Insights
Analysis of telecoms, data, payments and technology regulation and transactions
Clear, practical commentary on legal and regulatory developments affecting telecoms operators, digital infrastructure providers, technology companies, financial institutions, fintechs and investors.
Our blogging history
We have been publishing insights since 2010, when Rob first built the website on WordPress. From the outset, the aim was the same: careful research, precise language and analysis that explains not just the legal issue, but its practical and commercial effect.
That remains our approach today. Artificial intelligence now helps with parts of the research and drafting process, and it has supported the development of this website. But technology does not replace judgement, experience or specialist expertise. Our insights are shaped by real advisory work across regulation, compliance and transactions.
Through this Insights section, Bratby Law aims to provide clear analysis that helps organisations make informed decisions in complex and fast-moving areas of law and regulation. For advice on a specific issue, regulatory strategy or a transaction, please get in touch.
Recent articles
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Altnet PIA: the Framework, the Coalition and TAR 2026-31
In short: Altnet PIA, the Openreach product that lets operators build using its ducts and poles, is not new. It has been a regulated wholesale input since 2010, and the Electronic Communications Code requires operators to consider sharing apparatus more broadly. Two recent moves progress those arrangements. INCA’s Infrastructure Sharing Framework formalises operator-to-operator duct, pole…
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DMCCA Part 3 enforcement: the CMA’s first consumer reviews investigations and their implications for transactions
The CMA’s coordinated push against fake and misleading consumer reviews lands the new Part 3 direct enforcement powers in the DMCCA 2024 on the consumer reviews supply chain. Five cases opened on 27 March 2026 reach across that supply chain at the same time and signal that consumer review compliance is now a discrete deal due diligence item.
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CityFibre, nexfibre and the local market definition question
CityFibre’s intervention in the CMA’s nexfibre/Substantial inquiry turns on local market definition. Why that question shapes Phase 2 risk and the altnet consolidation pipeline.
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ICO enquiry into Meta AI smart glasses: what it tells AI product teams about outsourced human review
In short: The ICO wrote to Meta in March 2026 over outsourced human review of audio-visual data captured by Ray-Ban Meta smart glasses. The enquiry tests controller/processor allocation under UK GDPR Article 28, lawful basis for AI training data, and whether the DUAA 2025 “meaningful human involvement” standard is met where reviewers validate AI outputs…
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UK AI regulation: the practitioner framework
In short: There is no UK AI Act. UK AI regulation sits on the UK GDPR (as amended by the Data (Use and Access) Act 2025, in force 5 February 2026), sector regulators applying their existing rules (ICO, Ofcom, FCA), and DSIT policy direction. For clients with EU exposure the EU AI Act applies in…
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UK Compute Roadmap and data protection: AI infrastructure obligations
DSIT’s Compute Roadmap envisages £2bn of UK AI compute investment by 2030. The data protection regime that attaches to organisations building, procuring or operating that infrastructure is not in the Roadmap. This post sets out the four obligations under UK GDPR and DUAA 2025: DPIA, automated decision-making, international transfers, and Article 28 processor agreements.
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First DMCCA 2024 commitments: Apple, Google and platform regulation in practice
In short: The CMA has accepted the first voluntary commitments under the Digital Markets, Competition and Consumers Act 2024, from Apple and Google in respect of aspects of their UK mobile platforms. The commitments cover app review, app ranking, data use and iOS interoperability. They are legally binding and signal how the new digital markets…
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nexfibre/Substantial CMA inquiry: what it signals for UK fibre M&A
In short: The CMA opened its invitation to comment on the £2 billion nexfibre/Substantial transaction on 23 April 2026. The case is in pre-notification; the statutory 40-working-day Phase 1 clock has not started. The deal is publicly targeted at Q3 2026 completion; that timeline carries real Phase 2 risk, and mandatory NSI Act 2021 notification…
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AI in legal practice: what I tried, what broke, and what I built
After a year of testing frontier AI models and legal-specific platforms, the problem was not capability but structure. A law firm cannot be built around a model. It needs a method in which AI operates under controlled, auditable workflows, with the lawyer as the final gate.
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Frontier AI cyber risk and the TSA 2021: Ofcom’s open letter to Communications Providers
In short: Ofcom has written to UK Communications Providers on 21 April 2026 to assess cyber risks from frontier AI, citing the AI Security Institute’s evaluation of Claude Mythos Preview. The duties already sit in section 105A of the Communications Act 2003 and the Telecommunications (Security) Act 2021 framework. CPs must now document assessment of…
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Upper 6 GHz Spectrum: Ofcom’s High-Density Area Consultation
Ofcom’s consultation on how high-density areas are defined for Upper 6 GHz (6425-7125 MHz) subnational mobile licences closes on 6 July 2026. What MNOs and enterprise campus operators must know.
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Merchant interchange fees: CAT Trial 2 pass-on findings and the PSR cross-border cap judicial reviews
Competition Appeal Tribunal [2026] CAT 11 Trial 2 pass-on findings and the Administrative Court ruling in [2026] EWHC 64 (Admin) on the Payment Systems Regulator’s power under section 54 FSBRA 2013 to cap cross-border interchange fees.
Telecoms, data protection and payments regulation lawyers
Bratby Law advises on telecoms regulation, data protection, payments regulation and transactions across the communications, financial services and technology sectors.
How we work
Bratby Law works with clients in three ways: as direct legal advisors on specific matters, as specialist co-counsel supporting other legal teams, and as fractional general counsel on a longer-term retained basis. Each model delivers partner-level input without delegation.
Why Choose Bratby Law?
Sector expertise
Bratby Law advises exclusively on telecoms regulation, data protection, and payments regulation. That concentration means deeper knowledge of the regulatory environment, faster analysis, and advice that reflects how regulators actually behave: not how the textbook says they should.
Senior delivery
Every instruction is handled by Rob Bratby personally. With 30 years’ experience spanning Oftel, senior in-house roles at network operators, and partnership at international law firms, you receive the analysis directly: not through a junior team. The firm uses AI tools to extend research capacity and accelerate document review, so senior judgment is applied to more of your matter, not less.
Unique perspective
Rob Bratby has sat on all three sides of the regulatory table: as a regulator at Oftel, as General Counsel at major operators, and as external counsel. That inside-out perspective informs every piece of advice. He currently holds fractional General Counsel appointments at TOTSCo, UKPI, TelXL, and Core.
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