Argentina Type Approval Delay: ENACOM Resolution 57/2026

Argentina's telecommunications regulator is widely expected to push the commencement of its new type approval regime into 2027 but nothing has been published, and manufacturers planning on that basis are exposed. As of 24 July 2026, 1 September 2026 remains the operative date in law.

What ENACOM Resolution 57/2026 Actually Requires

ENACOM Resolution 57/2026 (RESOL-2026-57-APN-ENACOM#JGM) was signed on 24 February 2026 and published in the Boletín Oficial on 26 February 2026, entering into force the following day under Article 17. It dismantles a homologation framework that had operated substantially unchanged since Resolution 729/80, replacing direct regulator issued approvals with a third-party conformity assessment model.

The resolution approves three new regulations as annexes: the Registry of Telecommunications Activities and Materials (RAMATEL) Regulation, the Regulation of the Registry of Certification Agencies for Telecommunications Materials, and the Regulation of the Registry of Telecommunications Materials Testing Laboratories. Article 4 creates the Certification Agency registry itself, sitting within ENACOM's National Directorate of Radio Spectrum Engineering and ICT Services.

Under the new model, accredited Certification Agencies not ENACOM issue the Certificates of Conformity required for RAMATEL registration, working from accredited laboratory test reports and applicant documentation. Those agencies must hold accreditation from the Organismo Argentino de Acreditación (OAA) under ISO/IEC 17065; laboratories must hold OAA accreditation under IRAM ISO/IEC 17025. Certification Agencies also take on post approval market surveillance duties, so their role does not end at certificate issuance.

Several structural changes are already commercially significant. Article 6 provides that registrations granted under the new regulations carry no expiry date, eliminating the renewal cycle. The RAMATEL Regulation introduces "Product Families," allowing multiple models sharing technical characteristics to be registered together. Article 10 requires that telecommunications materials offered through web portals display their assigned RAMATEL registration number an obligation falling on both the seller's own site and on intermediary marketplace operators. Article 8 confirms that only RAMATEL registered materials may be sold, leased, loaned, distributed or otherwise offered in Argentina.

Critically, Article 13 sets 1 September 2026 as the commencement date for the RAMATEL Regulation specifically. Until that date, registrations continue to be processed under Resolution 729/80. Article 16 repeals the legacy instruments Resolutions 763/78, 729/80, 4528/81, 519/83, 179/84, 549/84, 585/84, 66/85, 83/86, 107/87, 784/87, 11.153/99, 9/2001 and ENACOM 5424/19 with effect from that same date.

The Expected Delay: What Is Reported and What Is Documented

Industry reporting indicates that ENACOM is likely to postpone enforcement of the new scheme into 2027, with the regulator requiring additional time to complete its internal transition, and that an official statement setting a revised implementation date is anticipated before 1 September 2026.

The operational rationale is plausible on the face of the resolution itself. ENACOM's own recitals acknowledge that implementation requires building digital processes within the HERTZ system and that applicants themselves need time to adapt which is why a commencement delay was written into the instrument in the first place. Article 14 separately instructs ENACOM directorates to establish fee schedules for all three new registries by updating the Régimen de Derechos y Aranceles Radioeléctricos under Resolution 10/95. Article 11 requires coordination with the Secretaría de Industria y Comercio on marketplace enforcement. Neither workstream has a published completion date.

There is also a second, independent route by which the September date could fail to take effect. The professional council COPITEC filed an autonomous precautionary measure on 18 May 2026 seeking suspension of Resolution 57/2026 before it commences, and reported further progress in its nullity action on 20 July 2026. Its objections centre on the elimination of the matriculated technical representative, the transfer of public technical functions to private entities, and the scope of an interventor's authority to enact structural reform. A judicial suspension and a regulatory postponement would have different legal consequences, and manufacturers should not treat the two as interchangeable.

What This Means for Manufacturers

The September date is still the one that governs. Until an amending resolution appears in the Boletín Oficial, planning assumptions should be built around 1 September 2026. An expected delay is not a legal basis for deferring preparation, and a certificate strategy predicated on a postponement that does not arrive leaves products unable to be lawfully offered for sale.

A delay does not buy you time on the adaptation deadlines. This is the point most frequently misread. The three year clock on existing Registro de Materiales entries runs from publication 26 February 2026 not from commencement. Those registrations lapse automatically on 26 February 2029 if not brought into conformity with the new RAMATEL Regulation. Recognised laboratories have two years from the same date, to 26 February 2028. If commencement slips to 2027 without a corresponding amendment to Article 5, the practical window to migrate a portfolio narrows rather than widens.

Filing under the legacy route retains value. Applications processed under Resolution 729/80 before commencement receive a three year validity period under Article 13. For manufacturers with imminent launches, completing legacy filings ahead of the transition remains a defensible way to secure market access continuity provided the eventual re-registration obligation is scheduled rather than forgotten.

Certification body capacity is the real constraint. Article 7 allows organisations already OAA accredited to ISO/IEC 17065 for other product certification schemes to obtain provisional ENACOM recognition without holding telecommunications specific accreditation, but the application window runs only for one year from publication closing 26 February 2027 and provisional recognition lasts one year. If the scheme's commencement moves into 2027 while that window stays fixed, the pool of available agencies at go live could be materially thinner than the design anticipated. Manufacturers should be identifying and engaging a Certification Agency now rather than waiting for the revised date.

Marketplace listings are a separate compliance surface. The Article 10 obligation to publish RAMATEL numbers on e-commerce listings reaches importers, brand owners and platform operators alike, and Article 12 exposes non compliance to the general sanctions regime alongside Laws 22.802 and 24.240. Commercial and e-commerce teams, not only regulatory affairs, need to be briefed.

Certification Impact Summary

Area	Position under legacy regime	Position under Resolution 57/2026	Impact on manufacturers
Certificate issuer	ENACOM issues homologation directly	Accredited Certification Agency issues Certificate of Conformity; ENACOM registers	New commercial relationship required; agency selection becomes a critical path item
Certification body accreditation	Not applicable	OAA accreditation to ISO/IEC 17065 mandatory; provisional route under Art. 7	Limited agency pool at launch; early engagement advised
Laboratory status	Registro de Laboratorios Acreditados (Res. 700/96)	Renamed registry; OAA accreditation to IRAM ISO/IEC 17025; 2-year adaptation to 26 Feb 2028	Verify current lab retains eligibility through the transition
Registration validity	Renewal cycle applied	New registrations issued without expiry (Art. 6)	Removes recurring renewal cost after migration
Legacy registrations	Held under Res. 729/80	Valid 3 years from 26 Feb 2026; automatic cancellation if not adapted	Portfolio migration plan required before 26 Feb 2029
Activity registrations	Renewal required	Continue without renewal (Art. 5)	Administrative relief; no action needed
Model grouping	Model-by-model	Product Families permitted for shared technical characteristics	Potential cost reduction across variant ranges
E-commerce listings	No specific obligation	RAMATEL number must appear on listings (Art. 10)	Applies to own sites and intermediary platforms
Technical representative	Matriculated representative mandatory	Role eliminated	Under judicial challenge; monitor outcome
Market surveillance	ENACOM-led	Certification Agencies conduct post-approval surveillance	Ongoing conformity obligations extend beyond certificate issuance

Timeline and Required Actions

Date	Event	Status	Required action
24 Feb 2026	Resolution 57/2026 signed	Confirmed	—
26 Feb 2026	Published in Boletín Oficial	Confirmed	Reference date for all adaptation clocks
27 Feb 2026	Resolution in force (Art. 17); Res. 700/96 repealed (Art. 15)	Confirmed	Confirm laboratory status under renamed registry
18 May 2026	COPITEC precautionary measure filed seeking suspension	Confirmed	Monitor docket; do not assume suspension
20 Jul 2026	COPITEC reports advance in nullity action	Confirmed	Continue monitoring
Before 1 Sep 2026	ENACOM statement on revised implementation date	[VERIFY] Anticipated, not documented	Watch Boletín Oficial and enacom.gob.ar/normativas daily from mid-August
1 Sep 2026	RAMATEL Regulation commences (Art. 13); legacy instruments repealed (Art. 16)	Confirmed unless amended	Complete legacy filings before this date; have a Certification Agency engaged
26 Feb 2027	Article 7 provisional recognition window closes	Confirmed	Confirm your chosen agency has secured recognition
2027	Expected revised commencement date	Unconfirmed	Do not plan on this date until published
26 Feb 2028	Laboratory adaptation deadline (Art. 5)	Confirmed	Verify test lab holds IRAM ISO/IEC 17025 OAA accreditation
26 Feb 2029	Existing material registrations lapse automatically (Art. 5)	Confirmed	Complete portfolio migration to new RAMATEL requirements

Recommended Position

Treat 1 September 2026 as the planning date and any postponement as upside. Prioritise three actions in the next four weeks: close out legacy Resolution 729/80 filings for products launching before mid-2027; open discussions with OAA-accredited certification bodies pursuing ENACOM recognition; and build a migration schedule for the existing portfolio anchored to 26 February 2029 rather than to whatever commencement date is ultimately confirmed. Monitor the Boletín Oficial directly an amending resolution, if it comes, will appear there before it appears anywhere else.