Associazione Italiana Internet Provider
AIIP
Promuovere e diffondere in Italia: - l’accesso al mercato delle reti e/o dei servizi di comunicazioni elettronica, ivi compreso l’accesso ad Internet, realizzati con ogni tecnologia secondo criteri di obiettività, trasparenza, non discriminazione, proporzionalità e non distorsione della concorrenza, anche attraverso la eliminazione delle barriere che ne ostacolano la crescita; - l’accesso al mercato dei contenuti multimediali (news, eventi sportivi, opere cinematografiche, opere protette dal diritto d’autore, etc.) e, più in generale, dei contenuti e servizi che possono essere forniti per il tramite di reti e/o servizi di comunicazione elettronica e della relativa fornitura al pubblico secondo criteri di obiettività, trasparenza, non discriminazione e non distorsione della concorrenza; - L’accesso al mercato di contenuti e servizi fruibili tramite le reti di comunicazione, secondo criteri di obiettività, trasparenza, non discriiminazione e non distorsione della concorrenza.
ID: 255497819753-30
Lobbying Activity
Response to Report on the review of the Digital Decade Policy Programme
16 Dec 2025
Associazione Italiana Internet Provider (AIIP), representing more than 60 competitive operators in the Italian telecommunications and digital infrastructure sector, welcomes the opportunity to contribute to the consultation on the Digital Decade Policy Programme. In our feedback, we emphasize key points that we believe are essential for the future development of Europes digital sovereignty and resilience. AIIP's key points are the following: - The current DDPP objectives and targets are misaligned with Europes digital realities and must be reoriented around digital sovereignty as a core strategic priority. - Europes growing dependence on non-European digital infrastructures, governed by extraterritorial laws, undermines legal certainty and economic resilience. - Targets should shift from symbolic KPIs to concrete criteria based on ownership, governance, jurisdiction and correct analysis of the real requirements. - Public procurement processes should be reformed to prioritize sovereign EU providers, with progressive quotas and stronger SME inclusion. - New monitoring indicators should focus on physical infrastructure, market concentration, fiscal contribution, and exposure to extraterritorial risks. - Governance should prioritize real infrastructure investment over excessive reporting, and avoid the creation of new oligopolies. - The role of regional and local authorities should be strengthened, enabling them to become active digital actors in the digital sovereignty agenda. Our detailed contribution is provided in the attached document.
Read full responseMeeting with Manuel Mateo Goyet (Acting Head of Unit Communications Networks, Content and Technology)
20 Nov 2025 · Exchange of views of data centres in Europe and the upcoming Cloud and AI Development Act
Response to Roadmap for artificial intelligence and digitalisation for energy (RAID-E)
4 Nov 2025
Associazione Italiana Internet Provider (AIIP) represents vertically integrated Italian operators owning and managing both broadband infrastructure and data centres, AIIP welcomes the initiative of a strategic roadmap for digitalisation and AI in the energy sector but raises strong concerns about its current direction. The Strategic Roadmap, while well-intentioned, risks further marginalising local and independent players in favour of global hyperscalers that already dominate the digital landscape. Without a recalibration of priorities, the initiative may undermine both European competitiveness and territorial cohesion. AIIP's position is further explained in the attached document.
Read full responseResponse to Digital Fairness Act
24 Oct 2025
The Italian Association of Internet Providers, AIIP, welcomes the European Commissions initiative to address unfair digital practices and improve consumer protection. As a long-established association representing over 60 SMEs operating in the digital sector throughout Italy, we support any initiative that protects citizens and strengthens a competitive and transparent market. However, it is essential that new rules avoid overburdening responsible and law-abiding small businesses, while ensuring strict oversight on the major players whose practices are at the core of todays digital imbalances. AIIP's position on the call for evidence's main areas of interest is further explained in the attached document.
Read full responseResponse to General revision of the General Block Exemption Regulation
6 Oct 2025
Associazione Italiana Internet Provider (AIIP), representing more than 60 competitive operators in the Italian telecommunications and digital infrastructure sector, welcomes the opportunity to comment on the announced revision of the General Block Exemption Regulation (Reg. 651/2014). In the attached document, you will find our comments on the general objective of the initiative, namely the simplification and reduction of administrative burdens for State aid granted under the General Block Exemption Regulation (GBER), as well as an in-depth analysis of aid aimed at supporting the take-up of ultra-broadband (so-called "Connectivity Vouchers" - Article 52c).
Read full responseResponse to Review of the Digital Markets Act
23 Sept 2025
Associazione Italiana Internet Provider (AIIP) represents more than 60 independent operators across the Italian country, including fixed and wireless network providers, datacenter and cloud operators, and companies offering broadband connectivity and digital services to both consumers and enterprises. As such, we are directly impacted by the market distortions addressed by the Digital Markets Act, and we welcome the opportunity to provide input to its first review. AIIP strongly supports the foundational principles of the DMA, especially its ambition to restore fairness and contestability in digital markets. However, to be fully effective, the DMA must go beyond symbolic compliance and ensure that the logic of gatekeeper regulation is fully extended to todays dominant and emerging players alike. At the same time, we urge the Commission to maintain a sharp distinction between the economic regulation of gatekeepers and the regulation of speech or expression online, which must remain beyond the remit of the DMA. Please find our contribution attached.
Read full responseResponse to Burden reduction and simplification for competitiveness of small mid-cap enterprises - Omnibus Regulation
25 Aug 2025
AIIP welcomes the Commissions proposal to streamline regulatory obligations for small and mid-sized enterprises as part of the Omnibus IV initiative. As Italys first and historic association of independent Internet and cloud providers, we represent over 60 companies operating across connectivity, fibre, data centre and cloud services with more than 250,000 business customers and 1 million residential clients. Based on our members direct experience, we believe the General Data Protection Regulation (Reg. EU 2016/679) remains disproportionately burdensome for SMEs. Without questioning the fundamental value of data protection, it is clear that current enforcement mechanisms and compliance expectations place significant strain on small operators, often without enhancing actual safeguards for citizens. In this context, AIIP proposes the following five priority areas for simplification: 1. Voluntary Compliance Declaration (New Art. 30): introduce an opt-in system whereby SMEs may submit a simplified privacy compliance document, outlining their internal model and security measures. If accepted by the competent authority, such declaration would suspend ordinary inspections for 24 months, unless serious incidents occur. This would reduce litigation, increase clarity and reward genuine compliance. 2. Stop the Risk of the Risk Approach (Art. 24): shift the focus from abstract or indirect risk scenarios to tangible, demonstrable threats. SMEs cannot be expected to prevent events that are hypothetical or speculative in nature, especially when based on vague standards of what might go wrong. 3. Balance with Freedom to Conduct a Business (Art. 5 and New Recital 13): enshrine the principle that data protection must be balanced with the economic continuity of the enterprise, as recognised under Article 16 of the EU Charter. Especially for SMEs, regulation should not impose disproportionate obligations that threaten business survival or innovation. 4. Inspection = Correction, Not Punishment (Art. 58): establish a minimum 90-day corrective period for SMEs found to be non-compliant in minor or formal aspects, before any sanctions are applied. This fosters cooperation and improves outcomes without unnecessary litigation or reputational damage. 5. Clarity on Enforcement Priorities: the Commission and national DPAs should jointly publish interpretative guidance specifying which obligations are to be considered core (i.e., protecting fundamental rights) versus those which are formal or secondary. This would help SMEs prioritise and optimise their resources. These proposals are not intended to weaken the GDPR but to make it more effective, proportionate and aligned with the operational reality of small businesses. An SME willing to comply should not be treated with the same tools designed for large tech conglomerates. A resilient European economy requires regulatory credibility but also trust, predictability, and a sense of fairness. We attach a background note with the draft legislative amendments we have submitted to our national authorities.
Read full responseResponse to Commission Implementing Regulation on fair use and anti-fraud policy for intra-EU communications
21 Jul 2025
Associazione Italiana Internet Provider (AIIP), welcoming the ongoing initiative and the opportunity to provide its own assessments, highlights the need to reconsider the proportionality of certain provisions in the draft. To this end, it submits the attached proposed amendments to the text, provided in an editable document with visible revisions, along with the corresponding explanatory notes.
Read full responseResponse to Digital Networks Act
10 Jul 2025
Associazione Italiana Internet Provider (AIIP) is the first and historic Italian association representing more than 60 Internet operators, infrastructure and network providers, including FTTH, as well as providers of electronic communications services, data center and cloud services. For thirty years, AIIP has been actively promoting an open, competitive and innovative telecommunications market in the interest of businesses and end-users. AIIP takes note of the call for evidence on the Digital Networks Act and appreciate the opportunity to contribute to this important debate. Below a summary of our positions on the Digital Networks Act: 1) Procedural Transparency: The draft text of the DNA should be subject to a dedicated public consultation before being submitted to the European Parliament and the Council. 2) Market assessment criteria: Market assessments must consider that bigger is not always more efficient; economies of density play a crucial role. 3) Regulatory Stability: The current SMP-based and symmetric access framework is effective and should not be undermined by broad deregulation. 4) Simplification: Streamlining and cutting red-tape are welcome, but must not result in the removal of essential ex-ante regulation. 5) Spectrum: AIIP opposes automatic licence extensions, which would harm market contestability and distort competition. 6) Copper Switch-Off: Switch-off should remain voluntary and based on geographic and service-specific analysis. 7) Net Neutrality: Any reinterpretation of Open Internet rules that allows preferential treatment must be rejected; net neutrality must be preserved. Our position is further detailed in the attached document.
Read full responseResponse to Cloud and AI Development Act
3 Jul 2025
The Italian Internet Providers Association (AIIP) is the first and longest-standing Italian association representing Internet operators, infrastructure and network providers, including FTTH, as well as providers of electronic communications services, data center and cloud services. For thirty years, AIIP has been actively promoting an open, competitive and innovative telecommunications market in the interest of businesses and end-users. AIIP's feedback is attached below.
Read full responseResponse to The EU Cybersecurity Act
20 Jun 2025
The Italian Association of Internet Providers (AIIP) is the first and longest-standing Italian association representing Internet operators, infrastructure and network providers, including FTTH, as well as providers of electronic communications services, data center and cloud services. For thirty years, AIIP has been actively promoting an open, competitive and innovative telecommunications market in the interest of businesses and end-users. AIIP has a direct interest in participating in the current procedure aimed at assessing possible updates to the Cybersecurity Act (CSA), both because a secure and protected environment is a prerequisite for the expansion of communication and cloud networks and services, and because such objectives must be pursued proportionally, avoiding the imposition of excessive and unsustainable burdens on the system and on the companies subject to cybersecurity obligations. AIIP's feedback is attached below.
Read full responseResponse to Impact assessment on retention of data by service providers for criminal proceedings
10 Jun 2025
AIIP represents 63 ISPs, CSPs and IXPs and, as such, possesses direct experience with data retention obligations and operational processes. Italian national rules, as outlined in Art. 132 et seq. of D.lgs. No. 196/2003 (the Privacy Code), stipulate retention periods ranging from 30 days to 24 months. However, these limits are overridden by an exceptional anti-terrorism provision (Art. 22 of L. 167/2017), which extends the retention period to 72 months a duration that appears disproportionate and infringing the rights of European citizens. Despite these issues, AIIP argues against a rigid, top-down approach at the European level, and deems that: 1. The regulation of data retention should primarily pertain to Member States. 2. Any European intervention should primarily aim at curbing disproportionate national measures and ensuring a level playing field between ISPs and large platforms. 3. Soft law instruments should be preferred. Any proportionality assessment must encompass all aspects of data retentionsuch as duration and scopewhich, in themselves, pose a risk to the rights of European citizens. While AIIPs providers have implemented robust systems to safeguard data, no system can offer absolute protection, particularly against hostile state actors. AIIP notes that potential attacks are likely to exploit social engineering techniques, rather than technological ones. The Italian legal framework on data retention has been marked by interpretative uncertainty, further exacerbated by legislative volatility (Art. 132 of the Privacy Code has been amended thirteen times). In this context, even requests from law enforcement authorities may raise compliance concerns, placing ISPs in a difficult position between the obligation to respond promptly and the duty to uphold privacy regulations. AIIP identifies the lack of consistent operational practices among law enforcement agencies as a systemic vulnerability. Malicious actors may exploit this weakness through impersonation or forgery. Requests that appear to originate from competent authorities carry an implicit pressure for immediate compliance, and the combination of urgency and threatcommon in phishing attackscan be exploited with even greater efficacy when mimicking official data access requests. At the industry level, AIIP highlights that data retention obligations increase operational costs for European TelCos, which are already at historic highs due to the growing regulatory burden at both national (e.g., IP-DNS filtering obligations under the Piracy Shield) and European levels (e.g., NIS2 Directive). For large companies, this results in higher prices and/or reduced investment capacity, thereby diminishing international competitiveness. The impact is even more severe for SMEs and startups, for whom compliance costs do not scale proportionally with business size, leading to a disproportionate burden and reduced market competition. Therefore, AIIP reiterates that all services provided to public authorities, including data retention for criminal investigations, must be compensated. Finally, the Commission should consider the risks associated with a top-down regulatory approach in this domain, which intersects with criminal procedure, privacy, and electronic communications laweach with distinct national practices. Such an approach risks introducing further complexity and undermining the very goal of harmonization. Even the use of a Directive may not mitigate these risks, as demonstrated by the Italian implementation of the EECC. Its transposition led to interpretative conflicts with pre-existing legislation on end-user rights, also due to fundamentally different regulatory paradigms. Despite extensive interventions by the national regulator, some legal uncertainty persists. Should a similar situation arise in the context of data retention, the resulting impacts on citizens rights and the digital ecosystem would be significantly greater.
Read full responseResponse to Assessment of the effects of the Recommendation on combating online piracy of sports and other live events
4 Jun 2025
Please find the feedback of Associazione Italiana Internet Provider (Italian Internet Providers Association) attached
Read full responseResponse to Technical description of important and critical products with digital elements
18 Apr 2025
Associazione Italiana Internet Provider (AIIP) welcomes the opportunity to provide feedback on the draft implementing regulation of the Cyber Resilience Act (CRA) and wishes to highlight critical aspects that may significantly impact small and medium-sized enterprises (SMEs), especially those that develop software internally for self-consumption or contribute to the open-source ecosystem. Please, find attached our comments on the draft Commission Implementing Regulation on the technical description of the categories of important and critical products with digital elements pursuant to Regulation (EU) 2024/2847 of the European Parliament and of the Council..
Read full responseResponse to How to master Europe’s digital infrastructure needs?
30 Jun 2024
Feedback provided as attached document.
Read full responseMeeting with Nicola Danti (Member of the European Parliament, Rapporteur)
21 Feb 2023 · Presentazione della posizione di AIIP sul Cyber Resilience Act
Response to The Union Position for the World Radiocommunication Conference 2023
25 Jul 2022
At AIIP (Associazione Italiana Internet Provider) we are very, very concerned about the future of landlines and the de-facto radio "extension" of the landline Internet services (for both residential and business), the Wi-Fi and it's future. Without a well sized range of "license free" spectrum, with room for future bandwidth and speed, the future of fiber and lindlines will be relegated to IMT networks backhauling, restricting even more the access market segment.
Without allowing a full unlicensed 6Ghz (5.945-7.125 Ghz) for NextGen WiFi like WiFi 6E and 7, as USA as already done, we will impair the future of wireless services as an extension of residential, public and industrial landlines, with a total dependence on 5G that, we known well, no one has really deployed (the real 5G, the one operating in band-C and, maybe in future, in other bands). Please also take in account that silicon shortage and the engineering savings by using a single chipset with a single software, without any variants for all Atlantic (Euro/USA) applications. It's insane, risky and not forward thinking to put all future of fixed & wireless future on 5/6G: if this plan fail (and has already proved to fail), we will not be able to have a fast and cheap solution for most of "verticals", as WiFi can do. Also without giving full 5.945-7.125 Ghz range to WiFi, it will not possible in the future to have more bandwidth/room for progressing performances on "wireless-from-fixed fiber services". We already are deploying 2.5 a 10G services (with 50G in trial with vendors), but without a consistent WiFi technology with room to grove when needed with an appropriate speed, customer will not be able to use it in full, finally leading to the end of landlines.
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