National radio interfaces: which sheet is your microwave link declared against?
7 min read
Anyone installing and commissioning a microwave link, an FWA terminal or an unlicensed-band backhaul hands over a file in which the conformity of the apparatus fits into two lines: the CE marking and an ETSI designation. If those two lines are all there is, at the first inspection they do not prove that this apparatus may sit on that band, in Italy, under that licence.
The reason is that in Italy the conditions of use of a band are not set out in the European standard: they sit in the radio interface specifications the Ministry notifies to the Commission. Article 8(1) of legislative decree 128 of 22 June 2016, which transposed Directive 2014/53/EU, says so: under the procedure in Directive (EU) 2015/1535, «il Ministero notifica le interfacce radio che intende regolamentare» — the Ministry notifies the radio interfaces it intends to regulate. And article 7 speaks directly to whoever climbs the mast: radio equipment may be put into service and used if it is properly installed, maintained and used for its intended purpose, and compliant with the decree.
The list about to be replaced
That list is still the one in the ministerial decree of 10 January 2005. MIMIT has put its wholesale replacement out to consultation: a draft directorial decree from the Directorate-General for Digital and Telecommunications, Division VI, described in the recitals as the surveillance authority for radio equipment. Article 2 is one line long: «È abrogato il decreto ministeriale 10 gennaio 2005 e successive modificazioni» — the ministerial decree of 10 January 2005, as amended, is repealed.
The deadline for contributions, 10 September 2026, has passed. As at the date of this note the decree does not appear to have been adopted: it is not among the Ministry’s directorial decrees, and the most recent item on the subject under notices and announcements is still the consultation.
What a sheet looks like
Each interface is a sheet of fifteen parameters. The first twelve are marked «Parte normativa», the normative part: service, application, frequency band, channelling, modulation, direction and separation, power, channel access, authorisation regime, additional essential requirements, frequency planning assumptions, envisaged changes. The last three make up the informative part: reference, notification number, remarks.
One example. Sheet T47, «APPARATI PER SERVIZIO FISSO», fixed service equipment, application point-to-point microwave links, covers 1350.000-1375.000 MHz paired with 1492.000-1517.000 MHz, with channel spacings from 2 MHz down to 0.025 MHz; the authorisation regime is general authorisation or individual right of use, and planning refers to ECC Recommendation T/R 13-01. T64 packs three millimetre-wave blocks together — 22.0-23.6, 24.5-26.5 and 27.5-29.5 GHz — with channel spacings up to 112 MHz.
The Ministry announces 113 interface sheets; in the PDF out for consultation the numbered sheets are 112: T01-T94 terrestrial, M01-M15 maritime, A01-A03 aeronautical. Twenty-eight carry the heading «APPARATI PER SERVIZIO FISSO»: these are the microwave links and the point-to-multipoint systems.
Where the ETSI standard stops
Here is the point for whoever signs. The reference to the European standard is not in the normative part of the sheet: it is parameter 13, the reference, and it sits in the informative part. Of the twenty-eight fixed-service sheets, twenty-four write it like this: “EN 302 217”. No part number, no version.
Today that designation covers three documents, and only one serves the purpose. ETSI EN 302 217-1 V3.4.1 (2025-07) is a “EUROPEAN STANDARD” and gathers, its title says, the “requirements not related to access to radio spectrum”. ETSI EN 302 217-2 V3.4.1 (2025-07) is instead a “HARMONISED EUROPEAN STANDARD”, subtitled “Harmonised Standard for access to radio spectrum”, for digital systems from 1 GHz to 174.8 GHz: this is the part written to carry the presumption of conformity. ETSI EN 302 217-3 is still at V2.2.1 of April 2014 and still describes itself as a “Harmonized EN covering the essential requirements of article 3.2 of the R&TTE Directive”, the directive that 2014/53/EU replaced.
Point-to-multipoint follows the same pattern: EN 302 326-1 V1.2.2 dates from 2007, EN 302 326-3 V2.1.1 from 2021, and the only harmonised part is EN 302 326-2, reissued as V2.2.1 in March 2026.
And harmonised standards carry a calendar that ends up inside the files. EN 302 217-2 V3.4.1 was adopted on 2 July 2025, is to be published as a national standard by 30 April 2026, and requires conflicting national texts to be withdrawn by 30 April 2027. EN 302 326-2 V2.2.1 was adopted on 12 March 2026: publication by 31 December 2026, withdrawal of conflicting texts by 31 December 2027. A declaration that says only EN 302 217, on those dates, no longer says what the apparatus was tested against.
The field left blank in the draft
There is a second detail worth knowing before citing the draft in a specification. Parameter 14 of every sheet is the notification number: it is blank in all 112. And in the recitals the notification to the Commission appears as “n. …../……/I”, dots in place of the digits. The picture is not closed: this is material for preparing files, not for closing them.
The cost of getting it wrong sits in the same legislative decree. Article 43 lists among the non-conformities an EU declaration of conformity that has not been correctly drawn up, and technical documentation that «non è disponibile o è incompleta», is unavailable or incomplete: for these the Ministry orders the operator to put matters right within a peremptory six-month deadline; article 46 adds a fine of 1,322 to 15,877 euro, plus 13 to 78 euro per unit, up to a ceiling of 132,316 euro. The problem is not the figure: it is reconstructing, in six months, unit by unit, what text the declaration was written against.
What to write, from now on
- the sheet code and its version — all V.1.0.0 in the draft — not just the band;
- the band and channel spacing actually configured, checked against parameters 3 and 4 of that sheet;
- the authorisation regime in parameter 9 and the licence that covers it, because who answers for what changes between a general authorisation and an individual right of use: it is the same check on entitlement that applies to whoever supplies a fibre network;
- the harmonised standard in full, with part, version and date, not the bare designation;
- the revision date of the file, because article 1 of the draft warns that the interfaces are subject to revision and supplementation whenever the national frequency allocation plan is updated.
What we do not know
We do not know whether or when the decree will be adopted, nor from what date: the consultation has closed, the text has not. We do not know why the Ministry announces 113 sheets while the PDF numbers 112: it could be a sheet that never made it into the file, or a different count. We do not know the notification numbers filed with the Commission, nor whether the final version will write the ETSI references with part and version. The text of the 10 January 2005 decree is not on Normattiva: the URN does not resolve, and we have not verified its publication reference in the Gazzetta.
How we solve it
On a radio installation the part that gets forgotten is not the alignment: it is the line saying which sheet that apparatus was declared against. We put it in writing twice. In the specification, as a clause: sheet code and version, band and channel spacing, authorisation regime, harmonised standard with part and version — and the same list becomes a checkpoint at acceptance, with the report handed over together with the installation. And then on the map: sheets, licences, bands and standard versions stop being scattered attachments and sit next to the optical traces and the as-built, as one object. On that map an AI running inside the client’s perimeter — on-premise, or in a dedicated cloud with data centres in Italy, together with CSIDIA, the other company in the group — answers the question that today costs six months of chasing: when a sheet changes, which units need reviewing. It is the method we bring to our network services and to our work on data and infrastructure AI. Our own crews, no subcontracting.
Do you have radio equipment in the field and a file that cites only the bare standard designation? Get in touch: we will look at which sheets apply to you and what the documentation is missing.