Platform terms and policies - direct legal advice from Bratby Law

Need advice before launching or changing a telecoms product?

Rob Bratby, Managing Partner
Last updated: March 2026

A telecoms product launch requires specialist regulatory advice. You are launching a new telecoms service, expanding into a new product area, or making a network change that engages regulatory obligations you have not previously had to manage. Before you go live, you need to confirm that your product complies with the General Conditions, that you hold the right numbering allocations, that your spectrum position is correct and that your security obligations under the TSA 2021 are met. We advise on defined matters at the point of product launch, change or network expansion.

What General Conditions compliance do we need for a new telecoms service?

Any provider of electronic communications services or networks in the UK must comply with the General Conditions of Entitlement set by Ofcom under the Communications Act 2003. The specific conditions that apply depend on the services you provide. For example, if you provide telephone services you must comply with conditions on number portability, access to emergency services, and billing transparency. We identify which General Conditions apply to your proposed service and advise on the practical steps needed for compliance before launch.

Do we need a numbering allocation from Ofcom before launching?

If your service requires telephone numbers, you will need to apply to Ofcom for a numbering allocation under the National Telephone Numbering Plan. The application process typically takes 3 to 8 weeks depending on the number range requested. We advise on which number ranges are appropriate for your service, prepare the application, and manage the process with Ofcom. If you are an MVNO, you may use numbers allocated to your host network operator rather than obtaining your own allocation.

How early should we involve a telecoms lawyer in a product launch?

Regulatory areas affecting a telecoms product launch

Planning to launch or change a telecoms product and need to understand the regulatory requirements before you commit to build? We advise on the General Conditions compliance, licence conditions, numbering, security duties and compliance obligations that must be in place before service launch.

For services involving payments or billing, there may be overlap with payments regulation where the service processes transactions. Switching obligations under the One Touch Switch regime must be built into customer-facing processes before launch. Providers offering bundled services should also consider whether their commercial arrangements require review under commercial contract frameworks applicable to the sector.

Early regulatory mapping for a telecoms product launch reduces the risk of enforcement action post-launch. Ofcom has increased its supervisory activity under the TSA 2021 framework, and new entrants are subject to the same compliance expectations as established operators. A structured compliance assessment before launch is the most cost-effective approach to managing regulatory risk.

Ideally, at the product design stage. Regulatory requirements can affect fundamental aspects of the product, including which customers you can serve, what information you must provide, and what systems you need in place. Engaging a telecoms lawyer early avoids the cost of redesigning a product to meet regulatory requirements after development is complete. For services that cross the telecoms and payments boundary, early assessment of the regulatory perimeter is particularly important.

Who telecoms product launch advice is for

Product and regulatory teams at telecoms operators preparing to launch a new service or enter a new market segment. Infrastructure providers planning a network build that requires Electronic Communications Code rights. Operators launching a service that requires new numbering allocations from Ofcom. MVNOs and MVNEs confirming their regulatory position before commercial launch. Businesses adding voice, messaging or connectivity features that may trigger General Conditions obligations.

Typical triggers

  • A business is launching an internet access service and needs to understand the net neutrality and transparency requirements under the Open Internet Regulation
  • A new communications provider needs a numbering allocation from Ofcom and advice on the application process and timeline
  • A product that combines telecoms and payments features needs a perimeter assessment to determine which regulatory regimes apply before launch

What we deliver for a telecoms product launch

Launching a new telecoms service involves technology licensing and IP clearance alongside regulatory compliance. We review software component dependencies, third-party licence obligations and IP ownership for bespoke service platforms, ensuring that the technology stack is properly licensed before commercial launch. This includes proprietary code, licensed components and open source dependencies.

  • Technology licensing audit: review of third-party IP clearance, licence terms and restrictions affecting service deployment
  • Software component audit: mapping proprietary code, licensed components and open source dependencies in the technology stack
  • IP rights in bespoke platforms: ownership clarity for custom network configurations and service-specific technical platforms
  • Open source compliance: managing licence obligations (GPL, Apache, MIT) for open source components in telecoms infrastructure
  • Launch-readiness memo: confirmation that the proposed service complies with the applicable General Conditions and any sector-specific obligations
  • Numbering application advice: guidance on Ofcom numbering applications, allocation conditions and number portability obligations
  • Code Powers assessment: advice on Electronic Communications Code rights for a specific infrastructure project
  • TSA 2021 compliance note: assessment of telecoms security obligations for a new service or network change
  • Regulatory sign-off note: a board paper confirming the regulatory position of a new or changed telecoms product
  • Numbering and porting assessment: where the product requires number allocations from Ofcom or involves number portability, advice on the application process, General Conditions obligations and implementation requirements
  • Interconnection and access strategy: where the product requires interconnection with other operators or access to third-party infrastructure, advice on the regulatory framework, commercial terms and negotiation approach

If you are launching a telecoms product and need regulatory and commercial advice, we can usually start within days of instruction. See all our direct legal advice services or get in touch.

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Representative experience

Recent and representative matters include:

  • Advised on the regulatory requirements for launching a fixed wireless access service, mapping the full pathway from General Conditions compliance through spectrum licensing to General Conditions compliance before the build phase commenced.
  • Supported the launch of a business VoIP platform, resolving number portability and emergency call obligations that the client had not identified in its original product specification.
  • Advised on regulatory requirements for a satellite-to-cellular service, identifying the interaction between General Conditions compliance and Wireless Telegraphy Act spectrum authorisation that required sequential rather than parallel applications.
  • Guided an IoT connectivity provider through the regulatory classification and notification process, confirming which individual services required separate notification and which could operate under an existing authorisation.
  • Advised on telecoms regulatory requirements for a smart building connectivity product, resolving the ECN classification question and identifying the in-building coverage obligations that applied.

Frequently asked questions

What are the General Conditions?

The General Conditions are Ofcom’s standing regulatory obligations for providers of electronic communications networks and services. They cover areas including numbering, switching, security, complaints handling and access. We advise on which conditions apply to a specific product. We work with your product and engineering teams to identify the regulatory requirements before you commit to a launch timeline, reducing the risk of delays or post-launch remediation.

How does this differ from ongoing fractional GC support?

This page is for defined, matter-specific instructions: a product launch, a numbering application, a Code Powers question. For ongoing embedded support, see the Fractional General Counsel pages. We work with your product and engineering teams to identify the regulatory requirements before you commit to a launch timeline, reducing the risk of delays or post-launch remediation.

How does this page differ from the Telecoms Regulation page?

The Telecoms Regulation page explains the regulatory framework. This page is for a live instruction where you have a specific product or service question that needs answering before launch. We work with your product and engineering teams to identify the regulatory requirements before you commit to a launch timeline, reducing the risk of delays or post-launch remediation.

We are launching an MVNO. What regulatory steps do we need to take?

An MVNO providing electronic communications services is subject to Ofcom’s General Conditions from the point it begins offering services. We advise on which General Conditions apply to your specific MVNO model, the commercial and regulatory terms of the host network agreement, and any numbering or porting requirements. See also our MVNOs and MVNEs transactions page for the deal side.

How early in the product development process should we engage regulatory advice?

Before committing to the technology build. Regulatory requirements can affect product design, commercial terms and go-to-market timing. A telecoms product launch assessment at the design stage identifies the applicable General Conditions obligations and any specific requirements (numbering, switching, security) before they become expensive to retrofit. We work with your product and engineering teams to identify the regulatory requirements before you commit to a launch timeline, reducing the risk of delays or post-launch remediation.

We are expanding our existing telecoms service into a new product area. Is that a new launch?

It depends on the product. Adding a new service category (for example, moving from fixed broadband to offering voice services) may bring additional General Conditions obligations and numbering requirements. We assess whether the expansion changes your regulatory position and advise on any additional compliance steps needed before the new product goes live.

Can you work alongside our technology and commercial teams during the product build?

Yes. For telecoms product launches, regulatory input is most effective when integrated with the product development process rather than delivered as a standalone legal opinion at the end. We work alongside product, technology and commercial teams to flag regulatory requirements as they arise during the build, reducing the risk of late-stage changes or compliance gaps at launch.

What regulatory steps are needed before launching a new telecoms service in the UK?

A UK telecoms provider must comply with Ofcom’s General Conditions of Entitlement from the date it begins providing the service. This includes compliance with the customer-facing General Conditions (contracts, complaints handling, switching), the security obligations under the Telecommunications (Security) Act 2021, and any numbering conditions if the service uses UK telephone numbers. If the service involves premium rate content, the Phone-paid Services Authority Code of Practice applies. We advise on the full regulatory checklist for a new telecoms service launch and work alongside your technology and commercial teams during the build phase.

Launching a regulated telecoms product?

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