A fractional general counsel provides senior legal leadership on a retained part-time basis, giving organisations access to strategic, commercial and regulatory support without the cost of a full-time hire. This model is suited to businesses operating in regulated, technology-driven and infrastructure-heavy sectors where legal issues are continuous, multi-disciplinary and operationally material.

Bratby Law delivers embedded general counsel capability for operators, technology companies, platforms, investors and international groups. The service is led directly by Rob Bratby, drawing on more than thirty years’ experience across private practice, a secondment to Oftel and senior in-house roles.

How it works

We operate as part of your internal team, providing a predictable and senior point of contact for legal, commercial and regulatory matters. Engagements typically include:

• A retainer-based model with agreed monthly or quarterly time allocation.
• Attendance at board, executive or project meetings where required.
• Integration with internal workflows, product teams and operational processes.
• Prioritisation, planning and coordination of legal work across the business.
• Management of external counsel and specialist support.
• Periodic reporting to senior leadership on risk, compliance and strategic legal issues.

The model is flexible and scales as business requirements change. It can also provide interim cover during recruitment, transactions or organisational change.

What we deliver

The service provides general counsel capability across regulatory, commercial and corporate matters, including:

• Governance frameworks and board support.
• Regulatory interpretation and compliance (telecoms, data protection, payments and security regimes).
• Product, operational and commercial risk analysis.
• Contracting and commercial negotiation across telecoms, technology, payments and data.
• Data protection and governance frameworks, including for AI-enabled products and services.
• Support on transactions, due diligence and corporate initiatives.
• Coordination of external advisers and specialist input.
• Engagement with regulators, government and industry bodies where relevant.

Our approach is grounded in clear, practical advice aligned to commercial priorities, operational realities and senior-level decision-making.

What the appointment covers

A fractional general counsel appointment with Bratby Law covers the work an in-house general counsel handles day to day, not only the regulatory questions the firm is known for. That includes company secretarial work and board governance, non-contentious employment matters, intellectual property and brand protection, commercial contracts and supplier terms, and the coordination of specialist external advisors where a matter needs one. Regulatory advice on telecoms, data protection and payments is inside the same appointment rather than beside it.

In practice that means the minutes, registers and filings a company must keep under the Companies Act 2006 are kept; the written statement of particulars each new employee must receive is current; the assignment clauses that put a contractor’s code and designs in the company’s hands are in place before a product ships; and contentious employment matters, litigation and work outside England and Wales are referred to a specialist whom the general counsel instructs and supervises.

Sector appointments

The six engagement shapes above describe how an appointment is structured. Two sector pages describe what Bratby Law does for a particular kind of business, drawing on its current appointments. Fractional General Counsel for Communications Providers covers mobile distributors, resellers, network operators, voice and contact-centre platforms and the industry bodies operating between them, with the Core Communication Group and TelXL appointments as worked examples. Fintech and Payments Fractional GC covers payment institutions, e-money institutions and fintechs.

Our Practice Areas

• Telecoms Regulation
• Data Protection
• Transactions
• Payments Regulation
• Digital Regulation
• Specialist UK telecoms, data protection and payments regulation lawyers

Other client engagement models

• Specialist Co-counsel
• Direct Legal Advice

Independent directory rankings

Our specialist expertise is recognised in major independent legal directories:

• Chambers & Partners: Rob Bratby is ranked as a Band 2 lawyer in the UK Guide 2026 in the “Telecommunications” category: Chambers
• The Legal 500: Rob Bratby is listed as a Leading Partner for Telecoms in London (TMT: IT and Telecoms). The Legal 500
• Lexology: Rob Bratby is recognised in the Lexology Index as a Global Elite Thought Leader for telecoms and media, and as a Thought Leader for data privacy and protection: Lexology

Current appointments

Bratby Law holds four fractional general counsel appointments. Two are communications providers with published case studies and two are industry bodies.

Core Communication Holdings Limited is a UK mobile distribution and communications group. The appointment covers the group’s commercial contracts with all major UK mobile network operators, compliance with the General Conditions and numbering obligations, data protection for the Amigo eSIM product, corporate structuring, acquisitions and disposals, company secretarial support and board advice. The Core Communication Group case study sets out the engagement in full.

TelXL Limited is a UK contact centre technology company. The appointment covers channel partner and reseller agreements, SaaS and enterprise contracts, data protection for AI-enabled products including conversation intelligence and sentiment analysis, compliance with the General Conditions, corporate transactions, dispute management, company secretarial support and board advice. The TelXL case study sets out the engagement in full.

Bratby Law is also general counsel to The One Touch Switching Company (TOTSCo), the industry body operating the cross-platform switching service mandated by Ofcom, where the appointment covers the legal and regulatory framework for the switching service, and to UK Payments Initiative Limited (UKPI), a multi-operator payments industry body, where it covers governance, regulatory engagement and commercial agreements.

Frequently asked questions

What is a fractional general counsel?

A fractional general counsel provides senior legal leadership on a retained or part-time basis. The role mirrors the function of an in-house general counsel but operates flexibly, giving organisations access to strategic legal, regulatory and governance advice without maintaining full-time headcount.

How does a fractional general counsel differ from a traditional law firm?

A fractional general counsel operates as part of the management team, working continuously with the business and supporting decision-making, governance and operational delivery. A law firm typically provides matter-specific external advice. The fractional model therefore combines in-house proximity with specialist external expertise.

Which organisations benefit most from a fractional general counsel?

The model suits businesses that encounter ongoing legal and regulatory issues but do not require, or do not yet have, a full-time general counsel. This includes operators, technology companies, scale-ups, joint ventures and overseas groups needing a UK legal presence. It is also effective during periods of transformation, restructuring or regulatory scrutiny.

What responsibilities does a fractional general counsel typically take on?

Responsibilities commonly include governance and board support, regulatory interpretation, commercial contracting, product review, data and AI governance, operational legal risk oversight, and coordination of external advisers. The general counsel tells the board what the position is and how it was reached.

Does a fractional general counsel handle company secretarial work?

Yes. Minutes, registers, filings and board papers are part of the appointment, as they would be for an in-house general counsel. A private company need not appoint a company secretary (section 270 of the Companies Act 2006), but it must keep minutes and registers, and the fractional general counsel does that work or supervises whoever does.

How flexible is the engagement model?

We scope engagements to business requirements, ranging from a fixed retainer for ongoing support to interim appointments during recruitment, transactions or organisational change. Time commitments can increase or reduce as operational demands shift.

Does a fractional general counsel replace external law firms?

No. A fractional general counsel determines when specialist external advice is required and manages that engagement. The model provides senior leadership and continuity, ensuring external support is used efficiently and aligned with business priorities.

What are the advantages of using a fractional general counsel?

Advantages include senior legal input at predictable cost, immediate access to regulatory and commercial expertise, improved coordination of legal work, and continuity across board, product and operational matters. It enables organisations to maintain high-quality legal oversight without building a full in-house team.

How quickly can support begin?

Engagements can typically begin at short notice. Following an initial assessment of requirements, support can start immediately or be aligned with a specific project timetable.

How is confidentiality managed?

Fractional general counsel engagements are conducted to the same professional standards as in-house and private practice roles. All work is performed under professional duties of confidentiality and, where required, under additional contractual confidentiality obligations.

How can Bratby Law be appointed as fractional general counsel?

You can contact the firm via the website to arrange a confidential discussion. We assess your operational and legal requirements and propose an engagement plan aligned with your governance, regulatory and commercial priorities.

See our Core Communication and TelXL case studies for examples of how the fractional general counsel model works in practice.