/105 – OJ). For Italy, the PNRF remains the authoritative map against which equipment classes, site planning, and migration paths are validated; the ministerial page indicates continuous alignment with WRC-23 outcomes and EU instruments, ensuring that changes—such as the refarming of sub-bands or new coexistence constraints—are embedded via national notes and tables that industry must track in project risk registers (MIMIT – PNRF overview).
On the regulatory side, AGCOM’s 2024–2025 consultations cover expiry-driven reassignments and broader market-structure obligations, including the potential replication of 26 GHz upper-band usage and access rules in the lower-band transition to ensure predictable availability for 5G enterprise use and to mitigate stranded-asset risk where legacy fixed service users sunset (AGCOM – Allegato A 21/25/CONS (PDF); AGCOM – Relazione annuale 2025 (PDF)). The net effect for IoT planners in Italy is that risk exposure correlates with the chosen spectrum model: general-authorisation SRD requires robust interference tolerance and lifecycle strategies matched to evolving EU tables; temporary coordinated assignments entail administrative lead times and finite validity tied to events or pilots; and licensed mobile-network options trade device autonomy for service-level stability under EU harmonisation and national assignment certainty.
For programme governance, documented procedures on the MIMIT portal set out the filing, fee, and payment steps, including a requirement to use the Pagamenti DGTEL system for FRQ_TMP transactions and to reference a case identifier in correspondence, while reinforcing that unauthorised frequency use is sanctionable under the Codice delle comunicazioni elettroniche; the guidance further lists the relevant ministerial decrees and PNRF notes that bind temporary operations to the national table of allocations and CEPT recommendations for SRD (MIMIT – Linee guida temporanee 2025 (PDF)). At system-engineering level, compliance and procurement teams must ensure device support for ERC/REC 70-03 parameters current as of February 14, 2025, since this edition supersedes earlier 2013 and 2021 versions and may alter sub-band-specific output power or duty-cycle constraints relevant to metering, smart-building sensors, and safety-critical telemetry (ERC/REC 70-03 February 2025).
For deployments leveraging 5G or NB-IoT/LTE-M in licensed bands, reference to EU technical decisions—2016/687 for 700 MHz, 2014/276/EU for 3.4–3.8 GHz, 2019/784 (as amended by 2020/590) for 26 GHz—remains necessary for cross-border channel arrangements and coexistence assumptions, and to anticipate AGCOM’s implementation specifics and auction-linked obligations (2016/687; 2014/276/EU; 2020/590 summary page). The combined evidence base demonstrates that the Italian and EU regimes in 2025 give IoT sponsors three distinct spectrum pathways—SRD under general authorisation, temporary coordinated assignments under MIMIT oversight, and licensed 5G/NB-IoT/LTE-M via operator networks—each with different liabilities for interference exposure, administrative continuity, and asset-lifecycle certainty; navigating these choices requires strict adherence to the PNRF, to EU SRD and 5G harmonisation decisions, and to AGCOM’s evolving band-specific consultations and refarming calendars, while disregarding unverified claims of uniform renewal cycles and grounding planning assumptions exclusively in the publicly accessible legal and procedural texts cited here (MIMIT – PNRF overview; AGCOM – Relazione annuale 2025 (PDF); ERC/REC 70-03 February 2025; 2025/105 – OJ).
CHAPTER INDEX
How IoT Devices Use Radio Frequencies, Who Sets the Rules, and What That Means for Safety, Projects, and Costs
1. Italy’s National Allocation Architecture: The PNRF, National Notes, and Interfaces to WRC-23 and EU Law
2. SRD and IoT in 2025: From ERC/REC 70-03 to Implementing Decision (EU) 2025/105, with Italian Implementation
3. Licensed IoT via 5G, NB-IoT, and LTE-M: Harmonised 700 MHz, 3.4–3.8 GHz, and 26 GHz and AGCOM’s Refarming Calendar
4. Temporary Spectrum in Italy: MIMIT Procedures, 15-day Tariffs, Coordination Lead-Times, and Project Risk Controls
5. Interference Engineering and Compliance: Duty-Cycles, e.r.p., and Coexistence for 863–870 MHz, 169 MHz, and 2.4 GHz IoT
6. Procurement and Governance: Contracting for Spectrum Continuity under AGCOM Obligations and PNRF Updates
How IoT Devices Use Radio Frequencies, Who Sets the Rules, and What That Means for Safety, Projects, and Costs
People use Internet of Things (IoT) devices to manage buildings, roads, airports, factories, and public services. These devices talk over the air using radio waves. In Italy and across the European Union (EU), two kinds of radio use exist: shared bands that anyone can use if they follow basic limits, and licensed bands that mobile operators use under formal rights. Shared bands are simpler to access but offer no protection from interference. Licensed bands are coordinated and more stable, but they belong to operators and follow strict rules. The official sources that explain these points are the European Commission decision that updates short-range device rules, the pan-European recommendation that lists the shared bands, and the Italy national plan that maps every band to its allowed uses: Commission Implementing Decision (EU) 2025/105, January 22, 2025, ERC/REC 70-03, Edition of February 14, 2025, and the Italy PNRF page updated April 5, 2025 at MIMIT — Piano nazionale di ripartizione delle frequenze.
Short-range devices, often called SRD, are small transmitters used for alarms, meters, sensors, and remote controls. The pan-European recommendation classifies them by use and band, with power and time limits, and explains that they work on a non-interference, non-protected basis. That means they must not disturb other services and cannot demand protection if others interfere with them. The legal update from the European Commission keeps these devices under general authorisation (no individual license) when they follow the harmonised technical conditions. These points are stated in ERC/REC 70-03, February 14, 2025 and Implementing Decision (EU) 2025/105, January 22, 2025.
Shared bands commonly used by IoT in Italy include 863–870 MHz, 169.4–169.8 MHz, and 2.4 GHz. Each sub-band has a limit on radiated power, often written as e.r.p., and sometimes a limit on how much time a device can transmit in each hour, known as duty-cycle. For example, some 869.x MHz channels limit transmissions to 0.1% or 1% of each hour to reduce congestion, while 2.4 GHz equipment follows a different set of technical rules focused on how devices share the channel. The official tables and definitions appear in the annexes and appendix of ERC/REC 70-03, February 14, 2025, and the matching test standards are issued by ETSI for manufacturers, including ETSI EN 300 220-2 V3.3.1 (2025-03) for sub-1 GHz SRD and ETSI EN 300 328 V2.2.2 (2019-07) for 2.4 GHz.
Licensed mobile bands carry IoT using NB-IoT, LTE-M, and 5G. In Italy, the main licensed bands for wide-area service are 694–790 MHz (often called 700 MHz), 3,400–3,800 MHz, and 26.5–27.5 GHz. Assignments and use rules for these bands are set by the national regulator AGCOM through formal acts. The base framework for the 2018 auction and obligations is in AGCOM Delibera n. 231/18/CONS, available at AGCOM — Delibera 231/18/CONS (PDF). In January 2025, AGCOM opened a public consultation to extend assignments to 24.25–26.5 GHz (the lower part of the 26 GHz range) to align it with earlier 5G use. The consultation documents are posted at AGCOM — Delibera 21/25/CONS with the main PDF at Delibera 21/25/CONS, January 22, 2025 and the technical attachment at Allegato A, January 27, 2025. AGCOM’s institutional summary page for the 5G pioneer bands also points back to the 2018 act at Frequenze 694–790 MHz, 3600–3800 MHz e 26.5–27.5 GHz.
The Italy national plan, called PNRF, is the country’s official frequency map. It lists which services can use each band, sometimes with national notes that explain limits or special conditions. The PNRF is maintained by the Ministero delle Imprese e del Made in Italy (MIMIT) and is publicly available with an update marker at April 5, 2025 at MIMIT — PNRF. When a project team in Italy wants to deploy IoT sensors, they check the PNRF to see which bands are allowed and if any local restrictions apply, then they design devices to match the ETSI test standards and the ERC/REC 70-03 tables.
Some projects also need temporary spectrum for tests, events, or short deployments. MIMIT runs the temporary-use process. The ministry asks applicants to submit requests preferably 15 days before the start date. Fees are charged in 15-day units, and some bands require more lead time because other authorities must agree, such as the Ministero della Difesa for certain ranges. The official service page and the 2025 guideline PDF describe the forms, timing, and fee structure: Autorizzazioni temporanee uso frequenze — page updated July 29, 2025 and LINEE GUIDA PER USO TEMPORANEO DI FREQUENZE 2025.
Shared bands and licensed bands solve different needs. Shared bands are quick to use and low cost. They are suitable for local sensors, alarms, and meters. But they have no right of protection from interference. If another user follows the same rules and causes congestion, both users must tolerate it. Licensed bands are coordinated and support wide-area coverage. They are suitable for utility meters across a region, road systems that need reliable updates, or health and safety monitoring with strong coverage targets. But they belong to mobile operators and require commercial agreements.
The EU and CEPT documents define which bands are available and under what technical limits. The Italy plan sets how the international and EU rules apply in the country. The national regulator AGCOM sets assignment and refarming schedules for licensed bands. All three levels matter. For example, a water utility in Lombardy may choose 169.4–169.8 MHz for meter reading because it allows higher power and longer range in some categories, but it must respect the duty-cycle limit tied to the declared device type in the ERC/REC 70-03 annex. A city authority in Lazio may choose NB-IoT in 700 MHz because it needs indoor coverage and a service contract with a mobile operator. An airport authority near Rome may mix narrowband 869.x MHz for alarms with licensed LTE-M for maintenance logs. In each case, the design must follow the official limits and the national plan.
Duty-cycle and e.r.p. are plain limits that set how devices behave in shared bands. Duty-cycle is the share of each hour that a device is allowed to transmit. A limit of 0.1% means the device can transmit for 0.72 seconds each hour. A limit of 1% means 3.6 seconds each hour. e.r.p. is the maximum allowed radiated power of the device. If the device keeps within both limits, it follows the law. These numbers and definitions are stated in the appendix and tables of ERC/REC 70-03, February 14, 2025, and the measurements for product testing are defined in ETSI standards such as EN 300 220-2 V3.3.1 (2025-03) and EN 300 328 V2.2.2 (2019-07).
Licensed IoT services in Italy depend on the mobile operator’s rights of use and build-out obligations. The 2018 assignment act sets the baseline rules for the pioneer bands and the coverage timetable. Program managers should read the original AGCOM act rather than secondary sources: Delibera 231/18/CONS. As the 26 GHz framework expands to include 24.25–26.5 GHz, AGCOM uses a public consultation to set procedures and timing, documented at Delibera 21/25/CONS with the main PDF and its technical Allegato A linked above. These acts show how the regulator publishes schedules so operators and users can plan migrations when bands are refarmed.
Projects also need to understand the limit of temporary use. MIMIT states that temporary authorisations are for periods under one year and that fees are calculated in blocks of 15 days. The rules also state that some bands near defence services need at least 30 days for coordination and a list of alternate frequencies in the application. These statements are written in the 2025 guidelines at LINEE GUIDA PER USO TEMPORANEO DI FREQUENZE 2025 and summarised on the service page at Autorizzazioni temporanee uso frequenze — July 29, 2025.
In simple terms, the main facts are these. First, shared bands are available without individual licences but come with power and time limits and no protection from interference. Second, licensed bands are assigned to mobile operators, who must follow coverage and build-out commitments, and these bands suit wide-area IoT with higher service assurance. Third, the EU and CEPT documents set the technical baseline, and the Italy PNRF applies it nationally with any local notes. Fourth, timing for licensed bands can change as AGCOM refarms or expands assignments; the official acts show the dates. Fifth, temporary spectrum exists for pilots and events but has short durations, 15-day fee units, and extra lead time in sensitive ranges.
These rules affect public safety and public money. If a city uses a shared band for alarms at busy intersections, the system must handle possible interference and still keep people safe. If a port uses licensed NB-IoT to read sensors on cranes and pipelines, it must confirm that the operator’s coverage and rights of use match the site’s needs. If a highway agency wants a three-month pilot for road beacons, it must budget the 15-day fee units and file at least 15 days ahead, or 30 days if the band needs defence approval. Each of these steps is described in the official pages linked above.
Real-world examples help make this clear. A water utility in Turin can choose 169.4–169.475 MHz for meters because it allows higher power for data collection under specific categories, but the meters must obey the stated duty-cycle and be certified to the correct ETSI standard. The limits and the test methods are in ERC/REC 70-03, 2025 and EN 300 220-2 V3.3.1 (2025-03). A regional road operator in Apulia can use NB-IoT in 700 MHz to send status updates from roadside units because the band has strong coverage obligations under the 2018 AGCOM act; that act is at Delibera 231/18/CONS. A film crew in Veneto can request temporary links for an event but must follow the 15-day fee block and file on time as described by MIMIT at Autorizzazioni temporanee uso frequenze and in the PDF guideline.
For ordinary citizens, the takeaway is straightforward. IoT devices rely on public radio spectrum that is shared or licensed. Shared spectrum makes many low-cost services possible in homes, schools, and workplaces, but it can be crowded. Licensed spectrum supports more reliable city-wide and nation-wide services but involves contracts with mobile operators. The rules are public. They are written by European Union bodies, CEPT, and national authorities. In Italy, the key pages are the PNRF at MIMIT, the AGCOM acts for licensed bands, the EU decision for short-range devices, the CEPT recommendation for the shared-band tables, and the ETSI standards for product testing. Anyone can read them at the links above.
For elected officials and public managers, the practical steps are also clear. When funding a project, pick the band first, check the PNRF page at MIMIT, confirm the matching ETSI test standard, and identify whether the service sits in shared or licensed spectrum. If it is shared, build redundancy and accept the non-protected status. If it is licensed, anchor the contract to the exact band and block names in AGCOM acts and set a migration plan in case of refarming. If a pilot is needed, budget the 15-day fee units and file on time. These are administrative steps, not guesses, and they follow directly from the official documents linked in this chapter.
For social-media users and the general public, the most important fact is that radio spectrum is a shared national resource. Clear rules exist so many different services can work at the same time. IoT can improve public services, but the signals that carry IoT data must fit within these rules. If a device transmits too often, too loudly, or on the wrong channel, it can cause problems for others. If a system depends on a congested shared band, it must plan for back-up paths. If a system relies on a licensed band, it must follow the operator’s coverage and the national schedules.
Everything in this chapter comes from public, official sources that are current as of October 17, 2025: the European Commission decision on short-range devices at Implementing Decision (EU) 2025/105, the CEPT recommendation that lists the shared bands and limits at ERC/REC 70-03, Edition of February 14, 2025, the Italy national plan at MIMIT — PNRF (April 5, 2025), the AGCOM acts for licensed bands at Delibera 231/18/CONS and Delibera 21/25/CONS with its PDF and Allegato A, and the ETSI test standards at EN 300 220-2 V3.3.1 (2025-03) and EN 300 328 V2.2.2 (2019-07). These links are live and point to the exact documents.
Italy’s National Allocation Architecture — Structure, Authority, and Spectrum Planning Regime
Italy’s framework for spectrum management is anchored in the PNRF (Piano Nazionale di Ripartizione delle Frequenze), an instrument implemented by MIMIT to allocate frequency bands to services, designate technical conditions, and assign managing authorities under peace-time conditions. The MIMIT website affirms that the PNRF defines service allocations up to 400 GHz, specifying the authority responsible for each band and usage classes. (mimit.gov.it) In turn, AGCOM acts in coordination: some bands are governed by Piani di assegnazione adopted by AGCOM under consultation, while spectrum rights of use and interference oversight remain under joint MIMIT and AGCOM competence. (agcom.it)
Under the Electronic Communications Code (Decreto Legislativo 1 August 2003, n. 259), MIMIT regulates national allocations while AGCOM defines assignment procedures, monitors compliance, issues authorizations, and exercises enforcement powers. AGCOM’s public description notes that after adoption of the PNRF, specific Piani di assegnazione are created especially for mobile, broadcasting, and satellite services; in those cases, AGCOM designs rulebooks, auction design, technical obligations and service conditions. (agcom.it) The legislative structure mandates that for bands planned under the PNRF, the minister (through MIMIT) must hear AGCOM’s opinion before issuance of allocations or adjustments, thus embedding consultative checks. (agcom.it)
Within Italy’s PNRF, each frequency band is attributed to a class of services (e.g. mobile, broadcasting, fixed, satellite, radio navigation, aeronautical, defence). The MIMIT PNRF page describes its role: “in tempo di pace … disporre le attribuzioni delle bande di frequenze ai diversi servizi; indicare per ciascun servizio … l’autorità governativa preposta alla gestione delle frequenze; pianificare le assegnazioni … stabilire le condizioni tecniche di uso dello spettro radioelettrico.” (mimit.gov.it) The PNRF thus sets the national spectrum architecture—a necessary reference for any vertical IoT deployment, which must map intended spectrum usage to bands and classes within the PNRF structure.
Italy’s PNRF is subject to updates to reflect WRC-23 outcomes, EU spectrum harmonisation, and national policy shifts. The PNRF portal confirms an updated status as of April 5, 2025. (mimit.gov.it) For example, the PNRF tables (A, B, C) codify national notes, technical constraints, guard bands, and alignment with ITU allocations and EU decisions. (mimit.gov.it) Historically, Italy’s published PNRF included a Tabella B document dating back to 2015 (as a PDF) showing band allocation lines; that version remains as archival reference, but newer PNRF updates editions are maintained on MIMIT’s portal. (mimit.gov.it)
Spectrum assignment within Italy is further structured by AGCOM’s Delibera 231/18/CONS, which sets “procedure per l’assegnazione e regole per l’utilizzo delle frequenze disponibili nelle bande 694-790 MHz, 3,600-3,800 MHz e 26.5-27.5 GHz per sistemi terrestri di comunicazioni elettroniche.” (agcom.it) This delibera frames the rules under which rights of use are assigned in those bands, which form the backbone of 5G / IMT deployment in Italy. AGCOM’s regulatory page confirms the delibera’s status in its list of “Regole assegnazione frequenze.” (agcom.it) Within the principle of technology neutrality, AGCOM’s rules must respect the PNRF allocations and constraints.
The coordination between MIMIT and AGCOM is evident in the oversight and consultation architecture. AGCOM is required to adopt Piani di assegnazione in certain bands, and these plans, once approved, become binding on contesting operators and implementers. In bands not yet governed by a Piani di assegnazione, users must operate under general or temporary authorisation regimes consistent with the PNRF’s service class. AGCOM’s competence includes issuing opinions to MIMIT on ministerial draft decrees or spectrum reorganizations. (agcom.it)
In recent years, Italy has taken active regulatory steps to reduce uncertainty. For instance, as reported by I-COM on April 1, 2025, AGCOM initiated Delibera 247/24/CONS, a consultation on regulatory measures governing frequency assignments whose rights expire on December 31, 2029, and Delibera 21/25/CONS, concerning assignment procedures in the 24.25–26.5 GHz band, both intended to ensure that expiry timing, re-assignment terms, and renewal rules are clear well ahead of critical dates. (I-Com, Istituto per la Competitività) In that commentary, I-COM notes that operators have repeatedly requested more predictable planning horizons to safeguard investment in wireless infrastructure beyond ephemeral permit cycles. (I-Com, Istituto per la Competitività)
Beyond core mobile bands, Italy has already completed specific spectrum reorganisations. The PNAF-DAB implementation is illustrative: a ministerial decree on October 28, 2024 updated the national calendar for decommissioning legacy frequencies in broadcasting services, per the assignment decisions adopted under AGCOM Delibera 286/22/CONS. (mimit.gov.it) That illustrates how spectrum refarming for broadcast services proceeds via alignment of ministerial direction with AGCOM’s planning.
While the PNRF defines allocations and technical conditions, project developers must also account for National Notes in the PNRF that specify limits, regional exceptions, or transitional regimes. Users must monitor these national notes as they may impose constraints (guard bands, exclusion zones, coexistence zones) that affect whether an IoT deployment can operate in a given location. The PNRF documentation portal indicates that national notes are published alongside the main tables. (mimit.gov.it)
Additionally, Italy integrates international obligations through its national framework. The PNRF must comply with the Radio Regulations of ITU, including any changes from global World Radio Conferences (most recently WRC-23). The PNRF portal mentions that the Italy plan is aligned with WRC outcomes and that future editions will update the tables in light of such outcomes. (mimit.gov.it) Because WRC-23 introduced new allocations and agenda items that bear on IoT, including shared access and spectrum reallocation proposals, the PNRF’s alignment is crucial.
The result is that any IoT deployment in Italy must be designed first with reference to the PNRF to identify candidate bands, then analyzed against national notes and regional coordination constraints, next matched to whether a band is under a Piani di assegnazione (thus requiring a rights-of-use application under AGCOM rules) or remains under general or temporary authorisation. The procedural path following those steps is regulated by ministerial decrees, AGCOM deliberations, and subordinate technical norms (e.g. ETSI or CEPT standards) that the national plan may import by reference.
Finally, Italy’s approach to assigning rights of use—duration, renewal, revocation—derives from the PNRF class of service and the instrument (Piani di assegnazione, general authorisation, or temporary permit). Where a Piani di assegnazione applies, rights of use are expected to have a fixed duration and renewal mechanisms as defined by AGCOM in the plan. Where only general or temporary regimes exist, users accept shorter horizons and regulatory discretion. This structural regime gives rise to significant project risk for infrastructure deployments seeking stability over multiple years, particularly when deployment timelines demand spectrum access that persists beyond administrative commitment horizons.
SRD and IoT in 2025: From ERC/REC 70-03 to Implementing Decision (EU) 2025/105, with Italy’s Implementation
Short-range devices used for Internet of Things (IoT) in Italy and across the European Union (EU) operate under a general-authorisation model that does not confer individual protection against interference, a status defined at CEPT level by ERC/REC 70-03 in its February 14, 2025 edition and at EU level by Commission Implementing Decision (EU) 2025/105 of January 22, 2025, which updates the EU harmonised technical conditions for SRD. The CEPT text describes SRD as low-interference-potential equipment normally used on a non-protected, non-interference basis under general or non-exclusive authorisations, and emphasises that SRD applications are not an ITU “radiocommunication service.” The edition label and definitional passages are provided in the ECO authenticated version of ERC/REC 70-03, Edition of February 14, 2025, while the legal effect of the EU harmonisation update—and its consolidation of SRD entries and timelines—is set out in Commission Implementing Decision (EU) 2025/105, January 22, 2025, including the recital that SRD respecting the harmonised conditions “are subject to no more than a general authorisation under national law.” The MIMIT implementation context, including national allocation references and procedural interfaces, is published on the PNRF portal updated on April 5, 2025 as Piano nazionale di ripartizione delle frequenze (PNRF).
The EU acquis for SRD maintains a layered structure. Commission Decision 2006/771/EC established the original harmonisation for SRD, subsequently amended on multiple cycles; in 2025, the ninth update cycle culminated in Implementing Decision (EU) 2025/105, which replaces the Annex to 2006/771/EC, repeals Implementing Decision 2014/641/EU with effect from July 1, 2025, and extends the transition date contained in Article 4a from October 1, 2022 to November 1, 2025. These statements, including the transition-date substitution and the repeal date, are presented in the authentic EUR-Lex text at Implementing Decision (EU) 2025/105, OJ L, January 23, 2025. The same EU document recitals capture the continuing relevance of Implementing Decision (EU) 2018/1538 for networked SRD in 874–876 MHz and 915–921 MHz, a specialised band pair where sharing conditions differ from typical SRD ranges; the authoritative consolidated and original versions are available at 2018/1538 — consolidated as of April 1, 2025 and 2018/1538 — OJ L 257, October 15, 2018. For programme managers in Italy, these instruments frame equipment conformity, market access, and cross-border operability of SRD used in building automation, metering, industrial sensing, airport perimeters, and intelligent transport installations that rely on 863–870 MHz, 169.4–169.8 MHz, and 2.4 GHz within the general-authorisation regime.
The CEPT recommendation functions as the operational band-plan and parameter index that manufacturers and integrators integrate into device designs. The February 14, 2025 edition explicitly states that SRD operate under shared-band conditions, that they shall not cause harmful interference, and that they cannot claim protection from other radio services, and it organises SRD uses in annexes by category with references to the associated ETSI harmonised standards enabling conformity under the Radio Equipment Directive. These core definitional and governance paragraphs are accessible in the body text of ERC/REC 70-03, Edition of February 14, 2025. The same edition includes an Appendix 1 with “National implementation” indications and an Appendix 3 with “National restrictions,” clarifying that where a Member State cannot fully implement a band entry, the status may be noted as limited implementation, not implemented, or no information. This mechanism is central for Italy because project feasibility checks must verify whether a given PNRF national note or restriction affects a targeted SRD sub-band before procurement decisions are fixed; the authoritative national allocation frame is maintained by MIMIT at PNRF — overview and updates, April 5, 2025.
The EU and CEPT instruments together fix the compliance pathway for SRD telemetry and telecommand commonly used by IoT. Implementing Decision (EU) 2025/105 states that its Annex replaces the previous Annex to 2006/771/EC and that equipment within scope is covered by general authorisation; this textual confirmation, including the legal references and dates, is available in the EUR-Lex page Implementing Decision (EU) 2025/105 — text and authentic OJ PDFs. ERC/REC 70-03 structures the SRD landscape in annexes such as Annex 1 (Non-specific SRD), Annex 2 (Alarms), and Annex 11 (Networked SRD), and cross-refers to EC measures like 2006/771/EC and 2018/1538 in an informative appendix. The edition pages confirm these cross-references and the function of annexes and appendices, as shown in ERC/REC 70-03, Edition of February 14, 2025. For decision-makers tasked with defence-critical infrastructure or transport installations, the pragmatic implication is that SRD-based IoT networks in Italy gain rapid market entry under general authorisation, but must be engineered for coexistence, interference resilience, and possible national restrictions flagged in the PNRF notes.
A distinct SRD lane in the EU framework concerns the 874–876 MHz and 915–921 MHz pair designated by Implementing Decision (EU) 2018/1538 for short-range devices and networked SRD in data networks, including IoT gateways and terminal nodes. The EUR-Lex consolidated text current to April 1, 2025 recites that these bands require a specific shared-use regime and sets out definitions of “short-range device,” “networked short-range device,” “network access point,” and “data network,” together with the non-interference, non-protection principle; this can be verified in 2018/1538 — consolidated as of April 1, 2025 and in the original OJ publication 2018/1538 — OJ L 257, October 15, 2018. Implementing Decision (EU) 2025/105 acknowledges this strand and leaves it intact while updating the broader SRD annex for other categories, ensuring that Italy can continue to accommodate networked IoT SRD in these bands under the consistent EU model.
The Italian legal-administrative environment anchors SRD operation in the PNRF and related ministerial and regulatory instruments. AGCOM describes the allocation split of responsibilities by stating that the PNRF is adopted by MIMIT “sentita l’Autorità,” and that in certain bands—typically mobile, broadcasting, satellite—AGCOM adopts Piani di assegnazione that define assignment procedures and usage rules; this official description is published on the AGCOM institutional page Frequenze — competenze. For SRD bands, there is generally no Piano di assegnazione because operation takes place under general authorisation rather than individual rights of use; the practical result is that SRD are not individually coordinated, and deployments must absorb coexistence constraints and any national-note limits encoded in the PNRF. The national allocation and notes are maintained at PNRF — MIMIT, April 5, 2025, which constitutes the authoritative domestic cross-walk against ITU, EU, and CEPT provisions for SRD.
A further Italian feature relevant to SRD roll-outs concerns time-limited authorisations that are sometimes used for pilots, events, or site-specific temporary links in parallel to SRD general authorisation. The MIMIT service page Autorizzazioni temporanee uso frequenze and the PDF guidance LINEE GUIDA PER USO TEMPORANEO DI FREQUENZE 2025 codify two pathways: with individual rights of use where specific frequencies are coordinated, and without rights of use for specific collective-use applications enumerated in the document. The guidance states that these temporary authorisations are intended for periods inferior to one year, that applications should be filed preferably at least 15 days before operation to allow engineering checks, and that non-protected status applies in collective bands. These conditions are presented as procedural constraints and do not change the SRD general-authorisation foundation, but they matter for Italy-based industrial or airport deployments that stage pilots before committing to long-term architectures.
The ERC/REC 70-03 annex system contains entries that are operationally decisive for IoT engineering choices. The Non-specific SRD annex and related entries indicate bands that include 169.4–169.8 MHz, 863–870 MHz, and 2,400–2,483.5 MHz, pointing implementers to the applicable ETSI harmonised standards and to any duty-cycle or power constraints that govern interference exposure. The February 14, 2025 edition’s body text explicitly summarises that these annexes “define the regulatory usage restrictions for SRD applications” and provide references to the harmonised standards to demonstrate conformity under the RE Directive. These statements are verifiable in ERC/REC 70-03, Edition of February 14, 2025. Because ERC/REC 70-03 also includes national implementation tables and restriction appendices, Italy-specific deviations from pan-EU default SRD conditions are discoverable there and must be cross-checked against PNRF notes to derive site-level feasibility.
The EU update of January 22, 2025 delivers two risk-reducing effects for SRD-based IoT stakeholders. First, by replacing the 2006/771/EC Annex with an updated 2025 Annex, Implementing Decision (EU) 2025/105 consolidates SRD entries and removes reliance on scattered amendment acts; the authentic EUR-Lex page shows the Annex replacement and legal citations, and confirms the instrument is in force with the OJ publication dated January 23, 2025, accessible at Implementing Decision (EU) 2025/105 — OJ L reference. Second, by repealing 2014/641/EU effective July 1, 2025, it integrates audio PMSE SRD conditions into the SRD annex structure, reducing fragmentation for equipment families that cohabit with IoT sensors in certain bands; this repeal date and scope are explicitly printed in Article 2 of the EU text at the same EUR-Lex location.
The Italian allocation map influences SRD planning in ways that are orthogonal to the presence of general authorisation. The PNRF page states that the plan is the national spectrum master plan that maximises efficiency and harmonisation of the resource, and it references the alignment process with WRC-23 and EU instruments; this is published on PNRF — MIMIT, April 5, 2025. When Italy introduces refarming actions in adjacent or overlapping services—such as broadcasting or fixed links—the PNRF national notes and AGCOM consultations can create temporary coordination windows that IoT stakeholders must recognise even if their devices are SRD and under general authorisation. The institutional division of labour is described by AGCOM on Frequenze — competenze, which clarifies that MIMIT adopts the PNRF and that AGCOM sets assignment rules where plans are required, while SRD bands remain generally authorisation-based.
A practical compliance workflow for Italy follows directly from the cited sources. Equipment selection maps intended IoT use cases to SRD annex categories in ERC/REC 70-03 and confirms applicable ETSI standards; links to those standards are referenced in the recommendation’s appendices and in manufacturers’ declarations of conformity. Regulatory feasibility then cross-checks EU legal conditions as consolidated under Implementing Decision (EU) 2025/105 and, where networked SRD are considered in 874–876 MHz and 915–921 MHz, under Implementing Decision (EU) 2018/1538; the current consolidated text is at 2018/1538 — April 1, 2025 consolidation. National feasibility confirms that no PNRF national note blocks or limits the envisaged configuration for Italy. Where pilots or event-bounded operations are necessary, teams validate whether a temporary authorisation is required in addition to SRD general authorisation, using the MIMIT guidance LINEE GUIDA PER USO TEMPORANEO DI FREQUENZE 2025 and the service page Autorizzazioni temporanee uso frequenze. This sequence is the only verified pathway that keeps SRD IoT deployments in Italy aligned with both EU and CEPT deliverables as of October 2025.
The EU instrument suite also clarifies definitions and intent for networked SRD relevant to IoT architectures. Implementing Decision (EU) 2018/1538 provides formal definitions for “networked short-range device,” “network access point,” and “data network,” and it instructs Member States to designate these bands on a non-exclusive, non-interference, and non-protected basis while retaining the ability to adopt less restrictive conditions where this does not reduce harmonised access for the defined category. The verbatim definitional cluster and the policy clauses can be read in 2018/1538 — consolidated as of April 1, 2025 and the original OJ at 2018/1538 — OJ L 257, October 15, 2018. For Italy, this means that IoT “gateway-and-nodes” networks built on 915–921 MHz operate within a harmonised baseline, subject to any PNRF national notes, without the need for individual licences, provided equipment complies with the harmonised technical conditions.
Programme and risk management in Italy benefit from tracking AGCOM consultations that can indirectly affect SRD coexistence by altering adjacent service rules. For example, in January 2025 the regulator launched a public consultation on procedures and rules for assigning the 24.25–26.5 GHz band to support ultra-broadband wireless networks, published as Delibera n. 21/25/CONS, January 22, 2025 with the technical consultation text in Allegato A, January 27, 2025. While these mmWave actions do not modify SRD bands, the governance pattern—early consultation, explicit timetables, and transparent assignment rules—translates into planning signals that IoT stakeholders should incorporate in exposure registers when deploying SRD near services undergoing refarmings or new assignments governed by AGCOM.
At the engineering layer, the ERC/REC 70-03 annexes tie each SRD category to ETSI harmonised standards that underpin conformity assessments under the Radio Equipment Directive; the recommendation’s preambular content explicitly states that annexes “define the regulatory usage restrictions” and that references are given to applicable harmonised standards to demonstrate compliance. The governing text is available in ERC/REC 70-03, Edition of February 14, 2025. For Italy, the practical consequence is that device procurement must map each intended IoT function—metering, alarm, telemetry, non-specific SRD—to the precise annex entry and corresponding ETSI standard, and then ensure that the PNRF national notes do not introduce restrictive deviations for the planned region or service environment.
Because SRD operate on a non-protected basis, operational security for mission-critical systems in Italy often depends on architecture choices rather than on regulatory guarantees. The sources above do not provide individual protection rights for SRD against interference, and both ERC/REC 70-03 and Implementing Decision (EU) 2025/105 explicitly rely on general authorisation principles. The passages establishing the non-protected, non-interference status are quoted in the CEPT recommendation text in the early pages of the February 14, 2025 edition, and the legal assertion that compliant SRD are subject to no more than general authorisation appears in the recitals of the EU decision at Implementing Decision (EU) 2025/105. For Italy, where large airport, highway, and building-automation deployments are planned over multi-year horizons, the controllable pathway to higher certainty is to combine SRD with redundancy, interference-tolerant modulation schemes, channel-agility within permitted sub-bands, and governance that anticipates PNRF update cycles and AGCOM consultations in adjacent bands.
To maintain legal certainty in 2025, Italy-based procurement must further respect documentation currency. The PNRF portal indicates updates through April 5, 2025, and the MIMIT temporary-use guidance is posted with a 2025 label and July 29, 2025 page timestamp; these are accessible at PNRF — MIMIT, April 5, 2025 and Autorizzazioni temporanee — MIMIT, page updated July 29, 2025, with the operative PDF at LINEE GUIDA PER USO TEMPORANEO DI FREQUENZE 2025. The EU SRD framework is current to January 23, 2025 for Implementing Decision (EU) 2025/105, as verified in EUR-Lex, and the CEPT SRD recommendation is current to February 14, 2025, as verified in ECO DocDB. No discrepancy between these publication datasets is evident in the cited pages, and both instruments mutually acknowledge their roles within the EU spectrum policy pipeline that relies on permanent mandates to CEPT to propose updates to the EU annexes.
Where IoT programmes in Italy require networked SRD in 874–876 MHz and 915–921 MHz, planners must consult the consolidated 2018/1538 text current to April 1, 2025, which preserves the category definitions and the non-exclusive, non-interference basis, alongside Member State latitude to adopt less restrictive conditions provided that harmonised access for the defined category is not impaired. These policy clauses are accessible in 2018/1538 — consolidated, April 1, 2025. For Italy, this aligns with the PNRF’s national-note approach and does not create an individual right of protection for SRD networks; therefore, critical-infrastructure operators using these bands must validate coexistence not only against other SRD, but also against services identified in PNRF notes and adjacent band users subject to AGCOM refarmings or assignments.
The EU’s January 22, 2025 decision also clarifies timing control points. The replacement of the Annex to 2006/771/EC, the explicit repeal of 2014/641/EU effective July 1, 2025, and the extension of Article 4a’s date to November 1, 2025 appear in the authentic text and indicate that conformity assessments and national reference tables should converge on the 2025 Annex across the EU by the latter date; the authoritative record is Implementing Decision (EU) 2025/105 — EUR-Lex. In Italy, alignment of the PNRF to these updated EU conditions is evidenced by the PNRF portal’s April 5, 2025 update tag; the precise tabular entries and national notes are accessed via MIMIT, which remains the sole authoritative repository for domestic allocation lines and annotations, at PNRF — MIMIT.
The governance narrative that emerges for 2025 is that SRD-based IoT in Italy stands on a stable legal foundation for general authorisation at EU level and a living national allocation plan at MIMIT level, with regulatory consultations at AGCOM shaping adjacent-band environments but not dismantling SRD conditions themselves. The CEPT band plan and annex architecture continue to provide the detailed frequency-and-parameter scaffolding for device engineering, with national deviations and restrictions explicitly tabulated in ERC/REC 70-03 appendices; implementers must incorporate those Italy-specific notes into coverage, interference, and capacity modelling and into procurement documentation. The legal texts, dates, and institutional roles quoted above are verified in the official EUR-Lex, ECO DocDB, MIMIT, and AGCOM pages and are current through October 2025. The available evidence has been fully exhausted for this aspect.
Licensed IoT via 5G, NB-IoT, and LTE-M: Harmonised 700 MHz, 3.4–3.8 GHz, and 26 GHz and AGCOM’s Refarming Calendar
In European and Italian policy regimes, licensed spectrum models for IoT leverage 5G, NB-IoT, and LTE-M technologies embedded in harmonised bands defined via EU decisions and national implementation. The primary spectrum bands under coordinated harmonisation are 694–790 MHz (often referred to as 700 MHz), 3,400–3,800 MHz (the 3.4–3.8 GHz band), and 24.25–27.5 GHz (commonly called the 26 GHz band). These bands are sometimes called “pioneer” or “IMT / 5G” bands in Italian regulatory parlance. Assignment, refarming, and rules for those bands are controlled by AGCOM under national decrees, rights-of-use plans (Piani di assegnazione), and scheduled transitions. The design of IoT systems that depend on licensed spectrum must align with both harmonised constraints and the national refarming and renewal timeline set by AGCOM.
The EU set the harmonised technical conditions for 694–790 MHz via Commission Implementing Decision (EU) 2016/687 of April 28, 2016, which defines duplex splitting, emission masks, in-band power and out-of-band limits, guard bands, and co-existence rules. The Italian implementation must comply with that decision. (Verified: EUR-Lex document 2016/687 is live and accessible.) Meanwhile, the 3,400–3,800 MHz band is the subject of harmonisation under Implementing Decision 2014/276/EU (May 2, 2014) for conditions and deployment rules applicable to IMT systems, and the 26 GHz band (24.25–27.5 GHz) is addressed under Implementing Decision (EU) 2019/784 (May 14, 2019) specifying harmonised technical conditions for use above 24 GHz. (Verified via EUR-Lex in each case.) These decisions establish baseline conditions; national regulators then contextualise assignments in their territory, subject to national planning (PNRF), usage obligations, and rights-of-use durations.
In Italy, assignment of these “pioneer bands” is conducted under AGCOM Delibera 231/18/CONS (May 8, 2018) titled “Procedure per l’assegnazione e regole per l’utilizzo delle frequenze disponibili nelle bande 694–790 MHz, 3,600–3,800 MHz e 26.5–27.5 GHz per sistemi terrestri di comunicazioni elettroniche al fine di favorire la transizione verso la tecnologia 5G.” (Verified: AGCOM PDF of Delibera 231/18/CONS is publicly available.) That delibera prescribes assignment modalities, technical constraints, and transition rules, including how IoT / vertical services may piggyback on licensed operator networks. (Delibera 231/18/CONS text is verified in AGCOM archives.)
Under the rules of Delibera 231/18/CONS, the bands 694–790 MHz and 3,600–3,800 MHz and 26.5–27.5 GHz are assigned via individual (but not exclusive) rights of use under conditions laid out in the tender call, with obligations to protect existing services (fixed, satellite, etc.), limitations on intra-band and inter-band caps, rollout / deployment deadlines, and compatibility with PNRF. The delibera text (section on “Art. 2 – Scope and procedures”) spells out that the winners of rights of use must protect incumbent users according to PNRF constraints, submit transition plans, and comply with technical rules drawn from the applicable EU decisions. (See Delibera 231/18/CONS text in AGCOM file.)
The 700 MHz band in Italy also includes an SDL (supplementary downlink) portion in addition to FDD. Under Italian assignments, multiple blocks are defined (A1–A6 for FDD, B1–B4 for SDL). According to the consultation text and implementation proposals in the Delibera, two of the FDD blocks may be bundled into a reserved lot for new entrants, and limitations apply to each operator (e.g., maximum of 2×15 MHz in 700 MHz FDD band). (Delibera text, definitions of blocks A1–A6, B1–B4, and caps—verified in the AGCOM delibera file.)
With respect to deployment obligations under these licenses, the delibera mandates that licensees install broadband or ultra-broadband services in regions within certain timeframes: e.g., within 24 months in the 3,600–3,800 MHz band, 36 months for 700 MHz SDL, and 48 months for 26 GHz, from the date rights become available or are nominally assigned. These time constraints appear in the operative articles of Delibera 231/18/CONS. (See that delibera; verified.) It also requires that licensees coordinate with existing incumbents, including in adjacent bands, and submit transition plans to the Ministry to handle equipment already installed (legacy systems). (Delibera articles on “requirements for use” and “transition” clauses.)
In terms of refarming and renewal, AGCOM has undertaken more recently further steps to open assignment procedures in the lower 24.25–26.5 GHz portion, which previously was used for fixed WLL (Wireless Local Loop) services. On October 7, 2025, the governing council approved Delibera 232/25/CONS, establishing new procedures and rules for assignments in the 24.25–26.5 GHz band — essentially the “lower 26 GHz” block — to create a stable long-term assignment framework for ultra-broadband wireless networks. (Verified via the MobileEurope article: “Italy advances 26 GHz framework … Delibera 232/25/CONS” with date reference; see MobileEurope article, Oct 2025.) That extension of assignment territory is a key piece of Italy’s refarming calendar, since previously only the upper 26.5–27.5 GHz had been allocated under 5G regimes. (As the article notes: “while the upper portion … had already been allocated in 2018 … the newly adopted rules now cover the lower block.”)
AGCOM in January 2025 also launched a public consultation regarding procedures for the 26 GHz band, as preparatory work prior to formalizing allocation modalities. (Verified: Telecompaper article “Italy’s Agcom consults on use of 26 GHz frequencies for 5G”, Jan 2025.) That consultation establishes that the regulator is formulating rules for verticals, point-to-point or point-multipoint, and integrated IoT / fixed / mobile use cases in mmWave terrain.
The Delibera 260/23/CONS (with AGCOM opinion to the Ministry) addresses the 24.25–27.5 GHz regime specifically, referencing prior delibera 231/18 and WLL usage in 24.5–26.5 GHz. (Verified: the PDF of Delibera 260/23/CONS is publicly available via AGCOM site.) It addresses rights-of-use for terrestrial broadband wireless services in 26/28 GHz, modifies conditions in Delibera 195/04/CONS (WLL rules), and coordinates with the PNRF and ministerial decree of August 31, 2022 (the PNRF approval). (See actual Delibera 260/23/CONS text.)
The interplay between national and EU obligations is essential for IoT systems. The harmonised conditions from EU decisions bind national assignment rules — e.g., the allowable spectral masks, out-of-band emissions, guard bands, and power levels for IoT / vertical slices operating within licensed segments must satisfy both the EU rules and any additional constraints in the Italian PNRF / AGCOM delibera. Because rights-of-use are non-exclusive, licensees must protect incumbent services, and future evolution (e.g. new 5G releases) may require devices to be upgraded or re-compliant with newer harmonised norms. The delibera texts explicitly foretell that equipment already installed may continue operating unless incompatible with newer standards, but licensing holders must file transition plans. (Delibera 231/18/CONS, Article on use conditions.)
From the strategic risk and planning perspective, IoT systems embedded in these licensed bands gain better interference protection and coordination guarantees compared to unlicensed SRD bands, but the project must absorb the risk of spectrum rights expiry, re-auction risk, refarming mandates, and infrastructure-sharing obligations (e.g. coverage, national obligations, wholesale access clauses). The 5G regulation guide for Italy (CMS Expert Guides, March 2025) states that the 700 MHz licensees must reach 99.4% of population coverage within 54 months and submit annual updates; failure to comply may lead to revocation of spectrum rights. (Verified: CMS Expert Guide Italy, 2025.) That obligation touches IoT because industrial systems may depend on saturating coverage in critical areas or in “extended rural” zones.
In summary, the viable licensed IoT pathway in Italy in 2025 depends on aligning deployments with the pioneer bands (700 MHz, 3.4–3.8 GHz, 26 GHz), structuring device architecture to comply with EU technical conditions, integrating transition planning for standard updates, and mapping to AGCOM’s refarming and new assignment calendar, especially as next-generation mmWave blocks (24.25–26.5 GHz) are made available under Delibera 232/25/CONS. Devices and network architects must embed flexibility to accommodate future reallocation, cap constraints, coverage obligations, and interoperability with incumbent mobile operator networks under license. The public, verified legal and regulatory instruments cited above (Delibera 231/18/CONS, Delibera 260/23/CONS, Delibera 232/25/CONS, Commission Implementing Decisions, CMS analysis, etc.) establish the binding structure for IoT in licensed spectrum in Italy as of October 2025. The available evidence has been fully exhausted for this aspect.
Temporary Spectrum in Italy: MIMIT Procedures, 15-day Tariffs, Coordination Lead-Times, and Project Risk Controls
Temporary spectrum in Italy is administered by the Ministero delle Imprese e del Made in Italy (MIMIT) through the Direzione Generale per il Digitale e le Telecomunicazioni – Istituto Superiore delle Comunicazioni e delle Tecnologie dell’Informazione (DGTEL-ISCTI) under a general-authorisation regime that distinguishes between assignments with individual rights of use and operations in collective-use bands for short-range devices (SRD). The official service page, last updated July 29, 2025, codifies the dual track, the request workflow, and the obligation to pay administrative fees and/or spectrum contributions, and it explicitly advises filing requests “preferibilmente, 15 giorni prima” to allow engineering analysis and coordination with band managers, with direct links to the application forms and the bilingual guidance package at Autorizzazioni temporanee uso frequenze — MIMIT, July 29, 2025.
The 2025 guidelines package provides the operational detail binding on applicants, including the separation between “Autorizzazione generale temporanea con conferimento del diritto individuale d’uso di frequenze” and “Autorizzazione generale temporanea per l’impiego di bande collettive … SRD,” the formal email intake channel, and the timing rule that requests be sent “almeno 15 giorni prima rispetto al giorno di decorrenza dell’autorizzazione richiesta.” The authentic PDF hosted by MIMIT sets out the application data model, the technical schedule per link, and the administrative caveats, and it establishes the payment pathway through the dedicated DGTEL portal. These parameters are traceable to MIMIT — LINEE GUIDA PER USO TEMPORANEO DI FREQUENZE 2025 (2025).
The guidelines formalise two instrument types for periods “inferiori ad un anno.” The first, a general authorisation with an individual right of use, covers temporary private networks and point-to-point or point-to-multipoint links in bands administered by the government. The second covers non-protected operations in collective-use bands for SRD such as professional wireless microphones (e.r.p. up to 50 mW) and DECT intercoms in 1,880–1,900 MHz, aligning with CEPT ERC/REC 70-03 constraints. Both are issued by DGTEL-ISCTI, Divisione VIII, with technical evaluation by Divisione VII, and both require fee payment prior to authorisation. The institutional split, the “inferiore ad un anno” limit, and the document workflow are all reproduced in the official PDF at MIMIT — LINEE GUIDA 2025 and summarised on Autorizzazioni temporanee — MIMIT, July 29, 2025.
Contributions for temporary rights follow a quindici giorni billing unit. The 2025 guidance states unambiguously: “Importo dovuto per ogni quindici giorni o frazione di durata,” then enumerates reference amounts by application type and technical profile. For example, a VHF/UHF land mobile channel “ad una o due frequenze” above 30 MHz “fino a 12,5 kHz” bandwidth is €300,00 per 15-day unit up to 15 km, while channels “oltre 12,5 kHz e fino a 25 kHz” are €600,00 per 15-day unit; one-way “radio camera” links above 1 GHz and up to 10 GHz are €630,00 (≤ 7 MHz), €720,00 (>7–14 MHz), and €810,00 (>14–28 MHz) per 15-day unit for up to 15 km. The same table lists studio-to-site wideband audio supports at €250,00 (100 kHz) and €500,00 (200 kHz) per 15-day unit (≤ 5 W e.r.p., >30 MHz–1,000 MHz) for 15 km one-way paths. For collective-use authorisations under SRD, fees for professional radiomicrophones (≤50 mW e.r.p.) scale by fleet size — €50,00 (1–5), €70,00 (6–10), €140,00 (11–15), €200,00 (16–100), €300,00 (>100) — while DECT intercom deployments in 1,880–1,900 MHz are charged €150,00 for paths up to 2 km with up to 5 device types. Every figure and constraint cited above is reproduced verbatim in the public PDF at MIMIT — LINEE GUIDA 2025.
Payments are executed through the authenticated DGTEL portal entry dedicated to temporary frequency authorisations, with the guidance prescribing insertion of the case identifier in the “NOTE” field per the “TEMP/AA/XXXX/SIGLA” convention. The official URL is provided as pagamentiDGTEL path “/pagamenti/nuovo/05-FRQ_TMP,” and the assistance contact is the same mailbox used for filing in case of portal issues. The operational payment string and the formatting requirement for the “NOTE” field are visible in the MIMIT document at LINEE GUIDA 2025 — Pagamenti DGTEL 05-FRQ_TMP.
Lead-times hinge on band management and the need to secure external coordination. The baseline advice is to submit “almeno 15 giorni prima,” as printed both on the service page and the PDF. Where requested frequencies fall in bands administered by the Ministero della Difesa, the guidance elevates the timing requirement to “almeno 30 giorni prima,” and it obliges the applicant to propose an “elenco di frequenze alternative.” This 30-day rule reflects the necessity of obtaining “nulla osta previo coordinamento,” a process condition that can extend beyond the baseline 15-day engineering analysis. The text of this special-case timing and the alternative-frequency requirement is contained in Section 4.1 of MIMIT — LINEE GUIDA 2025 and is reiterated programmatically on Autorizzazioni temporanee — MIMIT, July 29, 2025.
The file-and-pay workflow is tightly scripted. Applicants complete the bilingual XLSX forms for “RICHIESTA AUTORIZZAZIONE TEMPORANEA FREQUENZE AD USO PRIVATO” (rights of use) or the DOC form for “RICHIESTA USO TEMPORANEO RADIOMICROFONI IN BANDA COLLETTIVA,” attach per-link technical schedules (frequency, bandwidth, e.r.p., path length), and transmit the package to the dedicated mailbox. After validation, the administration communicates the exact amount due and the case identifier, which must be transcribed into the DGTEL payment “NOTE.” The forms and the mailbox routing are live at Autorizzazioni temporanee — MIMIT, July 29, 2025 with direct links to the Italian and English templates, and the payment mechanics and case-reference syntax are reproduced in LINEE GUIDA 2025.
Substantive technical constraints for temporary assignments in the land mobile service are reproduced in the same guidance document, which cites D.M. 17 aprile 1997 n. 162 for private radiomobile links and enumerates the VHF and UHF pools with 12,5 kHz channelisation. The table lists VHF simplex allocations such as 44,6–45 MHz, 160,0125–160,6000 MHz, 164,6125–165,3875 MHz, and 169,4000–169,9875 MHz; UHF simplex windows such as 440,0000–442,9875 MHz, 445,0000–445,9875 MHz, 450,3875–450,5000 MHz, 460,3875–460,5000 MHz; and paired duplex frameworks with distinct uplink/downlink pools. The guidance also flags that certain ranges — including 148–156 MHz, parts of 166,2250–167,2125 MHz, 170,8250–171,8125 MHz, and 410–430 MHz — are managed by Ministero della Difesa, hence the 30-day prefiling requirement and the obligation to provide alternatives. The enumerations are printed in Section 4.1 of MIMIT — LINEE GUIDA 2025.
The sanctioning baseline for unauthorised operation is anchored in Decreto Legislativo 1 agosto 2003, n. 259 (Codice delle comunicazioni elettroniche), with the MIMIT service page citing art. 102 for penalties. The official codification, which has been subject to subsequent amendments, is accessible on the state legal portals at Normattiva — D.Lgs 1 agosto 2003, n. 259 and via the Gazzetta Ufficiale codex navigation at Gazzetta Ufficiale — Codice delle comunicazioni elettroniche. Where amendments have altered sanction text or procedural cross-references, the consolidated articles can be consulted through the Gazzetta Ufficiale article navigation, for example the 2024 changes to Part IV touching art. 99 and art. 102, visible at Gazzetta Ufficiale — Art. 2, 2024.
Large-event governance illustrates how temporary spectrum policy scales to exceptional contexts and how filing windows interact with broader interference-prevention objectives. For the Milano Cortina 2026 Winter Games, MIMIT published a formal notice on January 24, 2025 defining “Normal,” “Late,” and “Extraordinary” booking periods and restricting certain requests in host venues to temporary authorisations expiring no later than December 31, 2025, with long-term rights eligible only from April 1, 2026. The official posting contains the date windows (February 6, 2025–May 31, 2025; September 1, 2025–October 25, 2025; January 1, 2026–March 22, 2026) and mandates use of the Spectrum Booking Portal managed by the organising foundation. The full text of these constraints is at MIMIT — Avviso 24 gennaio 2025 — Milano Cortina 2026.
Coordination dependencies are intrinsic project risks for temporary links near safety-critical environments such as airport perimeters, runways, and transport corridors. The MIMIT guidance already encodes an aviation-proximity caveat for SNG operations (“La stazione SNG non può operare a distanze dal bordo degli aeroporti inferiori a quelle specificate nella direttiva ERC/DEC/(06)03”), on the same official page that hosts the temporary-use procedures for SNG. This aviation guard-distance clause appears under the SNG section of Autorizzazioni temporanee — MIMIT, July 29, 2025 and illustrates how service-specific rules coexist with general filing and payment requirements.
From a programme-management perspective, the 15-day filing advice, the per-15-day tariff unit, the 30-day defence-band escalation, and the formalised “alternative frequencies” mandate together structure a defensible delivery plan for temporary networks, provided each element is encoded as a contractual milestone and a gating criterion. The primary controls are administrative and engineering-procedural, not speculative: file by ≥15 calendar days; for defence-managed pools file by ≥30 calendar days and present at least one fallback frequency set; calculate spectrum cost in 15-day quanta per link and bandwidth class; and stage DGTEL payment once the ministry communicates the exact amount and the case identifier. Each of these constraints is printed in the official documentation at Autorizzazioni temporanee — MIMIT, July 29, 2025 and LINEE GUIDA 2025.
The guidance also implies a geometry of feasibility for event-bounded deployments, which must now routinely model three horizons: <15 calendar days (high risk of denial for lack of engineering and coordination time), 15–29 days (nominal case for civilian bands), and ≥30 days (mandatory for defence-managed allocations). Because the authorisation confers either an individually coordinated right (for bands under MIMIT administration) or a general authorisation in collective bands (SRD), project assurance must incorporate non-protection status where applicable and pre-commit to interference-tolerant design. The factual basis for these risk layers is the combined effect of the timing rules, the band-manager clause, the “non-protected” SRD conditions referenced by the MIMIT page, and the explicit 15-day tariff quantisation, all set out in Autorizzazioni temporanee — MIMIT, July 29, 2025 and LINEE GUIDA 2025.
Where a temporary project extends toward the un anno ceiling, governance must track renewal risks and ensure continuity plans. Although the temporary regime is expressly bounded to periods “inferiori ad un anno,” the main MIMIT radio licensing hub clarifies that renewals for general authorisations with rights of use in other categories typically require 60-day pre-notice, indicating the administration’s expectation of early engagement to avoid gaps. The renewal marker and pre-notice instruction for general authorisations are stated at Radio — Autorizzazioni e licenze — MIMIT. For temporary permits themselves, the 15-day tariff base creates an economic incentive to schedule phased operations in discrete intervals and to define cutover and teardown windows that match quindicine boundaries.
A discrete control lever available to programme directors is the proactive selection of bands with minimal external coordination, especially where defence-managed blocks or aviation-sensitive adjacency would otherwise escalate timelines to ≥30 days. This lever is not speculative: it follows directly from the MIMIT rule that defence bands require prior “nulla osta” and an “elenco di frequenze alternative,” which in turn implies additional exchanges and potential denial. The formal text of this elevated requirement is contained in LINEE GUIDA 2025. Programme-level mitigation codifies a frequency-pool decision tree that avoids elevated-coordination bands unless mission-critical performance or propagation constraints necessitate them.
Event-period carve-outs can impose their own constraints, creating blackout periods for non-event long-term requests and forcing temporary-only operation. The Milano Cortina 2026 notice explicitly limits new general concessions within the host venues during the preparation interval and channels all temporary requests through the event’s Spectrum Booking Portal, with MIMIT acting as the authorization issuer thereafter. The dates, validity windows, and portal mandate are all set out in MIMIT — Avviso 24 gennaio 2025 — Milano Cortina 2026. Risk controls here require incorporating event calendars and spectrum availability plans into tender schedules and freezing frequency plans in lockstep with event authority updates.
The legal backbone for all temporary operations remains the Codice delle comunicazioni elettroniche, which MIMIT cites for sanctions (art. 102) on its official page; when a temporary authorisation is granted, it sits within the code’s architecture for private networks and radiomobile links, including references to D.M. 17 aprile 1997, n. 162 and subsequent interface specifications. The code’s canonical and consolidated versions are maintained by the state at Normattiva — D.Lgs 1 agosto 2003, n. 259 and Gazzetta Ufficiale — Codice delle comunicazioni elettroniche. Compliance documentation should quote the specific URL and capture the date on which the consolidated article text was accessed, because amendments in 2024 affected some parts of the code, as shown in Gazzetta Ufficiale — Art. 2, 2024.
In strictly operational terms, temporary spectrum projects face four verified categories of risk and matching controls traceable to MIMIT documents. First, timeliness risk: filing with less than 15 calendar days is formally discouraged and collapses coordination time; the countermeasure is a fixed milestone of ≥15 days (≥30 for defence bands) before start of use, grounded in Autorizzazioni temporanee — MIMIT, July 29, 2025 and LINEE GUIDA 2025. Second, cost-scaling risk from the 15-day unit; the countermeasure is aligning build, test, and operational windows to quindicine boundaries and modelling per-link bandwidth classes against the contribution table in LINEE GUIDA 2025. Third, coordination-denial risk for defence-managed pools; the countermeasure is early band selection away from flagged ranges and a pre-drafted “elenco di frequenze alternative” embedded in the initial application per LINEE GUIDA 2025. Fourth, event-period embargo risk exemplified by the Milano Cortina 2026 notice; the countermeasure is synchronising procurement with event booking windows and respecting the temporary-only constraint under MIMIT — Avviso 24 gennaio 2025.
A simple, verifiable assurance stack for mission-critical deployments formalises these controls into internal gates derived exactly from the public texts. Gate 1 (T-30/T-15): verify whether target bands intersect Ministero della Difesa pools listed in Sezione 4.1; if yes, set filing ≥30 days and attach alternatives; if no, set filing ≥15 days, per LINEE GUIDA 2025. Gate 2 (T-14): confirm that the application form includes per-link sheets, site coordinates, bandwidth, e.r.p., path length, and contact details, as required by Autorizzazioni temporanee — MIMIT, July 29, 2025. Gate 3 (T-10): verify receipt of the MIMIT case identifier and the communicated amount due; proceed to DGTEL payment with the identifier embedded in “NOTE,” per LINEE GUIDA 2025 — 05-FRQ_TMP. Gate 4 (T-7): lock the operational schedule to quindicine boundaries to avoid paying for unused days under the “per ogni quindici giorni o frazione” rule, per the same PDF. Gate 5 (T-0): confirm that any SRD use in collective bands aligns with ERC/REC 70-03 Annex constraints as referenced on the MIMIT page, and that aviation-sensitive operations (SNG) respect guard distances under ERC/DEC/(06)03, as posted on Autorizzazioni temporanee — MIMIT.
Where temporary use intersects broader refarmings or expiring rights in adjacent services, the national coordination practice emphasizes transparent calendars and consultations under AGCOM, but this does not supersede the MIMIT temporary regime. Projects that must operate during periods in which adjacent-service plans are evolving should still meet the same 15-day/30-day filing thresholds and attach alternatives when defence bands are implicated. The processes and calendars for adjacent services (for example, millimetre-wave consultations) are published by AGCOM in deliberations and annexes, but temporary authorisations remain a MIMIT-issued instrument with the contributions, timing, and coordination logic spelled out in Autorizzazioni temporanee — MIMIT, July 29, 2025 and in LINEE GUIDA 2025.
Because temporary authorisations create only time-bounded operating envelopes, procurement files must also capture the possibility of renewal denial when the period approaches un anno, and they must document fallback transport (fibre, leased backhaul, or licensed mobile slices) for continuity. These are not speculative imperatives: the temporary instrument is explicitly limited to “periodi inferiori ad un anno” and fee schedules are written in 15-day quanta, which together signal administrative expectations that operations will be genuinely transient or event-bound. The duration rule and the fee unit are visible in LINEE GUIDA 2025.
Finally, documentation hygiene is a control in its own right. Each application should embed the URL and access date for the active guidance and the code articles cited in the MIMIT page, namely Autorizzazioni temporanee — MIMIT, July 29, 2025, the full guidance PDF LINEE GUIDA 2025, the DGTEL payment entry string Pagamenti DGTEL — 05-FRQ_TMP, and the code references at Normattiva — D.Lgs 1 agosto 2003, n. 259 and Gazzetta Ufficiale — Codice delle comunicazioni elettroniche. For venue-bound deployments in host cities and hinterlands of major events such as Milano, Cortina d’Ampezzo, Valtellina, Val di Fiemme, Anterselva, and Verona, the MIMIT event notice dates and portal mandates at Avviso 24 gennaio 2025 — Milano Cortina 2026 must be replicated verbatim into the programme’s compliance checklist to prevent conflicts with event-period spectrum governance. The available evidence has been fully exhausted for this aspect.
Interference Engineering and Compliance: Duty-Cycles, e.r.p., and Coexistence for 863–870 MHz, 169 MHz, and 2.4 GHz IoT
Engineering for regulatory coexistence in Italy within 863–870 MHz, 169 MHz, and 2.4 GHz begins with the general-authorisation status and non-protection principle codified for short-range devices (SRD) at CEPT level and harmonised at European Union (EU) level, where the operative references current to October 17, 2025 are ERC/REC 70-03, Edition of February 14, 2025 and Commission Implementing Decision (EU) 2025/105, January 22, 2025. The CEPT recommendation defines SRD as operating on a non-interference, non-protected basis, with regulatory parameters expressed by category in annexed tables, while the EU decision amends 2006/771/EC to update SRD technical conditions and confirms that compliant SRD are subject to no more than a general authorisation under national law; both texts are publicly accessible and in force as of 2025 through the institutional repositories linked above. Within Italy, domestic allocation and any national notes constraining SRD use are referenced in the Piano nazionale di ripartizione delle frequenze (PNRF), updated April 5, 2025, which provides the authoritative cross-walk between ERC/REC 70-03 annexes and national allocation tables used by Ministero delle Imprese e del Made in Italy (MIMIT) for spectrum governance.
The 863–870 MHz segment contains multiple SRD sub-bands whose regulatory parameters for e.r.p., duty-cycle, channelisation, and mitigation are enumerated in ERC/REC 70-03 annexes. Within the non-specific SRD family, the text identifies, among others, 869.2–869.25 MHz at 10 mW e.r.p. with ≤0.1% duty-cycle and 25 kHz channel spacing, 869.25–869.3 MHz at 10 mW e.r.p. with ≤0.1% duty-cycle and ≤25 kHz occupied bandwidth, 869.3–869.4 MHz at 10 mW e.r.p. with ≤1.0% duty-cycle and ≤25 kHz, and 869.65–869.7 MHz at 25 mW e.r.p. with ≤10% duty-cycle and ≤25 kHz; these entries appear verbatim in the 2025 edition’s annex tables and are cross-referenced to ETSI EN 300 220 as the harmonised standard for SRD below 1,000 MHz, which is itself published as ETSI EN 300 220-2 V3.3.1 (2025-03). The duty-cycle categories used to interpret and verify these limits are defined in Appendix 5 of ERC/REC 70-03, where “Very Low” is ≤0.1% (0.72 s per 1 h observation window), “Low” is ≤1.0% (3.6 s per 1 h), “High” is ≤10% (36 s per 1 h), and “Very High” extends up to 100%, with the observation interval set, unless otherwise specified, to 1 h; the definitional text and example calculations are explicitly printed in the 2025 edition’s appendix to ensure consistent compliance interpretation across EU administrations and manufacturers.
Networked IoT architectures relying on data-centric SRD in 863–870 MHz must also consider the data-network entries maintained in ERC/REC 70-03 Annex 11 for 865–868 MHz, which impose Adaptive Power Control (APC) and differentiated duty-cycle caps between network access points and other nodes. The 2025 edition reproduces that 865–868 MHz category with 500 mW e.r.p., APC down to ≤5 mW, and duty-cycle limited to ≤10% for network access points and ≤2.5% otherwise, with ≤200 kHz occupied bandwidth; the annex notes point implementers to ETSI EN 303 204 for listen-before-talk (LBT) requirements on access points and to ETSI EN 300 220 for radio parameters and test methods. This combination—APC, per-role duty-cycles, and optional LBT—constitutes the verified mitigation scaffold for shared, non-protected data networks in 865–868 MHz, complementing the narrower non-specific channels available at 869.x MHz for low-duty telemetry; all values and conditions are drawn directly from the ERC/REC 70-03, Edition of February 14, 2025 tables and notes.
The 169 MHz allocation group presents a particularly instructive case for compliance engineering because ERC/REC 70-03 differentiates technical limits by annex category. In Annex 1 (Non-specific SRD), sub-band 169.4–169.475 MHz is listed at 500 mW e.r.p. with ≤1% duty-cycle (entry f1) and 169.4–169.4875 MHz at 10 mW e.r.p. with ≤0.1% duty-cycle (entry f2). In Annex 2 (Tracking, tracing, and data acquisition) the same 169.4–169.475 MHz appears for meter reading at 500 mW e.r.p. with ≤10% duty-cycle, referencing ECC/DEC/(05)02. The co-existence implication is not a contradiction but a categorical bifurcation: an identical radio channel can be deployed under distinct application categories with different duty-cycle ceilings, and the testable limit for a device is the one that corresponds to the declared category and the harmonised standard cited for that annex. The 2025 edition includes the category-specific rows and links Annex 1 entries to EN 300 220 and Annex 2 to ECC/DEC/(05)02; implementers in Italy must therefore bind device firmware and operational policies to the declared use category to avoid exceeding the applicable duty-cycle limit under the chosen annex framework, a requirement that is verifiable against the ERC/REC 70-03, 2025 tables for entries f1/f2 and band b in Annex 2.
The 2.4 GHz ISM band hosting Wi-Fi, Bluetooth, and IEEE 802.15.4 implementations is governed at the radio layer for the Radio Equipment Directive conformity path by ETSI EN 300 328, whose current harmonised version in widespread use is ETSI EN 300 328 V2.2.2 (2019-07). Unlike many 863–870 MHz and 169 MHz SRD sub-bands, EN 300 328 does not enforce fixed duty-cycle ceilings; instead it codifies spectrum-access mechanisms, transmitter and receiver characteristics, and measurement methods for wideband data transmission systems in 2,400–2,483.5 MHz, including requirements for receiver blocking, spurious emissions, and maximum power spectral density, with the mitigation focus achieved through adaptive frequency usage and medium-access constraints instead of strict transmission-time caps. ERC/REC 70-03 Annex 3 (Wideband data transmission systems) explicitly references EN 300 328 as the harmonised standard for the 2.4 GHz category, confirming the standard’s role in the SRD compliance chain; the annex linkage is printed in the “Harmonised Standards” list under annex b in the ERC/REC 70-03, 2025 document.
Designers of IoT fleets in Italy should treat duty-cycle and e.r.p. constraints as quantifiable budget lines that directly bound messaging frequency, payload size, and redundancy. A device operating in 869.2–869.25 MHz under a ≤0.1% duty-cycle has an hourly transmission allowance of 0.72 s, which must accommodate preamble, headers, payload, and acknowledgements within the chosen modulation and coding scheme; Appendix 5 to ERC/REC 70-03 provides the normative conversion between percentage ceilings and total permitted transmission-time per 1 h observation interval and gives numeric examples to illustrate scheduling compliance. Channelisation and occupied bandwidth constraints—25 kHz for the cited 869.x MHz entries—constrain symbol rates and hence achievable goodput under the same duty-cycle ceiling. The result is a tri-constraint problem where e.r.p., duty-cycle, and bandwidth form the fixed sides of a triangle and the variable side is the application-layer Quality of Service, with collision-avoidance and retransmission policies tuned to the non-protection nature of SRD bands.
In the 865–868 MHz networked SRD regime, APC and, where applicable under EN 303 204, LBT, provide coexistence tools that interact with duty-cycle caps and path budgets. APC requires equipment to reduce e.r.p. down to ≤5 mW when link budgets permit, shrinking interference footprints; the ERC/REC 70-03 table for this band embeds the APC requirement and the ≤5 mW floor for power back-off, while the catalogue of harmonised standards points network access-point implementers to EN 303 204 for LBT. The risk model in dense deployments therefore begins with a spectrum-access layer that throttles transmit power and imposes channel occupancy etiquette, complemented by application-layer pacing so that total airtime share across a dense mesh remains compatible with ≤2.5% per node where required and ≤10% at access points. These provisions are directly extractable from ERC/REC 70-03, 2025 and the ETSI harmonised standard references present in the annex.
Compliance at 169 MHz requires special attention to antenna physics and duty-cycle category selection. With 500 mW e.r.p. permitted in 169.4–169.475 MHz, link budgets favour suburban and rural telemetry where penetration and range are at a premium, but the ≤1% duty-cycle ceiling in Annex 1 constrains messaging cadence. Where meter reading under Annex 2 is applicable, the duty-cycle ceiling moves to ≤10%, but only within the defined application category linked to ECC/DEC/(05)02, and equipment must be certified and operated accordingly. The two entries—Annex 1 f1 and Annex 2 band b—are both present in the ERC/REC 70-03, 2025 tables and cannot be interchanged by operational convenience without violating the declared use class. The harmonised-standard path for radio parameters remains EN 300 220, with device test limits and methods formally specified in EN 300 220-2 V3.3.1 (2025-03).
For 2.4 GHz, coexistence engineering shifts from duty-cycle arithmetic toward adjacent-channel selectivity, blocking, frequency-hopping or adaptive mechanisms, maximum conducted output power, and spectral density as codified by EN 300 328. Because Wi-Fi, Bluetooth, and IEEE 802.15.4 operate in this band with differing channel widths and access methods, practical coexistence hinges on airtime fairness and spectrum-access adaptivity rather than legal duty-cycle caps. EN 300 328 provides measurement methods and limits for receiver performance and spurious emissions that, in concert with ERC/REC 70-03 Annex 3, aim to balance heterogeneous wideband and narrowband uses; implementers confirm compliance by testing to EN 300 328 V2.2.2 (2019-07) and documenting configuration parameters that influence spectrum access during certification.
A disciplined interference budget for Italy should embed the duty-cycle definitions from ERC/REC 70-03 Appendix 5 as numeric guardrails in network controllers and device firmware. For sub-bands with ≤0.1% limits such as 869.2–869.25 MHz, a scheduling envelope of 0.72 s per 1 h per device demands either very short frames or multi-hour pacing for larger payloads with forward-error correction. For ≤1% bands such as 869.3–869.4 MHz or 169.4–169.475 MHz under Annex 1, 3.6 s per 1 h allows modest increases in redundancy or acknowledgement overhead. For ≤10% bands such as 869.65–869.7 MHz and meter-reading in 169.4–169.475 MHz under Annex 2, 36 s per 1 h enables higher sampling densities or over-the-air update windows, but device count per cell must be bounded to avoid aggregate congestion in shared channels. These conversions and labels—Very Low, Low, High—are the exact terms and examples stated in ERC/REC 70-03 Appendix 5 of the 2025 edition.
Because SRD in Italy operate on a non-protected basis, coexistence risk controls extend beyond radio parameters to deployment geometry. Narrow 869.x MHz channels with 10 mW e.r.p. are well suited for in-building or campus-scale telemetry where path loss can be bounded and antenna siting minimises exposure to external interferers, while 25 mW e.r.p. at 869.65–869.7 MHz should be reserved for scenarios that justify the higher duty-cycle ceiling but can tolerate the corresponding increase in interference footprint. For wide-area telemetry requiring propagation headroom, 169.4–169.475 MHz at 500 mW e.r.p. under the applicable annex class extends coverage at the cost of stricter duty-cycle in Annex 1 or the application constraint in Annex 2. The binding references for these trade-offs are the annex tables in ERC/REC 70-03, 2025 and the measurement and conformance methods in EN 300 220-2 V3.3.1 (2025-03).
Legal certainty at EU level for SRD compliance in 863–870 MHz, 169 MHz, and 2.4 GHz is reinforced by the 2025 update to the SRD harmonisation annex through Implementing Decision (EU) 2025/105, which replaces the annex to 2006/771/EC and clarifies the status of SRD categories while leaving the specialised 874–876/915–921 MHz framework under Implementing Decision (EU) 2018/1538 (as consolidated April 1, 2025). While 2018/1538 targets different bands, its definitional clauses about networked SRD, non-exclusive access, and non-protection reinforce the compliance context for Italy, and cross-references to ERC/REC 70-03 in that instrument confirm the interplay between EU law and CEPT technical annexes.
Within Italy, engineering teams should supplement pan-EU references with national allocation checks in the PNRF, updated April 5, 2025. While SRD bands are typically available under general authorisation, national notes can impose geographic or service-specific cautions, and site-adjacent services (for example, aeronautical radionavigation near airports) may require additional risk controls even when not explicitly codified as prohibitions for the SRD class. The allocation page maintained by MIMIT records the status of national tables and the alignment cadence with WRC-23 results and EU decisions; procurement and design documentation should capture the URL and access date of the PNRF reference to ensure the allocation snapshot used in engineering is auditable.
For certification and market access, Radio Equipment Directive (RED) compliance requires conformity with the appropriate harmonised standards. EN 300 220-2 V3.3.1 (2025-03) is the current edition specifying test methods and limits for non-specific SRD in 25 MHz–1,000 MHz, explicitly covering 169 MHz and 863–870 MHz device classes used by IoT; the ETSI publication is the canonical reference. For wideband 2.4 GHz devices, EN 300 328 V2.2.2 (2019-07) remains the harmonised standard used by manufacturers for Wi-Fi, Bluetooth, and IEEE 802.15.4 classes; the official ETSI PDF is publicly accessible and in force. The linkage between ERC/REC 70-03 annexes and these harmonised standards is explicitly printed in the annex “Harmonised Standards” rows in the 2025 recommendation, providing the authoritative bridge from national allocation and EU harmonisation to practical device testing and DoC issuance.
Coexistence testing for Italy-bound IoT fleets should combine lab conformance and on-site validation aligned to the duty-cycle and e.r.p. ceilings referenced above. Lab measurement confirms transmitter power, occupied bandwidth, spurious emissions, and receiver blocking versus the ETSI standards; network simulation and on-site pilots confirm aggregate airtime share, channel utilisation under realistic node densities, and the efficacy of APC and LBT policies where mandated. For 865–868 MHz data networks, test plans must show that access points implement LBT per EN 303 204 and that APC reduces e.r.p. to ≤5 mW when feasible; for 869.x MHz channels, test vectors must prove compliance with the ≤0.1%, ≤1%, or ≤10% duty-cycle class and the 10–25 mW transmitter limits in the specific sub-band; for 169.4–169.475 MHz, programmes must select and document the annex category (non-specific ≤1% or meter-reading ≤10%) and verify firmware conformance to the declared ceiling at 500 mW e.r.p.. Each of these assertions is bound to the annex tables in ERC/REC 70-03, 2025 and the relevant ETSI standards cited above.
Operational governance for Italy should further respect project-level controls derived from the legal hierarchy. First, document and lock the SRD annex category and sub-band for each device class with a citation to the exact ERC/REC 70-03 table row and ETSI standard, ensuring that firmware and duty-cycle enforcement match the declared class. Second, capture the EU-law snapshot by embedding a reference to Implementing Decision (EU) 2025/105 and, if relevant to 874–876/915–921 MHz equipment within the same fleet, to 2018/1538 (consolidated April 1, 2025). Third, bind the national allocation snapshot via the PNRF update page, April 5, 2025 and, for pilots or venue-bound temporary work, the MIMIT temporary-use procedures that specify non-protected status in collective bands; these are formalised on Autorizzazioni temporanee uso frequenze — page updated July 29, 2025. None of these governance measures invents constraints; each is mirrored in the linked public texts.
Security-critical deployments—for example, runway-perimeter sensors, building-automation safety loops, or highway incident beacons—must integrate redundancy to compensate for SRD non-protection status confirmed by ERC/REC 70-03 and EU instruments. A validated approach is multi-homing across categories: a 169 MHz meter-reading channel under Annex 2 for extended reach and a 869.x MHz low-duty fallback under Annex 1 for alarm signalling, each engineered within its respective duty-cycle and e.r.p. ceiling; in dense campus environments, a 2.4 GHz EN 300 328 link can carry non-critical bulk telemetry and maintenance traffic, absorbing contention through adaptive mechanisms rather than relying on the tight duty-cycle budgets of narrowband SRD. The non-protection principle and the specific numeric ceilings or spectrum-access mechanisms cited for each band are not interpretive embellishments; they are the operative conditions visible in the ERC/REC 70-03, 2025 and EN 300 328 / EN 300 220-2 references.
Finally, to ensure continued compliance through 2025, organisations should monitor the ECO DocDB entry for ERC/REC 70-03 (Edition of February 14, 2025) and the EUR-Lex pages for SRD instruments—Implementing Decision (EU) 2025/105, January 22, 2025 and Implementing Decision (EU) 2018/1538, consolidated April 1, 2025—and log the PNRF update marker on April 5, 2025 for national alignment. These sources are the definitive repositories as of October 17, 2025 for the duty-cycle, e.r.p., and coexistence conditions governing IoT devices in 863–870 MHz, 169 MHz, and 2.4 GHz within Italy and the wider EU internal market. The available evidence has been fully exhausted for this aspect.
Procurement and Governance: Contracting for Spectrum Continuity under AGCOM Obligations and PNRF Updates
Procurement architectures for mission-critical Internet of Things (IoT) in Italy must embed verifiable legal anchors that map directly to national spectrum planning under the Piano nazionale di ripartizione delle frequenze (PNRF) and to regulatory milestones published by Autorità per le Garanzie nelle Comunicazioni (AGCOM). The allocation frame and update cadence are maintained by Ministero delle Imprese e del Made in Italy (MIMIT), whose official PNRF page confirms national alignment with International Telecommunication Union Radio Regulations and European Union instruments, and carries an update marker at April 5, 2025, establishing the most recent authoritative reference for domestic band attributions, national notes, and channelisation tables used during peace-time administration of the spectrum resource, as published at Piano nazionale di ripartizione delle frequenze (PNRF) — April 5, 2025. Governance sections inside AGCOM’s institutional site describe how the regulator sets assignment procedures and usage rules (especially where Piani di assegnazione exist), acting “sentita l’Autorità” for ministerial allocations and enforcing compliance under the national plan; the canonical description appears at AGCOM — Frequenze: competenze.
Contract formation for public and strategic operators has to translate those institutional touchpoints into enforceable risk-sharing clauses. The European Electronic Communications Code (EECC) establishes the Union’s framework for authorisations, rights of use, and spectrum policy coordination, with binding effect in Member States; its authentic text is accessible at Directive (EU) 2018/1972 — European Electronic Communications Code. At national level, procurement for public buyers is disciplined by the re-written Codice dei contratti pubblici, enacted by Decreto Legislativo March 31, 2023, n. 36 and maintained on the state’s official portal; the current codex landing page is Normattiva — D.Lgs 31 marzo 2023, n. 36, with direct access to article-specific anchors, for example Articolo 126 (Normattiva deep link) and Articolo 17 (Normattiva deep link). These two legal pillars — EECC and D.Lgs 36/2023 — establish, respectively, the spectrum-rights ecosystem and the public-contract toolkit within which spectrum-dependent IoT services must be procured, governed, and adapted over time.
Calendar certainty for licensed 5G bands is delineated in a sequence of AGCOM deliberations. The national auction and usage framework for 694–790 MHz, 3,600–3,800 MHz, and 26.5–27.5 GHz was set by Delibera n. 231/18/CONS, whose authentic PDF remains the only binding repository for blocks, assignment rules, coverage and rollout obligations, and compatibility with domestic planning; the document is hosted at AGCOM — Delibera 231/18/CONS (PDF). In January 2025, AGCOM opened a dedicated consultation to define procedures and rules for the 24.25–26.5 GHz portion (legacy WLL domain) to converge it with the “pioneer” 26.5–27.5 GHz usage model; the consultation act and its technical attachment are published as Delibera n. 21/25/CONS, January 22, 2025 (PDF) and Allegato A alla delibera n. 21/25/CONS, January 27, 2025 (PDF). In parallel, AGCOM’s sector-wide annual report embeds narrative and date-stamped milestones for spectrum policy; the most recent institutional report is posted as Relazione annuale 2025 (PDF). Procurement officers in Italy can therefore lift verified dates, obligations, and convergence plans for their risk registers directly from these live documents rather than relying on secondary commentary.
Commercial contracts anchored to licensed 5G NB-IoT/LTE-M services should include an explicit change-in-law and spectrum continuity regime that mirrors the hierarchy of sources above. Under EECC authorisation principles, rights of use are time-bounded and subject to renewal and refarming; therefore agreements with mobile network operators need a clause triad: (1) a representation and continuous-warranty clause that the service provider will operate solely within the applicable rights of use and the technical conditions of Union harmonisation decisions and domestic assignments (cross-referenced in schedules to the exact AGCOM deliberations and EU decisions relevant to the contracted band), anchored in Directive (EU) 2018/1972 — EECC and AGCOM — Delibera 231/18/CONS; (2) a regulatory-change adjustment clause that allocates the economic and technical consequences of any post-award refarming or assignment procedure initiated by AGCOM, by reference to the consultation documents and final acts — i.e., to Delibera n. 21/25/CONS and Allegato A for 24.25–26.5 GHz; and (3) a migration-and-fallback operational clause that compels the operator to maintain a pre-approved band-migration plan and device firmware roadmap consistent with the national plan’s update cadence, evidenced by the PNRF marker at April 5, 2025 at MIMIT — PNRF.
Public-sector buyers must additionally ensure that procurement documents are compliant with D.Lgs 36/2023 in framing technical specifications, performance conditions, and contract modifications during execution. Because spectrum governance is an exogenous risk, contract variation clauses should be drafted to the thresholds and procedures defined by the Codice dei contratti pubblici, relying on the consolidated legal portal to anchor article citations that control allowable scope changes; institutional anchors include the code’s landing page Normattiva — D.Lgs 31 marzo 2023, n. 36 and article-level views such as Articolo 126 and Articolo 17. This ensures that any necessary contractual adjustments — to accommodate AGCOM timetable changes or PNRF note revisions — are executed under legally valid variation procedures, documented against the state’s official codex rather than descriptive summaries.
Contract schedules should replicate, in full and with live links, the AGCOM instruments that concretely affect spectrum continuity. Delibera 231/18/CONS remains the primary source for the 700 MHz, 3.6–3.8 GHz, and 26.5–27.5 GHz assignment framework and includes references to coverage, build-out, and use-conditions that underwrite service-level assumptions for NB-IoT and LTE-M connectivity; the binding text is at AGCOM — Delibera 231/18/CONS (PDF). For 24.25–26.5 GHz, the live consultation and draft rules at Delibera n. 21/25/CONS and Allegato A provide the planning canvas for the WLL-to-5G transition; these documents, together with AGCOM’s positions in 2023 on reconciling legacy usage, articulate the policy direction and target dates cited in Delibera n. 260/23/CONS (PDF) and in the broader institutional reporting at Relazione annuale 2025 (PDF). Procurement governance should require prime contractors to keep these citations current in contract appendices, with a quarterly legal-monitoring deliverable that re-tests each URL and appends any AGCOM updates or new ministerial decrees affecting the underlying bands.
Where projects rely on private temporary spectrum during staged roll-outs before migrating to licensed operator services, contracting must absorb the procedural and economic structure of MIMIT’s temporary-use regime. Although this chapter focuses on steady-state continuity under AGCOM obligations and PNRF updates, the temporary pathway remains a necessary bridge for field trials and venue-bound operations, and thus its fee granularity and lead-time mechanics are governance facts: the MIMIT service page instructs that requests should be lodged “preferibilmente 15 giorni prima” and the 2025 guidance fixes a quindici giorni billing unit for spectrum contributions across link classes. These parameters are not inferred; they are printed on the institutional pages at Autorizzazioni temporanee uso frequenze — page updated July 29, 2025 and in the guidance PDF LINEE GUIDA PER USO TEMPORANEO DI FREQUENZE 2025. Contracts should therefore include a Transition Services exhibit that prices and schedules temporary-use phases in 15-day quanta, and obliges the supplier to migrate onto the steady-state licensed service profile within a timeframe compatible with AGCOM assignment and refarming calendars.
A robust spectrum-continuity covenant for NB-IoT/LTE-M service contracts specifies the exact bands, blocks, and rights-of-use held by the serving operator and requires notification of any impending change in the legal or technical conditions linked to those rights. The operator should be obliged to supply, at contract inception and annually thereafter, certificate extracts and AGCOM references that list assigned blocks, expiry dates, and any license-specific obligations. The clause should include an express remedy structure for: (a) migration to an alternative band within the same technology profile consistent with national assignments under Delibera 231/18/CONS; (b) interim use of roaming or MOCN/MVNO-style arrangements documented in the operator’s reference offer, governed by the same AGCOM conditions; and (c) prorated service-credit mechanics tied to the documented dates and milestones in AGCOM acts or MIMIT updates, with evidentiary links to Relazione annuale 2025 where coverage or deployment progress is officially discussed.
To accommodate PNRF evolution, contracts need a Regulatory Horizon Scan obligation that compels the supplier to track and report national-note changes, table updates, or new domestic decrees that affect co-existence assumptions or site-specific feasibility. The state-hosted training deck used by MIMIT for institutional briefings summarises the legal provenance of the PNRF and recalls the ministerial decree that approved the 2022 edition (supplement to the Gazzetta Ufficiale September 13, 2022, n. 214), demonstrating the ministry’s governance role and the plan’s update lineage; the deck is posted as Le Radiocomunicazioni nel contesto internazionale e nazionale — June 8, 2023 (PDF). The live PNRF page with the April 5, 2025 update flag remains the single source of truth for the current allocation snapshot at MIMIT — PNRF; procurement governance should require suppliers to append that URL and access date in every spectrum-impact report delivered under the contract.
For projects that will, by necessity, intersect the 26 GHz transition, the contracting record must capture the interplay between legacy WLL decommissioning and 5G assignment expansion. AGCOM’s recent documents confirm the policy trajectory: advisory opinions and deliberations in 2023 set the expectation that WLL switch-off would complete by the end of 2026 (with local variations in roadmap), while 2025 consultations moved to formalise procedures for assigning the 24.25–26.5 GHz portion; both statements are printed in Delibera n. 260/23/CONS (PDF), Delibera n. 21/25/CONS (PDF), and its Allegato A (PDF). A 26 GHz-reliant IoT procurement must therefore bind the supplier to a cutover plan keyed to the official AGCOM calendar, including a pre-negotiated list of alternate channels or bands and a device-firmware update timeline that satisfies certification dependencies. The evidence trail for these dates belongs in the contract annex so that disputes over “foreseeability” of regulatory change are resolved against the documentary record.
In practice, service-level agreements (SLA) for IoT telemetry carried on operator networks require a two-layer approach. The IP-service layer defines PDU session availability, round-trip latency targets, and packet-loss ceilings in the serving area; the spectrum-assurance layer defines what happens if the underlying band’s use-conditions are altered by AGCOM or by MIMIT updates to national tables. The second layer should: (i) state that any refarming or assignment change evidenced by an AGCOM act (or ministerial decree reflected on the PNRF page) triggers the supplier’s Migration Plan within n days; (ii) set interim minimums (e.g., fallback onto a different licensed band with comparable radio conditions) pending completion of the migration; and (iii) link service-credit sizing to the effective date printed in the AGCOM or MIMIT document, as evidenced by the institutional PDF or page at AGCOM — Relazione annuale 2025, AGCOM — Delibera 231/18/CONS, and MIMIT — PNRF. This eliminates ambiguity over whether an event constitutes force majeure, regulatory change, or supplier default.
Because public buyers operate under the formal strictures of D.Lgs 36/2023, contract modification and termination mechanisms should be drafted to the code’s permissible pathways and threshold logic. Institutionally valid drafting uses Normattiva deep links to the relevant articles to ground the variation procedures in the governing code, such as Articolo 126 and Articolo 17; this approach prevents later disputes about the legitimacy of a change order issued to accommodate a new AGCOM assignment rule or PNRF national note.
To operationalise these legal anchors, procurement files should include a Spectrum Governance Plan annex with four verifiable controls. Control 1 (Legal Horizon Scan): a quarterly report that re-verifies the status of MIMIT — PNRF, cites any changes to national notes, and records whether those changes affect the contracted IoT device classes. Control 2 (Regulatory Milestone Tracking): a schedule keyed to AGCOM acts, including Delibera 231/18/CONS, Delibera 21/25/CONS, its Allegato A, and narrative checkpoints in Relazione annuale 2025. Control 3 (License Evidence Pack): annual delivery by the operator of rights-of-use extracts that identify blocks, expiry dates, and obligations in the contracted bands, with the AGCOM PDF citations attached. Control 4 (Change-in-Law Playbook): pre-approved procedures for device firmware updates, SIM/eSIM profile migrations across bands, and, where necessary, portable allocation of endpoints to an alternate operator under a roaming/MOCN mechanism, all time-boxed to the effective dates in the verified AGCOM/MIMIT documents and executed under D.Lgs 36/2023 change-order rules.
Risk allocation in mixed SRD/licensed architectures — common in airport perimeters, runway safety systems, and highway ITS corridors — should reflect the unprotected status of SRD and the higher continuity expectations attached to licensed operator carriage. The unprotected aspect is not a matter of opinion; it is printed in the short-range devices acquis (harmonised at Union level) and in CEPT recommendation text, and the national allocation plan is explicit that coexistence and protection norms are determined by service class and band. While this chapter does not recapitulate SRD technicalities, procurement teams should ensure that any SRD segment inside the solution is governed by a separate availability matrix and mitigation plan, while the licensed segment carries the continuity covenant tied to the AGCOM/PNRF sources cited above. If temporary private links are unavoidable during commissioning, the 15-day tariff unit and ≥15/≥30 day filing windows in MIMIT guidance at Autorizzazioni temporanee uso frequenze — July 29, 2025 and LINEE GUIDA 2025 must be embedded as critical-path milestones in the project’s master schedule.
Programme-level governance requires that all hyperlinks used in contracts and internal standards reference only official institutional repositories, mirroring the verification protocol applied here. For Union law and spectrum harmonisation: Directive (EU) 2018/1972 — EECC. For national allocation and updates: MIMIT — PNRF (April 5, 2025). For assignment frameworks and consultations: AGCOM — Delibera 231/18/CONS, AGCOM — Delibera 21/25/CONS, AGCOM — Allegato A a 21/25/CONS, AGCOM — Relazione annuale 2025, and legacy WLL convergence positions at AGCOM — Delibera 260/23/CONS. For public-contract mechanics: Normattiva — D.Lgs 31 marzo 2023, n. 36 with deep links to article views such as Art. 126 and Art. 17. This disciplined sourcing practice elevates auditability and sharply reduces dispute latitude over whether a change was reasonably foreseeable or properly evidenced.
The contracting blueprint described here does not hypothesise relationships that are not present in the cited texts. It lifts only from the official documents that define Italy’s allocation architecture and AGCOM’s assignment and refarming calendar, and it anchors public-contract change mechanics to the state’s codified procurement law. As of October 17, 2025, the institutional links above are live and point to the precise documents they name; any future evolution should be captured by the Spectrum Governance Plan annex with updated PNRF snapshots and AGCOM deliberations attached as they are published. The available evidence has been fully exhausted for this aspect.
| Area / topic | Bands / technologies | Status (shared or licensed) | What the rule or document does (plain language) | Core technical limits (power, duty-cycle, access) | Operational notes and examples | Italy-specific implementation or process | Key dates and timelines | Fees / costs (if applicable) | Primary authority | Official source (title and live link) |
|---|---|---|---|---|---|---|---|---|---|---|
| Definition and status of SRD (short-range devices) in Europe | Multiple SRD bands, including 169.4–169.8 MHz, 863–870 MHz, and 2.4 GHz | Shared (general authorization; no individual license) | Confirms SRD are low-power, low-range devices that must not cause interference and cannot claim protection | Duty-cycle ceilings by sub-band; power limits by band; references to harmonized ETSI standards | Used for alarms, meters, industrial sensors, building automation | Italy follows this framework within its national plan (PNRF) | CEPT recommendation edition date: February 14, 2025 | Not applicable | CEPT (European Conference of Postal and Telecommunications Administrations) | ERC/REC 70-03, Edition of February 14, 2025 — ERC/REC 70-03 (ECO DocDB) |
| EU legal update for SRD conditions | EU-wide SRD categories (various bands) | Shared | Replaces the SRD annex to 2006/771/EC; confirms that SRD complying with harmonized conditions are subject to general authorization only | Keeps SRD technical conditions aligned across EU | Ensures consistency across member states; does not grant protection | Italy aligns through PNRF | Decision adopted January 22, 2025; OJ publication January 23, 2025 | Not applicable | European Commission | Commission Implementing Decision (EU) 2025/105 — EUR-Lex OJ page |
| Networked SRD (data networks) bands | 874–876 MHz and 915–921 MHz | Shared | Sets conditions and definitions for networked SRD (network access points and nodes) on a non-exclusive, non-protected basis | Defines roles (access points vs nodes) and coexistence principles | Used for IoT gateways and devices needing medium-range links | Italy can designate these bands following EU conditions; check PNRF notes | Decision published October 15, 2018; consolidation current to April 1, 2025 | Not applicable | European Commission | Implementing Decision (EU) 2018/1538 — Consolidated (April 1, 2025) and Original OJ |
| Italy’s national frequency plan (PNRF) | All bands in Italy (allocations and notes) | Both (shared and licensed entries) | National mapping of bands to services; includes national notes and alignment with EU and ITU | Technical details by band are in annex tables; national notes may add conditions | Primary reference for feasibility checks before any deployment | Use for band selection, national notes, and alignment with EU rules | Page shows update marker April 5, 2025 | Not applicable | MIMIT (Ministero delle Imprese e del Made in Italy) | Piano nazionale di ripartizione delle frequenze (PNRF) — MIMIT page |
| Non-specific SRD sub-bands often used by IoT | 863–870 MHz (selected sub-bands) | Shared | Allows telemetry and control with strict limits to share the band | Examples from CEPT tables: 869.2–869.25 MHz up to 10 mW e.r.p. with duty-cycle 0.1% per hour; 869.3–869.4 MHz up to 10 mW e.r.p. with duty-cycle 1% per hour; 869.65–869.7 MHz up to 25 mW e.r.p. with duty-cycle 10% per hour; channelization typically 25 kHz | Good for short messages and alarms; design must fit time budget and power cap | Confirm any Italy national note in PNRF before deployment | Current in 2025 CEPT edition | Not applicable | CEPT | ERC/REC 70-03, Annex tables — ECO DocDB |
| Networked SRD data networks in 865–868 MHz (Annex 11) | 865–868 MHz | Shared | Enables data networks with access points and nodes under shared access rules | Up to 500 mW e.r.p. with Adaptive Power Control down to ≤ 5 mW; duty-cycle up to 10% at access points and up to 2.5% at other devices; access points may need LBT per ETSI EN 303 204 | Suitable for clustered IoT networks with controlled airtime and power | Italy follows CEPT, subject to PNRF notes | Current in 2025 CEPT edition | Not applicable | CEPT / ETSI | ERC/REC 70-03 (Annex 11) — ECO DocDB; ETSI EN 303 204 (referenced in annex) |
| 169 MHz SRD (non-specific and metering) | 169.4–169.8 MHz (sub-bands) | Shared | Two categories: non-specific SRD and specific “meter reading” use with different duty-cycles | Example CEPT entries: non-specific SRD in 169.4–169.475 MHz up to 500 mW e.r.p. with duty-cycle 1% per hour; meter reading in 169.4–169.475 MHz up to 500 mW e.r.p. with duty-cycle 10% per hour (application-specific) | Designers must bind devices to the declared category and respect the matching limits | Check PNRF for any Italy-specific restrictions | Current in 2025 CEPT edition | Not applicable | CEPT | ERC/REC 70-03 (Annex 1 and Annex 2 tables) — ECO DocDB |
| 2.4 GHz wideband data systems (Wi-Fi, Bluetooth, 802.15.4) | 2,400–2,483.5 MHz | Shared | Uses a harmonized ETSI standard that focuses on access behavior and receiver performance rather than strict duty-cycle caps | Compliance via ETSI EN 300 328 (e.g., maximum power spectral density, receiver blocking, spurious emissions) | Good for bulk telemetry and local networks; coexistence handled by adaptive mechanisms | Italy treats this as SRD wideband per CEPT annex; check PNRF for any national note | EN 300 328 current version widely used for RED compliance | Not applicable | ETSI (harmonized under RED) | ETSI EN 300 328 V2.2.2 (2019-07) — ETSI official PDF |
| Harmonized test standard for sub-1 GHz SRD | 25 MHz–1,000 MHz (covers 169 MHz and 863–870 MHz classes) | Shared | Defines radio test limits and methods for RED conformity | Transmitter power, occupied bandwidth, spurious emissions, receiver blocking, duty-cycle measurement | Required for CE declarations and market access | Used in Italy for conformity of SRD products | Version V3.3.1 published March 2025 | Not applicable | ETSI | ETSI EN 300 220-2 V3.3.1 (2025-03) — ETSI official PDF |
| Duty-cycle definitions (observation window) | Applies to many SRD sub-bands | Shared | Defines time-on-air budgets per hour to limit congestion | Very low: 0.1% (0.72 s per hour); low: 1% (3.6 s per hour); high: 10% (36 s per hour); unless band entry states otherwise | Enforced in firmware and scheduling to meet legal limits | Italy uses same definitions via CEPT tables | Current in 2025 CEPT edition | Not applicable | CEPT | ERC/REC 70-03, Appendix 5 — ECO DocDB |
| Italy temporary spectrum (what it is) | Various bands; private links and certain collective-use applications | Both (temporary general authorization; some with individual right of use) | Enables short-term use for tests, events, or pilots | Technical limits defined by band; some collective bands (e.g., SRD microphones, DECT intercoms) | Valid for periods under one year; non-protection applies in collective bands | Applications via DGTEL-ISCTI; forms and email intake specified | Preferably file 15 days before start; 30 days if MoD coordination needed | Fees are charged in 15-day units per link/type | MIMIT (DGTEL-ISCTI) | Autorizzazioni temporanee uso frequenze — MIMIT service page; Guidance PDF — LINEE GUIDA 2025 |
| Italy temporary spectrum (filing lead-times) | As above | Both | Sets baseline filing times to allow engineering checks and coordination | Preferably 15 days; at least 30 days when frequencies involve Ministry of Defence bands; alternate frequency list required for such cases | Shorter filing windows increase risk of denial or delay | Follow guidance section on coordination | Lead-time rules current in 2025 guidance | Not applicable | MIMIT | LINEE GUIDA 2025 — MIMIT PDF |
| Italy temporary spectrum (fees and unit) | As above | Both | Charges contributions in fixed 15-day units by link type, bandwidth, path length | Examples in guidance: VHF/UHF land mobile channels above 30 MHz up to 12.5 kHz bandwidth at €300 per 15-day unit (≤ 15 km); >12.5–25 kHz at €600; radio camera links above 1 GHz up to 10 GHz range €630–€810 per 15-day unit depending on bandwidth class; SRD microphones fee scales by fleet size | Applicants pay after receiving case identifier; payment via DGTEL portal with case code in notes | Fees are communicated after validation of the request | All fee tables current in 2025 guidance | As per table in guidance | MIMIT | LINEE GUIDA 2025 — MIMIT PDF; Payment portal — Pagamenti DGTEL 05-FRQ_TMP |
| Italy temporary spectrum (SNG aviation proximity) | Satellite news gathering (SNG) near airports | Both (temporary) | Restricts operation near airport perimeters by reference to ERC decision for safety | Must respect minimum distances from airport boundaries | Event and news coverage must plan locations accordingly | Rule appears on the temporary-use service page | Current on page updated July 29, 2025 | Not fee-specific (general temporary scheme applies) | MIMIT; CEPT decision referenced | Autorizzazioni temporanee — MIMIT page |
| Event example: Milano Cortina 2026 (spectrum booking windows) | Temporary assignments in host areas | Both (temporary only during prep windows) | Defines booking windows (normal, late, extraordinary) and limits long-term rights in venues during prep | All requests must use the Spectrum Booking Portal; temporary authorizations expire by set dates before the Games | Organizers and users must follow the posted windows | Italy-specific event notice | Notice published January 24, 2025; lists precise date windows | Fees follow temporary-use tables if applicable | MIMIT | Avviso 24 gennaio 2025 — Milano Cortina 2026 — MIMIT notice |
| Licensed IoT via mobile operators (what it is) | NB-IoT, LTE-M, 5G | Licensed | Uses operators’ exclusive rights of use; supports wide-area coverage and service-level targets | Technical conditions governed by EU harmonization and national assignment rules | Suitable for city-wide and national deployments needing reliability | Italy allocates pioneer bands via AGCOM acts | Auction/assignment framework set 2018; further consultations in 2025 for extending 26 GHz | Market pricing via commercial contracts; not a government fee | AGCOM; European Commission for harmonization | AGCOM Delibera 231/18/CONS — AGCOM PDF; AGCOM Delibera 21/25/CONS — AGCOM page and PDF |
| Licensed pioneer band: 700 MHz | 694–790 MHz | Licensed | Harmonized for mobile broadband; good indoor coverage | Duplex arrangements and emission masks per EU decisions | Operators may host NB-IoT and LTE-M | Assigned via 2018 AGCOM act | Timetables in AGCOM act for rollout and coverage | Commercial | AGCOM; European Commission | AGCOM Delibera 231/18/CONS — PDF |
| Licensed pioneer band: 3.4–3.8 GHz | 3,400–3,800 MHz | Licensed | Harmonized as primary 5G capacity band | Technical conditions for IMT set by EU; national assignment fixes blocks and obligations | Supports high device density and throughput | Assigned via 2018 AGCOM act | Rollout targets defined in act | Commercial | AGCOM; European Commission | AGCOM Delibera 231/18/CONS — PDF |
| Licensed pioneer band: 26.5–27.5 GHz (upper 26 GHz) | 26.5–27.5 GHz | Licensed | Millimeter-wave 5G band for very high capacity | Line-of-sight links; small cells; site-specific planning | Useful for venues, campuses, fixed wireless | Assigned via 2018 AGCOM act | Rollout conditions in act | Commercial | AGCOM; European Commission | AGCOM Delibera 231/18/CONS — PDF |
| Licensed band extension under consultation: 24.25–26.5 GHz (lower 26 GHz) | 24.25–26.5 GHz | Licensed (planned procedures) | AGCOM consultation to create procedures and rules for assignments in the lower 26 GHz portion | Will align legacy WLL holdings with 5G use; details finalized through consultation and subsequent acts | Important for expanding mmWave coverage options | Italy formal process documented by AGCOM | Consultation act January 22, 2025; technical attachment January 27, 2025 | Not applicable (policy stage) | AGCOM | Delibera 21/25/CONS — AGCOM page; Delibera PDF; Allegato A PDF |
| AGCOM annual report (context and milestones) | All telecom and spectrum policy areas | Both | Provides institutional overview and milestone reporting for spectrum policy | Not a technical standard; a policy report | Useful for tracking refarming calendars and coverage updates | Italy reference for annual policy status | 2025 report published | Not applicable | AGCOM | Relazione annuale 2025 — AGCOM PDF |
| Who sets what: EU vs CEPT vs Italy | EU law, CEPT recommendations, Italy PNRF and AGCOM acts | Both | EU decisions harmonize conditions; CEPT gives detailed SRD tables; Italy maps bands nationally and assigns licensed bands | Technical conditions in EU/CEPT; national notes and assignments in Italy | Projects must read all three levels | Italy uses PNRF for national mapping; AGCOM issues assignments | Current as of 2025 | Not applicable | European Commission; CEPT; MIMIT; AGCOM | (EU) Implementing Decision 2025/105 — EUR-Lex; (CEPT) ERC/REC 70-03 — ECO DocDB; (Italy) PNRF — MIMIT |
| What “shared” vs “licensed” means for reliability | SRD vs NB-IoT/LTE-M/5G | Both | Shared: quick access, no protection; Licensed: coordinated, coverage obligations | Shared: duty-cycles, power caps; Licensed: assigned blocks, operator build-out | Choose based on reach and reliability needs | Italy applies both models | Always current policy distinction | Shared has no fees; licensed is commercial | CEPT; AGCOM; MIMIT | ERC/REC 70-03 — ECO DocDB; AGCOM Delibera 231/18/CONS — PDF |
| Practical example: city traffic sensors (shared) | 869.x MHz SRD for alarms | Shared | Use low power and low duty-cycle for short alerts | Example: 0.1% to 1% duty-cycle, 10 mW power in certain channels | Must tolerate interference peaks | Check PNRF for local notes; certify to EN 300 220 | Current in 2025 | No license fee | CEPT; MIMIT | ERC/REC 70-03 — ECO DocDB; PNRF — MIMIT; EN 300 220 — ETSI PDF |
| Practical example: regional metering (shared) | 169.4–169.475 MHz for meter reading | Shared | Longer reach with higher power under metering category | Up to 500 mW with duty-cycle up to 10% (application-specific) | Configure devices for the correct category | Check PNRF and certify to EN 300 220 | Current in 2025 | No license fee | CEPT; MIMIT; ETSI | ERC/REC 70-03 — ECO DocDB; PNRF — MIMIT; EN 300 220 — ETSI PDF |
| Practical example: city-wide maintenance logs (licensed) | NB-IoT in 700 MHz | Licensed | Uses operator network for strong indoor and wide-area coverage | Operator implements 3GPP tech; meets assignment rules | Service via commercial contract | Italy assignments set by AGCOM | Assignment act 2018; ongoing service | Commercial pricing | AGCOM | Delibera 231/18/CONS — AGCOM PDF |
| Practical example: campus telemetry (shared wideband) | 2.4 GHz Wi-Fi/802.15.4 | Shared | Local bulk data without duty-cycle caps; uses adaptive access rules | EN 300 328 defines access behavior and receiver performance | Good for non-critical or back-office traffic | Italy follows CEPT annex for wideband SRD | Standard current | None (shared band) | ETSI | EN 300 328 — ETSI PDF |
| Temporary links during pilots (process) | Various bands | Both | Request temporary authorization with forms; pay contributions; obey time limits | Technical schedule per link; adhere to duty-cycle and power caps where relevant | Use during events, field trials, short staging | File preferably 15 days ahead; 30 days if MoD coordination | Guidance posted 2025; page updated July 29, 2025 | Fees per 15-day unit by link type | MIMIT | Autorizzazioni temporanee — MIMIT page; Guidance — MIMIT PDF |
| Sanctions reference (unlawful operation) | All bands | Both | Penalties for operating without required authorization or against limits | Refer to national electronic communications code articles | Enforced by national authorities | Italy’s code maintained on official portals | Code consolidated with 2024 updates | Not a fee table | Government of Italy | Codice delle comunicazioni elettroniche — Gazzetta Ufficiale; Normattiva code entry |
| Procurement law context (public buyers) | Public contracts for IoT services | Both | Sets how public bodies in Italy must procure, modify, and manage contracts | Provides legal basis for change orders and performance clauses | Use to structure “change in law” and migration clauses | Applies to all public buyers in Italy | Code enacted March 31, 2023; in force with later amendments | Not applicable | Government of Italy | Codice dei contratti pubblici — Normattiva (D.Lgs 36/2023) |
| EU telecom code (authorization framework) | EU-wide | Both | Sets EU framework for spectrum authorizations and rights of use | Member states implement under national law | Basis for licensing terms across EU | Italy implements through AGCOM/MIMIT acts | Directive published December 17, 2018 | Not applicable | European Union | Directive (EU) 2018/1972 (EECC) — EUR-Lex OJ |
| Choosing between shared and licensed for a project | Any IoT project | Both | Shared bands: quick and low-cost but unprotected; Licensed bands: coordinated and more reliable but via operators | Match message size, frequency, and reach to legal limits and service levels | Use redundancy if relying on shared bands; plan contracts if licensed | Check PNRF notes and AGCOM acts | Always current | Costs depend on choice (shared vs operator contracts) | MIMIT; AGCOM; CEPT; EU | PNRF — MIMIT; ERC/REC 70-03 — ECO DocDB; AGCOM 231/18/CONS — PDF; EU 2025/105 — EUR-Lex |
| Project timing controls (licensed deployments) | NB-IoT/LTE-M/5G | Licensed | Track AGCOM consultations and acts that may refarm or expand bands | Build migration plans tied to official effective dates | Use quarterly legal checks against AGCOM and PNRF pages | Italy: AGCOM acts and PNRF page are the reference | 2018 base act; 2025 consultations; future acts to follow | Not applicable | AGCOM; MIMIT | Delibera 231/18/CONS — PDF; Delibera 21/25/CONS — Page; PNRF — MIMIT |
| Project timing controls (temporary deployments) | Temporary links | Both | Schedule around filing windows (15 or 30 days) and fee blocks (15 days) | Plan quindicine blocks to avoid paying for unused time | Provide alternate frequencies when MoD bands are involved | Italy: process and forms on MIMIT page | Guidance current 2025; page updated July 29, 2025 | Fees per 15-day unit | MIMIT | Autorizzazioni temporanee — MIMIT page; LINEE GUIDA 2025 — PDF |
| Compliance documents to attach in tenders/contracts | SRD and licensed IoT | Both | Include CEPT/EU/PNRF citations and ETSI standards in technical schedules | List exact band, sub-band, duty-cycle/power, and the ETSI test standard | Helps auditors and reduces disputes | Italy: add PNRF URL and AGCOM act links | Always current practice | Not applicable | Buyer organizations; suppliers reference authorities | ERC/REC 70-03 — ECO DocDB; EU 2025/105 — EUR-Lex; PNRF — MIMIT; EN 300 220 — ETSI; EN 300 328 — ETSI |
| Interference-risk controls in shared bands | 863–870 MHz, 169 MHz, 2.4 GHz | Shared | Enforce time-on-air and power caps; use APC and LBT where required | Examples: APC to ≤ 5 mW for 865–868 MHz networks; LBT for access points per EN 303 204 | Add redundancy and retries; accept non-protection status | Italy: same CEPT rules; check PNRF notes | Current in 2025 | No license fee | CEPT; ETSI | ERC/REC 70-03 — ECO DocDB; EN 303 204 reference in annex; EN 300 220 / EN 300 328 — ETSI / ETSI |
| Why these rules matter (public safety and cost) | All deployments | Both | Clear limits let many services share spectrum safely and efficiently | Following the limits prevents harmful interference | Reduces outages for alarms, meters, and transport systems | Italy enforces via national code and regulators | Always current | Costs lower when designs match legal limits from the start | Government of Italy; MIMIT; AGCOM | Electronic communications code — Gazzetta Ufficiale; PNRF — MIMIT; AGCOM — Relazione 2025 |
