The Broadband Map has to be downloaded every month. Where is the proof?

Your order configurator asks for the street number and returns the list of technologies available at that address. Eight months from now someone will ask which extraction of the map the answer shown on 12 July rested on, for that contract, for that customer. If the only possible answer is the last one we downloaded, it is not an answer. And since 20 June 2026 there is a penalty behind that question.

The duty dates from February, the penalty from June

Article 13(1)(b) of decree-law no. 19 of 19 February 2026 — Italy’s recovery-plan decree, in force from 20 February — inserted into article 98-quaterdecies(1) of the Electronic Communications Code an obligation on internet access service providers: to tell the consumer which access network technologies are available at their service address, with their performance, on the basis of the mapping database of article 22. Conversion law no. 50 of 20 April 2026 added a single sentence to that letter, on penalties: they apply once two months have elapsed. The AGCOM circular of 3 July 2026, signed by the consumer protection and the networks and services directorates, concludes that the penalty regime becomes applicable as from 20 June 2026.

The buyer’s side we have already taken apart. This is the side of whoever has to produce the answer: every day, at every street number, and be able to prove it.

Above 50,000 customers you download, below it you redirect

The circular records that several operators opposed the idea of querying the Broadband Map in real time through an API, among other reasons because of the risk that a malfunction or unavailability of the external platform could prevent the sale from being completed. The Authority accepts the objection and, for this first application, sets two regimes. Operators with 50,000 customers or more must obtain the coverage maps made available through the Broadband Map by download, at least monthly. Below the threshold it is enough to give prominence, on the website and commercial channels, to a link redirecting to the portal. In both cases the data on display must sit where the customer sees it, inside the offer selection journey, on the one-to-one «canali mirati» of resolution 292/18/CONS.

The monthly download is evidence, not a box to tick

The circular says what to download and how often. It does not say how you prove you did. And proof is needed, for three reasons that sit in three different sources.

The first: paragraph 5 of the same article 98-quaterdecies provides that the paragraph 1 information becomes an integral part of the contract. The list of technologies at a street number is not sales material to be binned at the end of a campaign: it is a clause, and a clause has to be proven.

The second: article 1(31) of law 249/1997 — the provision invoked for penalties — punishes, in terms, those who fail to comply with the orders and formal warnings of the Authority. The moment that counts is not the sale; it is the formal warning that arrives months later and demands an account of one specific position. By then the question is no longer what does the map say today, but what did it say when you sold.

The third sits in the portal’s terms of use. The data are derived from statistical processing (sample statistical averages) and/or graphical processing of the data supplied by individual operators, with the warning that no right may be derived from the use of the output data, and the Authority reserves the right to add and/or modify and/or remove features and data without notice. Translated: July’s map no longer exists in September. Only the copy you kept.

The four lines your archive must be able to produce

To withstand a challenge — in a typical working model reconstructed backwards — four linked pieces of information are needed for every order:

which file was downloaded from the Broadband Map, with date, time and a fingerprint of its content;
which row of that file corresponds to the customer’s street number, and under which address normalisation rule: the map thinks in street numbers, the CRM in whatever someone typed on the phone;
what was shown on screen, on which channel and at which point of the ordering journey;
which document was handed over on a durable medium, and which extraction it came from.

One piece is missing, and the circular says so itself: the export format is among the questions referred to the technical working group opened with the consumer associations, for example on the format of the data to be exported. Anyone building the chain now should assume the format will change.

The same page carries a second deadline

The function that answers on an address is the one in article 7(4) of resolution 292/18/CONS. That resolution was amended by resolution 207/26/CONS of 29 July 2026, published on 12 August: new labels for mixed architectures — including a blue label for FWA offers meeting criterion 3 of the BEREC guidelines on very high capacity networks — and an obligation to place alongside those indications a link to the «pagina di trasparenza tecnica», the technical transparency page required by Annex A to resolution 156/23/CONS. The deadline is in article 2: the provisions of this resolution are implemented within 6 months of its publication, that is by 12 February 2027. Whoever opens the configurator for the map opens it twice, unless they do it once.

What we do not know

The circular does not define which customers count towards the 50,000 threshold: fixed lines, total customers, active contracts. It sets no format and no retention period for the evidence of the extraction. It does not clarify whether republishing Broadband Map data on an operator’s own commercial channels amounts to the derivative work for which the portal’s terms require the Creative Commons Attribution 4.0 credit to be shown: that is a question to put, not a risk to write off. And there is no published calendar of database updates: article 22 of the Code requires updating at least once a year, while the circular observes that the periodicity is longer than a month.

The point.

Two different jobs, and both have to be done. The first is contractual: the monthly extraction, the matching rule between map and address estate and the retention of the evidence become written clauses in the specification for the sales system, with a check at acceptance — take a sample order and trace back from the screen the customer saw to the file it came from. The second is data governance: extractions, address estate, answers given and contracts stop being four separate archives and become a single map, on which what did we say at that street number in July is settled by one query rather than a week of searching. Where an AI is needed for that, it runs inside your perimeter — on-premises, or dedicated cloud with data centres in Italy — together with CSIDIA, the group’s other company: the customer base never leaves the building. Our own teams, no subcontracting. It is the same rigour asked of a documented network, moved to the commercial front end.

Do you need to put the chain between map, configurator and contract back in order? Talk to an engineer: half an hour to find where it breaks.