Italy’s public opt-out register: what anyone calling Italy must do

What the register is

The public opt-out register (Registro pubblico delle opposizioni, RPO) is Italy’s do-not-call list: it holds the numbers of people who do not want calls for advertising, direct sales, market research or commercial communications. It stems from Article 130 of the Italian Personal Data Protection Code; Law no. 5 of 11 January 2018 and Decree of the President of the Republic (DPR) no. 26 of 27 January 2022 extended it to all Italian numbers.

The register belongs to the Ministry of Enterprises and Made in Italy (MIMIT), which has entrusted its management to the Fondazione Ugo Bordoni; the Italian Data Protection Authority (the Garante) supervises it. Since 27 July 2022 it has also covered mobiles.

Which numbers it covers

All national numbers, landline and mobile, whether or not they are in public telephone directories. The line holder registers on the register’s website, by phone or by email. Registration never expires and covers calls by a person and automated calls alike.

For callers, registration has two effects:

• it revokes all past consents to sales calls, given to anyone, and bans the use of numbers passed to third parties on the strength of those consents;
• it leaves valid consents given after registration and those tied to a contract that is ongoing or ended no more than thirty days ago.

Watch out: an unregistered number is not free to call. Without consent, and only with a human agent, you may call only unregistered numbers listed in public telephone directories; for the others, mobiles included, you need consent.

What callers must do

The duty falls on the data controller, whoever decides the campaign and owns the lists, who must:

• register with the RPO as an operator, listing every external call centre that actually makes the calls; a call centre that owns the lists registers itself;
• check the register every month and in any case before every campaign: the register replies to the list within 24 hours, flagging registered numbers, and the reply is valid for fifteen days;
• tell the person called where their number came from and how to join the register;
• always present the calling number, as explained in the guide to the 0843 and 0844 prefixes.

You need not check the register to call your own customers under an ongoing contract, or people who asked to be called. When a list changes hands, both sides check it. And diallers that search for numbers automatically are banned.

If you call from abroad

The register covers all Italian numbers: for this reason, the official website says, its scope ‘includes calls from abroad’. Numbers to be checked are sent without the international dialling code.

If the call centre is in a country outside the European Union, Decree-Law no. 83 of 22 June 2012 (Article 24-bis) adds, among others, these rules:

• whoever locates call-centre work there, including through outsourcing, must notify the competent ministries and the Garante at least thirty days in advance, stating how it complies with, among other things, the register;
• the person called must first be told which country the agent is in, and that they can ask for an agent in Italy or the European Union; the fine is €50,000 for each day of violation;
• a violation can be notified to the foreign call centre through the company that outsources the calls to it.

What you risk

Ignoring the register breaches the right to object. The fines are those of the General Data Protection Regulation (GDPR): up to €20 million or, for a company, up to 4% of total worldwide annual turnover in the previous financial year, whichever is higher. For repeated breaches, on a report from the Garante, the authorisation to operate can be suspended or revoked. And the controller is jointly and severally liable even when calls are outsourced to a call centre.

Three recent decisions by the Garante:

• 13 March 2025 (decision no. 157): checking the register is a ‘pre-condition’ of telemarketing, and without it no campaign may start; an indemnity clause does not exempt the controller from showing that it processes data lawfully;
• 21 March 2025 (newsletter no. 533): consent collected with generic wording, which does not let people choose the type of offers, does not cancel the effects of registration;
• 23 July 2026 (decision no. 556): €9,516,000 against a company on whose behalf rogue call centres, disguising the calling number, often called registered numbers. Signing up to a code of conduct, the Garante reiterated, does not exempt anyone from overseeing their partners.

The Code of conduct for telemarketing and teleselling activities was approved by the Garante, in its final version, on 7 March 2024 (Official Journal of 27 March 2024). It applies to those who sign up to it, including from abroad.

With Mercurion

We activate 0843 and 0844 numbers, and other Italian numbers, through a partner carrier. Outbound calls run on CLI routes (Calling Line Identification): the person who answers sees the number you chose. Before opening traffic we check with you which country you call from, with which numbers and over which routes.