Fintech and Payments Fractional GC

Embedded senior legal leadership for fintechs, PSPs and payments businesses

Fintechs, payment service providers, electronic money institutions and open banking businesses operate in one of the most intensively regulated sectors in the UK. FCA authorisation, PSR oversight, safeguarding obligations, anti-money laundering compliance and data protection requirements create a continuous regulatory workload that demands senior legal attention. Yet many payments businesses, particularly those at growth stage, do not have a full-time general counsel. Bratby Law provides fractional general counsel for fintech and payments businesses, delivering embedded senior legal leadership focused on the regulatory and commercial challenges specific to this sector.

Who this is for

This model serves payments businesses that need ongoing senior legal support but are not yet at the scale where a full-time GC is justified. Typical clients include payment service providers and electronic money institutions authorised or registered with the FCA under the Payment Services Regulations 2017 or the Electronic Money Regulations 2011; open banking and variable recurring payment providers navigating the PSR and FCA frameworks; embedded finance and banking-as-a-service businesses managing regulatory relationships on behalf of their clients; payment technology companies whose products touch regulated payment processing; and fintech businesses preparing for, or recently having obtained, FCA authorisation who need experienced legal support during the critical post-authorisation period.

Recurring workstreams

Fractional GC support for fintech and payments businesses typically covers regulatory compliance management, including FCA and PSR reporting obligations, safeguarding arrangements, complaint handling, wind-down planning and ongoing conditions of authorisation. It covers commercial contracts, including payment processing agreements, merchant services terms, scheme membership agreements, open banking access arrangements and technology licensing. It covers governance and board support, including preparation of compliance monitoring reports, board papers on regulatory developments, and advice on senior management responsibility under the FCA’s Senior Managers and Certification Regime. It covers data protection compliance, including DPIAs for new payment products, data processing agreements with partners and processors, and ICO accountability documentation under UK GDPR and the Data Protection Act 2018. And it covers regulatory change management, including tracking and implementing changes from FCA consultations, PSR policy statements, and HM Treasury legislative programmes such as the proposed FCA/PSR consolidation.

Legal and regulatory coverage

The fractional GC role for payments businesses covers the full scope of legal and regulatory requirements specific to the sector. This includes the Payment Services Regulations 2017 and Electronic Money Regulations 2011 (authorisation conditions, safeguarding, conduct requirements, reporting and wind-down); FCA Handbook requirements applicable to payment institutions and electronic money institutions; PSR regulation of payment systems, including the New Payments Architecture and interchange fee regulation; open banking and account information service regulation, including PSD2-derived requirements retained in UK law; Consumer Duty obligations as applied to payments businesses; anti-money laundering and counter-terrorism financing compliance under the Money Laundering Regulations 2017; and operational resilience requirements, including the FCA and PRA operational resilience framework and awareness of the EU’s Digital Operational Resilience Act where relevant to cross-border operations.

Rob Bratby holds a fractional General Counsel appointment at UK Payments Initiative Limited, giving him direct, current experience of the regulatory landscape facing payments businesses. Combined with over 30 years’ experience across Oftel, COLT, international law firms, and current appointments at TelXL, Core and The One Touch Switching Company, this provides the breadth and depth of regulatory experience that payments businesses need from a fractional GC.

Why this model for payments businesses

Payments businesses face a particular challenge with legal resourcing. The regulatory workload is continuous and demanding, but much of it is recurring rather than project-based. Authorisation conditions must be maintained, safeguarding must be monitored, regulatory returns must be filed, and commercial contracts must be reviewed against a moving regulatory baseline. Instructing external lawyers on each issue individually is expensive and creates fragmented advice with no continuity. A fractional GC provides the senior, consistent legal oversight that the regulatory environment demands, at a cost that scales with the business rather than with the number of instructions.

For fintechs in particular, having a fractional GC who understands the payments regulatory framework also strengthens the business’s position with the FCA. Regulated businesses are expected to have adequate senior management arrangements, including appropriate legal oversight. A fractional GC appointment demonstrates to the regulator that the business takes its compliance obligations seriously and has experienced legal leadership in place.

Related practice areas

Fintech and payments fractional GC work draws directly on Bratby Law’s core practice areas. For FCA and PSR authorisation, open banking, scheme governance and safeguarding, see Payments Regulation. For commercial and corporate transactions, see Transactions. For UK GDPR compliance and data protection for payments products, see Data Protection.

Related engagement models

What clients say about Bratby Law:

“…one of those rare lawyers who really does understand the business imperatives behind the legal situations businesses find themselves in.”
“I worked with Rob over many years whilst I was at Orange. He is one of those rare lawyers who really does understand the business imperatives behind the legal situations businesses find themselves in. Most notably he provided first class support to me and my team on a high profile / high value joint venture network sharing deal. His ability to see both the detail and the bigger strategic picture were enormously helpful.”
Amanda Doyle
(Former) General Counsel, Orange UK
“I would highly recommend Rob and his team.”
“I have had the pleasure of working with Rob now on a number of occasions and engagements with clients. Rob is one of the most knowledgeable people I have come across in the Telecommunications industry, both in his comprehensive understanding of the law for various countries and in the application of this law and what it means for Operators. This is complemented by his generosity with sharing his knowledge, and the friendly style with which he works. I would highly recommend Rob and his team.”
Nick White
(Former) Deloitte
“I would recommend Rob for any major Telecoms project”
“I worked with Rob to introduce One Touch Switching for broadband and fixed voice, which launched successfully with almost two million customers using the service to date. Rob is a first class Legal Counsel with exceptional legal and regulatory knowledge enabling him to give insightful strategic guidance to the ExCo and the Board. He is highly trusted by Directors and easy to work with. I would recommend Rob for any major Telecoms project.”
Toby Lovell
(Former) Chief of Staff, The One Touch Switching Company

Independent directory rankings

Our specialist expertise is recognised in major independent legal directories:

Chambers & Partners: Rob Bratby is ranked in the UK Guide 2026 in the “Telecommunications” category: Chambers
The Legal 500: Rob Bratby is listed as a “Leading Partner – Telecoms” in London (TMT – IT & Telecoms): The Legal 500
Lexology: Rob Bratby is featured on Lexology’s expert profiles (Global Elite Thought Leader): Lexology

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Frequently asked questions

Do you only advise FCA-authorised businesses?

No. We advise businesses at all stages, including those preparing for authorisation, those operating under the registration regime, and those that are already fully authorised. We also advise businesses that are assessing whether their activities fall within the regulatory perimeter.

Can you help with an FCA authorisation application?

Yes, as a project counsel engagement alongside the fractional GC role. Authorisation applications typically run for six to twelve months and require dedicated project management. See Project Counsel for how we structure project-based work.

What is the typical time commitment?

Most fintech and payments fractional GC engagements start at three to five days per month, depending on the regulatory workload and the stage of the business. The allocation adjusts as needs change.

How do you stay current on payments regulation?

Rob Bratby’s fractional General Counsel appointment at UK Payments Initiative Limited provides direct, current exposure to the payments regulatory landscape. This is supplemented by active monitoring of FCA, PSR and HM Treasury consultations, policy statements and enforcement activity.

Can you manage our FCA relationship?

Yes. We manage direct engagement with the FCA and PSR on behalf of clients, including regulatory correspondence, supervisory meetings, reporting obligations and change-in-control notifications.

Book a call

If your fintech or payments business needs senior legal support, contact us to discuss fractional general counsel for your business.