New forms for masts and fibre excavation: two deadlines, and the letters no longer match

The urban excavation application you have in preparation is being built on form H, and until September that was the right letter. In the annex published in the Gazzetta Ufficiale on 25 September, H is the notice of commencement of works for radio installations, and the application for civil works, excavation and occupation of public land in urban areas has become form J. Local authorities have until 9 November 2026 to update the forms they use: until then the same letter, on different portals, can open different procedures.

Nine forms become eleven

The Agreement concluded in the Conferenza Unificata on 10 September 2026 (Repertorio atti no. 108/CU) rewrites annex 12-bis to the Italian electronic communications code. Article 1(2) contains one word worth rereading: the new forms «sostituiscono i modelli provvisori adottati con decreto direttoriale 14 febbraio 2025» — replace the provisional forms of 14 February 2025. Provisional: the forms filled in for eighteen months were, by the admission of the act superseding them, a bridge.

The bridge had nine forms, A to I, in three parts. The new annex has eleven, A to K, with no parts. This is not an addition at the end: the letters have shifted. The old form F covered temporary mobile telephony installations and non-substantial variations together; they are now two forms, F and G. A form H appears that did not exist before — notice of commencement of works under article 40(5) of decree-law 77/2021, for variations with a height increase of at most 1.5 metres and a silhouette-area increase of at most 1.5 square metres. And the two excavation forms, formerly H and I, slide down to J (urban areas) and K (non-urban areas), both under article 49(1) of legislative decree 259/2003.

Two dates, and they do not bind the same parties

Article 1(3) sets two distinct deadlines, under article 24(2-bis), (3) and (4) of decree-law 90/2014 as converted by law 114/2014. For the regions: «le regioni adeguano entro il 26 ottobre 2026 … utilizzando le informazioni contrassegnate come variabili» — the regions adapt by 26 October 2026, using the information marked as variable. For local authorities: «entro e non oltre il 9 novembre 2026» — by 9 November 2026 at the latest — to adapt the forms in use. Article 1(4) adds one line: regions and local authorities are to ensure «la massima diffusione dei modelli allegati», the widest possible circulation of the attached forms.

The information marked as variable carries a precise sign. At the foot of forms A to H a note says that sections and information liable to vary on the basis of regional rules are «contrassegnate con un asterisco (*)» — marked with an asterisk. On forms I, J and K that note is absent, and the only asterisk left points to the digital signature. Which, for anyone filing excavation work, reads as follows: nothing on forms J and K is left for a region to fill in, and the only date that concerns you is the local authorities’ one.

The route is no longer described in prose

On the 2025 form the route was narrated: it had to be described concisely but exhaustively, and streets affected, length of the installation and laying technique were one bullet inside the contents of the attached site plan.

On form J, section A is made of boxes: length of the route, streets affected, route coordinates (UTM) with X and Y. A footnote states the system: «Fare riferimento al sistema geodetico nazionale ETRF 2000 di cui al DM 11 maggio 2016» — the national ETRF 2000 geodetic system of the ministerial decree of 11 May 2016, which established the national federated infrastructure register. The letters ETRF never appear on the 2025 forms — the same reference as the data already fed to that register.

Then a closed list of eight laying techniques: microtrench, minitrench, horizontal drilling, aerial laying, laying in existing infrastructure, traditional excavation, mixed, other. Each with its reference — minitrench to article 8, drilling to article 7 and traditional excavation to article 9 of the ministerial decree of 1 October 2013, laying in existing infrastructure to article 3 of legislative decree 33/2016. The first box is the most recent: «Microtrincea (rif. articolo 40, comma 4, del D.L. 77/2021, come modificato dal D.L. 19/2026, convertito con L. 50/2026)». The reference is to a law of April 2026: that box could not exist on a form dated February 2025.

The engineer signs, and so does the subcontractor

Three requirements absent in 2025. The first is a section for the engineer’s details, on ten forms out of eleven — missing only from form I, the one addressed to the environmental agency alone. It asks for surname, tax code, professional register, digital domicile, and closes with a declaration under articles 46 and 47 of presidential decree 445/2000: «che le informazioni e i dati contenuti negli allegati tecnici alla presente pratica corrispondono a verità» — that the data in the technical annexes are true. The technical annexes now have a signatory with a name.

The second applies to all eleven forms: the declarant certifies that none of «le cause di divieto, di decadenza o di sospensione previste dalla legge» — the grounds of prohibition, forfeiture or suspension provided for by law — applies to them, under article 67 of legislative decree 159/2011. The 2025 forms had no anti-mafia declaration.

The third concerns whoever does the digging. Among the contents of the works design, marked always mandatory, forms J and K call for «la metodologia e i materiali utilizzati per il ripristino della sede stradale» — the method and materials used to reinstate the road surface — and, where the work is subcontracted, for «la ragione sociale e i recapiti del direttore dei lavori dell’impresa» — the company name and contacts of the contractor’s site manager. If the site manager is not yet appointed, the details must reach the one-stop shop before works begin. The applicant’s identity data also leave the form: they become a separate annex, approved by the Conferenza Unificata agreement of 4 April 2024.

What the agreement does not say

The agreement sets two dates and an obligation to circulate. It does not say what becomes of an application filed on a superseded form. And the new forms drop the warning that closed the 2025 list of attachments — if even one was missing, «l’istanza risulterà incompleta e quindi non istruibile», the application is incomplete and therefore cannot be processed. In its place stands the column marking every attachment as always mandatory.

The practical consequence is ours, not the act’s: in this window the letter on the form is not reliable information. What identifies the application is the procedure and the article invoked — article 49(1) for excavation and occupation of public land, article 44 for the installation permit — not the letter printed at the top of the page.

The point

An application that comes back does not show up at acceptance testing: it shows up six weeks later, when the site should have opened. In the compliance specifications we deliver, the reference to a form is written by procedure and article, never by letter, and the documentation the application demands — design with laying technique and reinstatement, 1:1,000 site plan, 1:25,000 extract, engineer’s declaration — is verified before filing, the way a measurement is verified at acceptance. On the other axis: route length, streets, ETRF 2000 coordinates, declared laying technique and the site manager’s name are exactly the data every application produces and that then sit in separate folders. With us they converge into a single map of the network and its sections, where an AI flags a filed route that does not match the as-built, or a section authorised as a microtrench and laid some other way, and a team of ours closes the gap before acceptance testing. Where an AI is needed on that data, it runs inside the client perimeter — on-premises or in a dedicated cloud with data centres in Italy — with CSIDIA, the other company in the group. Our own teams, no subcontracting.

Are you preparing excavation and installation applications, or do you have to accept the filings a supplier makes on your behalf? Talk to one of our engineers: the site visit is free of charge, and an application is prepared to hold up at the counter, not to go out on time.