Other measures, such as behavioural remedies or making Sky reduce its shareholding to 9.9%, would not be effective, ITV argues.
Making Sky reduce its shareholding to 4.9% would at least begin to address its concerns, it added, if the commission decided on a partial divestment.
ITV's submission was a response to the Competition Commission's provisional findings that Sky's acquisition of the stake last November did lessen competition in the media sector and that it was considering a range of actions, including forcing Sky to dispose of its entire shareholding.
Although BSkyB's stake is below the 20% limit allowed by the Communications Act, the commission said there was motivation and opportunity for the pay-TV group to weaken ITV.
Sky's own response was to offer to hand over a fifth of its voting rights to an independent trustee, leaving it in direct control of 14.9% of ITV shares.
Earlier this week, it was reported that Apax, the private equity firm, was considering making a third takeover approach to ITV.
The broadcaster's current share price is 94.5p, meaning that if Sky were to sell its shareholding today it would get a £658m return on its £940m investment.
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