Frank reached out to me to ask for some feedback on the question of taking folks on a tour in Italy. 10+ years ago, I lived in Rome for a few years and learned about the requirements of guiding. Today, I am a travel advisor working for an American company, so I've seen all sides of this question.
From the travel perspective, a "tour director/coordinator" is far different from a guide. As an American-based company, we very infrequently work with guides directly. Rather, we work with coordinators - often called DMC's (Destination Management Companies). We do this worldwide - including Italy - and most of our DMC partners are located in-country (although not all). There are different rules/regulations for every country and a DMC has the local knowledge, expertise, and resources to best coordinate the design and implementation of events, activities, tours, transportation, and trip logistics. They also have great "buying" power with their local connections and lower cost contract-hotel-pricing (room prices we could not get independently). When we work with guides, and we want the best guides - often specific guides - we coordinate these arrangements through DMC's.
There are some travel advisors who DO take their clients on trips all around the world - including Italy. They are not licensed guides, nor is their company "licensed" in Italy. Yet, they are licensed and insured through their American company (required for travel advisors). I myself carry a $5 million professional liability errors and omissions insurance policy. The travel advisor, working independently - or through a DMC - coordinates the hotels, transfers, trains, restaurant reservations, etc.
But when it comes to the tour segment of their trip, the travel advisor HIRES A LOCAL GUIDE - either through a DMC or independently. The interpretation of "touring" vs. "guiding" is different in every country (probably every municipality!). And there is nothing worse than your tour - or your trip - being interrupted by a legal issue such as this. Thus, reputable travel advisors only work with local, licensed, and vetted guides - certified in the country, district, or city where their clients are touring. The liability and trip interruption is too much of a risk.
So back to the original question: Could a person combine their love of Italy and photography to coordinate tours in Italy?
I suppose you could, but I have to admit, doing groups is TOUGH. Group travel has been likened to "herding cats" and that's a pretty good analogy. Legally, you could bring them over - you could coordinate the air, the transfers, the trains, the hotels... but when you get out into a city... Is that a tour?
Once you start providing that touring-level-of-service, you are stepping on toes. And in Italy, the folks who will follow up on you - and point you out to the authorities - will be the guides (or the local, licensed photographers). They take this as a personal affront because IT IS HARD to get that guide certification, that local license. (A mastering of the Italian language comes in handy here!).
Because there are travel advisors or academia who bring groups of travelers to foreign lands, yes I think all that trip logistics can be done. But if you start "guiding" (and again, what is "guiding" is open to LOCAL interpretation), then you've crossed the line. Not sure if that answers the question posed... and there are far more parts to this regarding BUILDING the trip... but you can certainly bring a group over. It's what you do with them when they're in-country that will determine your viability or liability.