The organisation detailed its concerns in a statement to the Commission, which is currently investigating Sky's £1 billion swoop on ITV shares last November.
It is also concerned about the effect the size of the combined broadcasters would have on the commercial sales market, and about informal sharing of commercial information between Sky and ITV.
Jim Marshall, the chairman of Starcom and the IPA Media Futures president, said: "ITV and Sky will continue to be hugely influential and dominant players in terms of content and commercial viewing. Any combining of commercial sales would be dangerously anti-competitive, and should not be allowed under any circumstances."
He added: "If the deal goes ahead, we want a clear statement that Sky and ITV cannot combine sales operations. We want to see restrictions that will stop this and a mechanism whereby this can be tracked and regulated. If it were to occur, Sky should be forced to divest itself of its stake."
The Competition Commission was first called upon to investigate the deal in April.