Ofcom’s Plan of Work 2026/27: What It Means for Telecoms Investment and Transactions

ByRob Bratby Posted on Telecoms regulation, M&A, Ofcom, Transactions, UK
Ofcom Plan of Work 2026/27 telecoms investment and transactions Bratby Law telecoms regulation

Ofcom Plan of Work 2026/27, published in March 2026, sets out regulatory priorities for the year ahead. For operators, investors and dealmakers in the UK telecoms sector, this signals where Ofcom will direct its attention during a period of accelerating altnet consolidation, the final stages of the copper-to-fibre transition, and expanding security obligations under the Telecommunications (Security) Act 2021.

Regulatory background

The Plan of Work sits within Ofcom’s Three Year Plan 2025-2028, which organises its programme around four priorities: reliable internet and post, trusted media, safer life online, and enabling wireless connectivity. For telecoms, the most consequential strand is the first, under which Ofcom has grouped its work on fixed and mobile network regulation, network transitions and security.

Three recent developments frame the Ofcom Plan of Work 2026/27 programme. The Telecoms Access Review 2026-31, published in March 2026, establishes the regulatory framework for fixed access markets for the next five years. As we noted in our earlier analysis of the TAR, this review defines the SMP conditions governing Openreach’s physical infrastructure access, wholesale local access and business connectivity services. The Cyber Security and Resilience Bill will extend Ofcom’s security oversight to data centres and critical infrastructure. And the UK government’s consultation on competition regime reforms, launched in January 2026, signals a more permissive approach to telecoms consolidation, with the CMA’s revised merger remedies guidance now expressly recognising the role of behavioural remedies in regulated sectors.

Ofcom Plan of Work 2026: key areas

The Ofcom Plan of Work 2026 identifies five areas with direct relevance to telecoms regulation and transactions.

Security obligations and the TSA 2021 timeline. 2026 is a transitional year for TSA compliance. No new milestone falls due this year, but operators are expected to build privileged access management, SIEM/SOC capability and telecoms-grade monitoring in preparation for the March 2027 uplift, when controls must operate at scale. Ofcom will also prepare for new duties under the Cyber Security and Resilience Bill, which extends its cybersecurity oversight to data centres. For investors in UK telecoms assets, security compliance maturity is an increasingly material factor in valuation and risk assessment. Acquirers should treat TSA readiness as a core due diligence item, not an operational afterthought.

Copper retirement and network transitions. Ofcom will finalise the regulatory framework for copper retirement during 2026/27, retaining a three-stage approach that shifts regulatory protections from copper to fibre on an exchange-by-exchange basis. With the PSTN switch-off scheduled for January 2027, this is the final year in which legacy network arrangements must be unwound. The copper retirement programme principally affects BT and wholesale operators still running legacy services. For altnets, which are fibre-native, the transactions question is different: as copper customers migrate, the competitive window for customer acquisition narrows. Operators and investors need to assess how far any target’s business plan depends on capturing migrating copper customers before the transition completes.

Altnet consolidation and market structure. Ofcom has acknowledged that the UK fixed broadband market is more fragmented than anticipated when the fibre investment cycle began. The Ofcom Plan of Work 2026 stops short of endorsing consolidation but signals that Ofcom will monitor competitive dynamics as the market restructures. That monitoring role matters. Ofcom does not review mergers; that is the CMA’s jurisdiction. But Ofcom has concurrent competition powers under the Enterprise Act 2002, and the Vodafone/Three clearance in December 2024 demonstrated how Ofcom’s sectoral expertise now underpins the CMA’s willingness to accept behavioural remedies in telecoms mergers. The CMA accepted a GBP 11 billion network investment commitment alongside price caps and wholesale access protections, with Ofcom taking a direct role in monitoring compliance.

The nexfibre acquisition of Netomnia for GBP 2 billion, expected to complete by Q3 2026, will test this framework further, creating the largest independent fibre challenger to Openreach with a path to 20 million premises. CityFibre has called on the CMA to scrutinise the deal, warning of a return to an Openreach/VMO2 duopoly. The UK government’s pro-growth merger policy and the CMA’s revised merger remedies guidance, which took effect in December 2025, both point toward clearance with conditions rather than prohibition. The practical question for dealmakers is what those conditions will look like, and what role Ofcom will play in enforcing them.

Spectrum and satellite connectivity. Ofcom plans to set out its approach to authorisations in the 2 GHz MSS band, publish decisions on the upper 1.4 GHz band for mobile, and review demand for spectrum below 1 GHz. It will also progress direct-to-device satellite connectivity, with expected updates to mobile operator licence conditions. These spectrum decisions have direct implications for mobile network operators and for satellite ventures seeking UK market access.

AI and its impact on telecoms. Ofcom invited contributions on how AI could affect broadband, mobile and pay TV customer experience, with this work continuing into 2026/27. While the regulatory response to AI in telecoms remains at an early stage, operators should expect Ofcom to develop views on AI-driven network management, customer service automation and algorithmic pricing practices.

Commercial and operational implications

For PE investors and corporate acquirers, the Ofcom Plan of Work 2026 crystallises several due diligence priorities. Any target operator’s exposure to copper retirement timelines, TSA compliance costs and spectrum licence conditions should be assessed against the regulatory calendar Ofcom has now set out. The altnet consolidation cycle creates both acquisition opportunities and competitive risk: acquirers who move before the market stabilises may secure favourable valuations, but they also absorb integration risk at a moment when Ofcom’s regulatory framework is still bedding in.

For operators, the message is operational. The PSTN switch-off deadline is nine months away. TSA security controls must be functioning at scale by March 2027. Copper retirement is proceeding exchange by exchange. These are not future risks; they are current work programmes with defined regulatory consequences for non-compliance. Ofcom’s enforcement powers under sections 96A to 96C of the Communications Act 2003 and under the TSA 2021 give it the tools to act where operators fall short.

Network-sharing and wholesale access arrangements also merit attention. The TAR 2026-31 framework defines the terms on which competitors access Openreach’s physical infrastructure. Operators negotiating or renegotiating duct and pole access, dark fibre or wholesale fibre products will do so against the backdrop of Ofcom’s new SMP conditions for the next five years.

Viewpoint

Ofcom’s Plan of Work 2026/27 arrives at a point of convergence: the fibre build programme is entering its final phase, the legacy copper network is being retired, security obligations are escalating, and the altnet market is consolidating. For those advising on telecoms transactions, the regulatory calendar is no longer background context; it is a driver of deal structure, pricing and risk allocation. From my time at Oftel, when the focus was on infrastructure competition and cable companies were building the first alternative access networks while COLT was rolling out city fibre across European business districts, I recognise the pattern: regulatory frameworks designed to promote investment eventually shape the terms on which that investment changes hands. The altnets of 2026 face the same structural dynamics that the cable operators and competitive carriers faced in the early 2000s. The difference is that Ofcom now has a direct monitoring role in post-merger compliance, and the stakes in each transaction are considerably higher.

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For advice on how Ofcom’s 2026/27 priorities affect your telecoms investment, transaction or compliance programme, contact Rob Bratby at Bratby Law.

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