A fractional general counsel for telecoms is a senior lawyer who knows the sector, retained part-time to do the legal work a communications provider generates every week: operator and channel contracts, compliance with the General Conditions, numbering, security duties, data protection for consumer and AI-enabled products, corporate transactions and the board’s own governance. Bratby Law holds four such appointments. Two are communications providers with published case studies, Core Communication Group and TelXL Limited, and two are industry bodies. Rob Bratby does the work himself. He has practised for thirty years at leading UK and US City law firms and was seconded to Oftel.

Who this is for

Mobile distributors, MVNOs and resellers hold commercial agreements with the mobile network operators on one side and with retailers, wholesale partners and end customers on the other. Each agreement carries regulatory consequences: a provider of an electronic communications service must comply with the General Conditions of Entitlement that Ofcom sets under section 45 of the Communications Act 2003, and a provider that adopts telephone numbers takes on the numbering obligations that follow from the National Telephone Numbering Plan under section 56. The general counsel reads the MNO contract and the General Conditions together, because the gaps open up between the two.

Internet service providers, altnets and wholesale network operators are subject to a wide range of regulatory obligations. A provider of a public electronic communications network or service must take appropriate and proportionate security measures under section 105A of the Communications Act 2003, inserted by the Telecommunications (Security) Act 2021, and the security regime applies to supply-chain contracts as well as to the network itself. Network build brings Code Powers, wayleaves and wholesale access agreements. The general counsel keeps the contracts and the compliance record in step as the network grows.

Voice, contact-centre and cloud communications platforms sell software, but the service they deliver is usually an electronic communications service, so the General Conditions, numbering and switching obligations can apply to them as they do to a network operator. The same platforms process call recordings, transcripts and analytics that engage UK GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (PECR), and any feature that profiles or scores a caller may need a data protection impact assessment under Article 35 UK GDPR. The general counsel reviews the product itself before launch, as well as the contracts around it.

Industry bodies formed by operators to run a shared service or to speak for a sector need a lawyer who is independent of any one member. Their general counsel handles the constitution and governance of the body, the participation agreements with members, engagement with Ofcom, and the competition-law discipline that applies whenever competitors sit in the same room. Two of the firm’s four appointments are bodies of this kind.

What a fractional general counsel for telecoms covers day to day

Rob Bratby does the work an in-house general counsel does day to day, alongside regulatory advice on telecoms, data protection and payments. That includes company secretarial work and board governance, non-contentious employment and consultant matters, intellectual property and brand protection, commercial contracts and supplier terms, and the coordination of specialist external advisors where a matter needs one.

A private company need not appoint a company secretary (section 270 of the Companies Act 2006), but every company must record minutes of its directors’ meetings and keep them for ten years (section 248), file its confirmation statement and keep its registers current. The general counsel does that work, or supervises whoever does, so the board’s record is complete when a lender, an acquirer or a regulator asks for it. In employment, an employer must give each worker a written statement of particulars no later than the first day of employment (section 1 of the Employment Rights Act 1996), and the general counsel keeps the template current and settles the non-contentious questions that arise; contentious matters are referred to an employment specialist. In intellectual property, copyright in software and documentation written by an employee in the course of employment belongs to the employer unless agreed otherwise (section 11(2) of the Copyright, Designs and Patents Act 1988), but work by a contractor does not, and the general counsel sees that the assignment clauses are in place before a product ships.

Obligation on a communications provider	Who it applies to	What the general counsel does
Compliance with the General Conditions of Entitlement	Every provider of an electronic communications network or service	Maps each condition to the product, the contract terms and the customer journey; handles Ofcom correspondence
Numbering obligations under the National Telephone Numbering Plan	Providers that adopt or allocate telephone numbers	Number applications, porting and sub-allocation terms, misuse controls
Security measures for networks and services (sections 105A to 105D, inserted by the Telecommunications (Security) Act 2021)	Providers of public electronic communications networks and services	Supplier contract terms, incident procedures, board reporting on the security record
Processor contracts and impact assessments (Articles 28 and 35 UK GDPR)	Controllers and processors of customer, caller and employee data	Data processing agreements with operators and partners, DPIAs for analytics and AI features
Direct marketing and terminal-equipment rules (regulations 22 and 6 PECR, as amended by the Data (Use and Access) Act 2025)	Any provider marketing to individual subscribers or storing information on a device	Consent and soft opt-in design, cookie and app compliance
Mandatory notification of a notifiable acquisition (section 14 National Security and Investment Act 2021)	Acquirers of control in entities in the communications sector	Deal structuring and NSIA clearance on acquisitions and disposals
Minutes, registers and filings (sections 248 and 270 Companies Act 2006)	Every company; a private company need not appoint a secretary	Company secretarial work and board support

Two appointments in detail

Core Communication Group

Core Communication Holdings Limited is a UK mobile distribution and communications group whose business depends on agreements with every major UK mobile network operator for SIM distribution, alongside contracts with national and independent retailers, wholesale partners and accessory suppliers. Bratby Law drafts, reviews and negotiates those agreements, advises on the contractual and data protection arrangements for their eSIM product, including roaming partner agreements, international transfer mechanisms and end-user terms, and advises on compliance with the General Conditions, numbering obligations and consumer protection requirements as the group’s products change. Bratby Law also advises on the group’s corporate structure, acquisitions and disposals, company secretarial work and board matters. Tony Greaves, the group’s CEO, says: “he gives us direct, practical advice without the overhead of a full-time hire.” The full case study is the Core Communication Group case study.

TelXL Limited

TelXL Limited is a UK contact centre technology company selling its Cxp platform through channel partners. The platform’s AI analytics features, including conversation intelligence, real-time transcription and sentiment analysis, need the data protection work to be done inside the product roadmap rather than after launch, so Bratby Law advises on data processing agreements, controller and processor obligations, data protection impact assessments and the privacy documentation for each AI-driven feature. Bratby Law also handles partner onboarding, reseller agreements, SaaS terms and enterprise contracts, compliance with the General Conditions, numbering, network access and switching, dispute management, and corporate transactions including the disposal of a group subsidiary by trade sale, together with company secretarial support and board advice. Aaron Fox, TelXL’s Chief Executive, says: “He provides the commercial judgment of a general counsel with the specialist regulatory knowledge we need across telecoms, data protection and payments.” The full account is in the TelXL case study.

Industry bodies: TOTSCo and UKPI

Bratby Law is general counsel to The One Touch Switching Company (TOTSCo), the industry body operating the cross-platform switching service mandated by Ofcom, advising on 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. In each, the general counsel holds a position independent of any single member and keeps the body’s decisions within competition law. A communications provider that is a member of such a body meets the same questions from the other direction, and Bratby Law advises members on that too.

How this compares with instructing a firm matter by matter

Question for a communications provider	Matter-by-matter instruction of a telecoms firm	Fractional general counsel for telecoms
Who holds the context on the MNO or wholesale contract	Rebuilt from the file each time a new lawyer picks it up	Held continuously by the general counsel who negotiated it
How fast a product question gets a regulatory answer	An engagement letter, a scope and a fee estimate first	Same day, against a known product and a known compliance record
Who manages specialist external counsel	The business, without a lawyer to brief or review them	The general counsel scopes, instructs and reviews the specialist
Who prepares the board and keeps the company’s record	Nobody, unless a director does it	The general counsel, as part of the retainer
How cost behaves	Hourly, matter by matter, unpredictable across a year	A retainer with an agreed time allocation, adjusted as the business changes

Context is the largest difference. A communications provider’s legal questions are rarely new, and recur across the same handful of contracts, products and regulatory relationships. A lawyer who holds that context answers most of them in minutes. A firm instructed matter by matter starts each one from the beginning.

Bratby Law does not replace specialist external firms where a matter needs one, for contentious employment work, litigation or a jurisdiction outside England and Wales. The general counsel decides when that is needed, instructs the specialist and reviews the advice, so the business pays for specialist work only where it is required and receives it in a form it can act on.

How to start

A fractional general counsel for telecoms starts by reviewing the provider’s contracts, regulatory position and corporate record. Rob Bratby then agrees a monthly or quarterly time allocation, attends board or executive meetings where needed, and is the single point of contact for every legal question. The mechanics of the retainer, reporting and flexing the allocation are set out on the Fractional General Counsel page, and they are the same for a communications provider as for any other appointment.

Frequently asked questions

Does a small communications provider need a general counsel at all?

A provider with one operator contract and a few hundred customers may not. It usually does once the General Conditions apply to its service, it adopts numbers, or it signs a wholesale or channel agreement whose terms it cannot fully assess. A fractional general counsel for telecoms scales the time allocation to the size of the business, so the cost follows the legal load.

Does the general counsel handle Ofcom correspondence and complaints?

Yes. The general counsel handles information requests, compliance correspondence and complaints and investigations with Ofcom on the provider’s behalf, and prepares the board where a matter could lead to enforcement. Formal representations in an enforcement case are prepared under the same appointment.

Does it cover data protection for a new product?

Yes. A fractional general counsel for telecoms reviews the product itself: the lawful basis, the privacy notice, the processor contracts under Article 28 UK GDPR, a data protection impact assessment under Article 35 where the product profiles or monitors individuals, and the PECR rules on marketing and on storing information on a device. That is the work Bratby Law does for TelXL.

How does it fit with a law firm the provider already uses?

The general counsel manages that relationship rather than replacing it. Existing firms continue to act where they add value, typically litigation, property or specialist employment work, and the general counsel briefs them, reviews their advice and keeps the cost within the budget the board has set.

What happens in the first month of a fractional general counsel for telecoms appointment?

The first month is a review: the operator and channel contracts, the regulatory register against the General Conditions and numbering obligations, the data protection documentation, the statutory books and the board’s open legal actions. Rob Bratby then gives the board a short written note of the position, a list of what needs attention in order of consequence, and an agreed allocation for the months that follow.

Other fractional general counsel pages:

Fractional General Counsel
Tech Scale-Up Counsel
Interim Counsel
Fintech and Payments Fractional GC
UK Counsel for Global Businesses
Telecoms Regulation

If you run a communications provider and want a fractional general counsel for telecoms, Bratby Law can usually start at short notice.

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

Read the Core Communication and TelXL case studies for the full account of each appointment.