On 6 November 2026 Italy's communications regulator AGCOM opened a public consultation on four draft schemes covering media service authorisations, DTT network operators, satellite and alternative media services, and conditional access systems. Trade outlet Advanced Television, our only source for the draft's content, calls the hybrid DTT/IP framework in Resolution 247/26/CONS the "cornerstone". Comments are due on 18 December. We have not read the AGCOM resolution text itself, so everything below about the draft's content rests on that report and should be checked against the official document.
What the draft reportedly does
According to Advanced Television, a standard DTT licence would automatically cover streaming the broadcaster's authorised schedule over IP through interactive applications. Hosting third-party IP content on an existing channel number would instead need a secondary authorisation and a logical channel number (LCN) adjustment. Local channels carrying third-party IP schedules would be placed in the 650–699 range, and national broadcasters hosting such content would get priority in 950–999. Moving a viewer from the DTT signal to an IP stream would require explicit action, such as pressing a button, after a clear on-screen notice. The reported draft also repeats the ban on brokering DTT transmission capacity and expects the consultation to clarify where unlawful capacity transfer ends and lawful third-party interactive hosting begins.
The same report says commercial broadcasters would need to be joint-stock companies or cooperatives with at least €155,000 of fully paid-up capital net of losses. It also says a channel-name change would need ministry approval, which can take up to 30 days, rather than a simple notification.
The strongest case for the rules
The regulatory logic deserves a fair hearing. The LCN list is scarce public real estate, and viewers rely on it. If a broadcaster could sell its channel slot to anyone who can stream, the numbering plan would become a marketplace and the capacity-brokering ban would be hollow. An explicit viewer action before leaving the broadcast signal protects consumers from being silently pushed onto data-metered or advertising-heavy streams, and protects the prominence of public-interest services. Capital floors, similarly, are a conventional way to screen out thinly funded licensees. On this reading, the draft is careful housekeeping.
Where the draft gets it right
The core decision, letting a DTT licence extend to IP delivery of the same authorised schedule, is the proportionate one. It does not require a second licensing process for something a broadcaster already editorially controls, and it lets Italian terrestrial TV compete with streaming-native services on features such as catch-up and restart without breaking the platform. It also builds on AGCOM's own groundwork. In resolution 138/25/CONS of 27 May 2025 the regulator opened a fact-finding on HbbTV, noting that these applications are not pre-installed on the television. They are downloaded via information carried on the DTT multiplexes, and the IP content is reached through a call-to-action. Contributors included RAI, Reti Televisive Italiane, Persidera, Aeranti-Corallo, the Italian internet provider association AIIP, Confindustria Radio Televisioni and the HbbTV Association. AGCOM closed the inquiry with resolution 292/25/CONS on 3 December 2025. A consultation that follows a documented inquiry is a better process than rule-making by assumption.
Where the evidence is thinner
The second-tier rules are where proportionality is not yet demonstrated. Three questions stand out for respondents.
- Secondary authorisations for third-party hosting. The reported draft would require them but, as described, it does not say what harm a lighter notification regime would fail to prevent. Authorisation adds delay for small local broadcasters whose economics depend on carrying partner content. A clear, objective test separating lawful hosting from capacity brokering would serve better than a permission gate.
- The LCN carve-outs. Pushing third-party IP schedules into 650–699 and 950–999 may keep the main numbering plan clean, but it also relegates hosted services to remote channel numbers where viewers rarely browse. The consultation should ask for data on viewing of those ranges rather than assume neutrality.
- Capital and renaming rules. A €155,000 fully paid-up floor and a ministry approval of up to 30 days for a name change are fixed burdens that fall hardest on small operators. Channel names are an editorial and brand matter. Unless AGCOM can show consumer confusion that a notification would not solve, the approval step looks heavier than the problem.
Why this is not a platform-liability story
The topic label may suggest the Digital Services Act, but nothing in the reported draft concerns intermediary liability or content moderation. It sits in audiovisual media regulation, the field shaped by Directive (EU) 2018/1808, which amended the Audiovisual Media Services Directive and which Italy implemented through legislative decree 208/2021, cited in AGCOM's own resolutions. The distinction matters because the draft's real risk is not over-moderation. It is that licensing categories written for broadcast could quietly be stretched over every internet-delivered service that touches a TV set.
What respondents should press for
The consultation closes on 18 December, and three asks are practical. First, publish the evidence behind each secondary authorisation and LCN range. Second, define "interactive hosting" by function so that lawful app features are not treated as brokered capacity. Third, keep the explicit-action rule but make it technology-neutral, so it does not freeze today's remote-control interaction into the licence. Hybrid television is a genuine chance for Italian broadcasters to modernise. The licence extension should be kept as drafted, and the add-on gates should have to earn their place with data.