*by Fulvio Sarzana di S.Ippolito, Lawyer, Sarzana and Partners Law Firm. Sarzana Law Firm and Associates
On Digital Agenda An article by Fulvio Sarzana on the 26 GHz tender has been published. The piece is an operational guide for telecommunications companies evaluating whether to participate. On August 26, 2026, the Ministry published in Official Journal the call for tenders for the 24.25-26.5 GHz band. Applications must be submitted by September 25, 2026. This means there is less than a month to decide whether to compete, with whom, and for which lots.
What is at stake in the 26 GHz race?
The band covers a total of 2.25 GHz, divided into seven 200 MHz blocks. The structure includes up to five national lots and up to 42 regional lots, distributed across 19 regions and the two autonomous provinces. Usage rights begin January 1, 2029, and last for 15 years. They can be extended for another five years and renewed once for a maximum of 10 years.
The specifications also allow early access to bandwidth for ultra-broadband systems, before the formal effective date. This should be reviewed on a case-by-case basis with your technical advisors, as it may impact your investment plans.
Who can participate and under what conditions?
Half of the lots are reserved for incumbent WLL operators, i.e., holders of usage rights already in existence as of December 31, 2022. The reserve covers national lots L3 and L4 and regional lots L1.1-L1.21. For these companies, the priority is to immediately verify their incumbency and the documentary consistency of existing rights. The specifications introduce controls on corporate control chains to prevent reserves from ending up in the hands of parties connected to outgoing holders.
Incumbents and new entrants compete together for the remaining lots. Those entering this segment for the first time must expect more time for due diligence: verification of admission requirements, preparation of financial guarantees, and assessment of the required technical coverage.
26 GHz tender deadlines
Three dates mark the procedure. Applications are due on September 25, 2026. The award is expected by the end of 2026. The assigned rights begin on January 1, 2029.
Approximately two years pass between the awarding of the contract and the start of operations. Companies should use this timeframe to plan network investments. The specifications require the network to be installed within 36 months of the frequencies becoming available and commercial service to be activated in all provinces within the assigned area.
How to prepare for the 26 GHz competition
The article outlines three concrete steps for the coming weeks.
- Map the lots of interest, whether national or regional, by cross-referencing existing network coverage, previous WLL presence, and expansion plans. The choice between national and regional lots changes the economic risk profile.
- Check technical compatibility with incumbent services in your area. The specifications establish a bandwidth-sharing model in Annex 3 and an incumbent protection plan in Annex 4, which may include geographic exclusion zones.
- Prepare the annual reporting plan for the Ministry and AGCOM now. Failure to comply with the installation and activation requirements will result in forfeiture of the award, but will not exempt the company from paying the final bid amount.
The issues still open
Two issues remain to be monitored until the auction is awarded. The first is the final price level: lower starting prices than in 2018 do not guarantee low final prices if demand for national lots is high. The second is the technical management of bandwidth sharing with incumbents, which will depend on the exclusion zones applied province by province.
For a 26 GHz tender with such tight deadlines, companies should closely monitor the FAQs and clarifications that the Ministry will publish in the coming weeks. A late clarification on a technical point may arrive after the application has already been submitted.
For the complete picture, please refer to’article on Digital Agenda. On this topic, see also the in-depth study in the Study on the 26 GHz tender notice.
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