Interim general counsel for telecoms, payments and technology businesses that have lost their GC or senior legal resource and need immediate cover. Your general counsel has resigned, is on extended leave or has been redeployed. Regulatory deadlines continue, commercial contracts need signing and the board needs legal input now. You cannot wait three to six months for a permanent recruitment process. We step in within days to maintain legal continuity, manage the regulatory relationship with Ofcom, the FCA or the ICO, and keep the business moving while you recruit.

Who this is for

GC has left, is on leave or your business is in transition and you need immediate legal leadership? Interim counsel provides temporary general counsel cover for regulated telecoms, data protection and payments businesses, maintaining continuity on regulatory compliance and commercial operations during the gap.

Typical triggers

• The GC resigns and the notice period is too short to recruit a replacement before they leave
• The sole in-house lawyer goes on extended leave and there is no backup
• A PE acquisition completes and the target company’s legal function needs to be rebuilt
• The business receives an Ofcom information request, FCA supervisory notice or ICO investigation notice and has no qualified lawyer to respond
• A regulatory deadline is approaching and the departing GC was the only person managing the compliance programme
• The board needs to approve a material contract or regulatory filing and there is no legal sign-off available
• A PE acquisition has completed and the target company needs immediate interim legal leadership while a permanent GC is recruited
• The sole in-house lawyer has resigned and there are outstanding regulatory deadlines that need to be managed during the notice period and beyond
• The business has received a regulatory information request or investigation notice and has no qualified internal lawyer to manage the response

What we deliver

Interim counsel engagements are designed for speed and continuity. The priority is to ensure that nothing falls through the gap between the departing lawyer and their replacement. Typical deliverables include:

• Immediate triage: within the first week, we identify all open legal matters, regulatory deadlines and pending contracts, and produce a status report for the board
• Regulatory continuity: we become the named legal contact for Ofcom, the FCA, the PSR or the ICO and manage any open regulatory matters including compliance reporting under the Communications Act 2003, PSRs 2017 or UK GDPR
• Commercial contract management: reviewing, negotiating and signing contracts that cannot wait for a permanent hire, including interconnection agreements, SaaS contracts, data processing agreements and supplier terms
• Board support: attending board meetings, preparing legal papers and providing the governance input that a GC would normally deliver
• Compliance programme management: maintaining the existing compliance programme, managing regulatory filings and ensuring that reporting deadlines under the Telecommunications (Security) Act 2021 or FCA rules are met
• Handover to permanent hire: preparing a structured handover document for the incoming GC covering all open matters, regulatory contacts, contract status and risk register
• Recruitment input: if requested, advising the board on the skills and experience profile for the permanent GC hire

How the engagement works

All interim counsel work is delivered by Rob Bratby personally. We can begin within 48 hours of instruction. The engagement is structured as a weekly or monthly retainer with a defined time commitment, typically 3 to 5 days per week in the initial phase, stepping down as the situation stabilises and a permanent hire is made. We work on site or remotely as required.

Interim engagements typically last 3 to 6 months. There is no minimum term, but the engagement continues until the permanent hire is in place and a structured handover has been completed.

Related practice areas

For the underlying regulatory frameworks, see Telecoms Regulation, Data Protection and Payments Regulation. For matter-specific advice rather than ongoing embedded support, see Direct Legal Advice. For ongoing retained support rather than interim cover, see Fractional General Counsel.

Representative experience

Recent and representative matters include:

• Provided interim GC cover for a telecoms operator during a six-month recruitment period, maintaining Ofcom compliance, commercial contracts and a network sharing dispute without interruption.
• Acted as interim counsel for a payments business during a regulatory remediation programme following FCA supervisory findings, managing the remediation plan and ongoing compliance in parallel.
• Provided interim legal leadership for a data-driven platform business during a corporate restructuring, maintaining UK GDPR compliance and commercial agreements through the transition.
• Served as interim GC for an e-money institution during a change of control process, managing FCA notifications and ongoing regulatory compliance while the permanent appointment was made.
• Provided interim counsel to a telecoms reseller during an Ofcom investigation, managing the regulatory response alongside business-as-usual legal work throughout the investigation period.

Frequently asked questions

How quickly can you start?

We can begin within 48 hours of instruction. The first week focuses on triage: identifying all open matters, regulatory deadlines and pending contracts so that nothing is missed during the transition.

What happens when you recruit a permanent GC?

We prepare a structured handover covering all open matters, regulatory contacts, contract status, compliance deadlines and a risk register. The handover is designed to give the incoming GC a complete picture from day one.

Can you sign contracts on behalf of the company?

We can review, negotiate and recommend contracts for execution. Whether we sign on behalf of the company depends on the authority delegated by the board. In most interim engagements, we are given signing authority for routine commercial contracts within agreed parameters.

How does interim counsel differ from fractional GC?

Interim counsel is emergency cover for an immediate gap. The time commitment is higher (typically near full-time initially) and the engagement is designed to end when a permanent hire starts. Fractional GC is an ongoing, part-time retained arrangement for businesses that do not need or cannot justify a full-time GC.

Do you work on site?

We work on site or remotely as the business requires. In the initial phase of an interim engagement, on-site presence is usually more effective for building relationships and understanding the business. As the engagement stabilises, remote working is standard.

Can you manage regulatory correspondence while acting as interim counsel?

Yes. Managing ongoing correspondence with regulators is one of the most time-critical tasks when the permanent GC departs. We take over as the point of contact for Ofcom, FCA, ICO, or PSR communications, respond to information requests within statutory deadlines, and ensure the board is kept informed. Our direct experience with these regulators means we can manage the relationship effectively from day one of the interim appointment.

What does the first week of an interim counsel appointment look like?

In the first week, we conduct triage: identifying all open legal matters, pending regulatory deadlines, contracts awaiting signature, and any disputes or investigations in progress. We assess which matters are urgent and which can wait, brief the board on the status of the legal function, and establish a working rhythm with the internal team. For regulated businesses, we prioritise any outstanding regulatory filings or correspondence that has statutory deadlines.

Can you negotiate commercial contracts on behalf of the company?

Yes. As interim counsel, we negotiate and approve commercial contracts on behalf of the business, applying the same commercial judgement an in-house GC would exercise. For regulated businesses, this includes ensuring that contracts comply with applicable regulatory requirements, for example data processing agreements that satisfy UK GDPR obligations, or interconnection agreements that comply with Ofcom’s General Conditions.

Related fractional general counsel pages

See also our other fractional general counsel pages:

• UK Counsel for Global Businesses
• Project Counsel
• Joint Venture Counsel
• Tech Scale-Up Counsel
• Fractional General Counsel (overview)

If your GC has departed and you need immediate senior legal cover, we can step in within days.