SEPTEMBER 30, 2025

Normative alert: New General Regulation of the Universal Service

CIRCULARS

TMT (Telecoms, Media, Technology) Department Report | Normative alert: New General Regulation of the Universal Service.

Dear all,

On September 22, 2025, the National Communications Agency (“ENACOM”) published Resolution No. 1182/2025 (the “Resolution”, available only in Spanish here) in the Official Gazette, introducing a new General Regulation of the Universal Service (the “New Regulation”) pursuant to Article 18 of Law No. 27,078 on ICT Services (the “ICT Law”). Accordingly, the Resolution repeals previous versions of the aforementioned regulation, which had been enacted through ENACOM Resolutions No. 2642/2016 and 721/2020, respectively.

Among the main innovations of the New Regulation is the introduction of the so-called “Universal Service Contribution Credit Certificate.” Those who carry out Universal Service projects—according to the programs listed in Article 16 of the New Regulation—may use these certificates, in whole or in part, to offset the mandatory monthly 1% contribution that information and communication technology service (“ICT Services”) licensees must pay under Article 22 of the ICT Law.

Regarding projects, the New Regulation sets a 45-day (forty-five) period for filing objections to projects and a maximum of 60 (sixty) days for the review of project reports. Additionally, the minimum investment amount for each project will be defined in each program, thereby eliminating the previous fixed minimum of 100 Minimum, Vital and Mobile Salaries.

The New Regulation also stands out for expanding the scope of Universal Service programs.  Such new programs are related to the following areas: the optimization or expansion of last-mile networks; the promotion of infrastructure investments in areas without coverage; the development of provincial integration in ICT Services; the development of a neutral wholesale network; the promotion of mobile access networks in areas without coverage; the promotion of distribution and/or access networks in areas where implementation is difficult or costs are excessive; and the promotion of data center developments and their integration with artificial intelligence.

The Resolution established that the New Regulation came into force on the same day it was published in the Official Gazette.

We remain at your disposal for any information you may consider necessary.

Yours sincerely,

Emilio Beccar Varela

Florencia Rosati

Franco Blanklejder