Project counsel for telecoms, payments and data protection workstreams where you need a senior regulatory lawyer for a defined project with a clear scope and timeline. Your business has a specific regulatory or commercial project that requires specialist legal input, but neither your in-house team nor your panel firm has the sector depth to deliver it. You need someone who can own the legal workstream, integrate with your project team and deliver to a fixed deadline. We provide project counsel for defined engagements across telecoms regulation, payments compliance and data protection.

Who this is for

Running a defined project – a network build, regulatory application, product launch or restructuring – that needs dedicated legal support from start to finish? Project counsel provides a named lawyer embedded in the project team for the duration, covering all regulatory, commercial and contractual workstreams.

Project type	Typical scope	Duration
Regulatory compliance programme	Gap analysis, remediation plan, policy drafting, staff training across telecoms, data or payments obligations	3-6 months
Licence application or renewal	Preparing and managing Ofcom, FCA or PSR applications, conditions negotiation, post-grant compliance	2-6 months
Network build or expansion	Code powers applications, wayleave negotiations, planning consents, TSA 2021 security compliance	6-12 months
Product launch regulatory workstream	Regulatory perimeter assessment, General Conditions mapping, numbering and spectrum applications	2-4 months
Transaction regulatory workstream	Regulatory due diligence, change-of-control notifications, post-completion integration	3-9 months
Regulatory response or investigation	Managing Ofcom, ICO or FCA information requests, preparing submissions, remediation	Variable

Typical triggers

• You are implementing Telecommunications (Security) Act 2021 requirements and need a lawyer who understands the security framework to own the compliance workstream
• You are preparing for a market review or responding to an Ofcom consultation and need a regulatory lawyer to draft the submission
• You are launching a payments product and need project counsel to manage the FCA application or variation process
• You are running a UK GDPR compliance programme and need a lawyer to conduct the data protection impact assessments and draft the accountability documentation
• You are implementing a switching or migration programme and need someone to manage the regulatory obligations under General Condition C7
• You are negotiating a complex interconnection, access or network sharing agreement and need specialist regulatory drafting input
• A specific commercial contract requires regulatory expertise that your panel firm does not hold
• The business needs to manage a specific regulatory approval process, such as an FCA change of control application or spectrum licence transfer
• A data protection remediation programme needs to be designed and implemented as a defined project with clear deliverables
• A commercial dispute with a counterparty, such as an interconnection dispute or Electronic Communications Code wayleave negotiation, needs project-based legal management

What we deliver

Project counsel engagements have a defined scope, timeline and set of deliverables agreed at the outset. Typical deliverables include:

• Regulatory compliance projects: managing compliance workstreams under the Communications Act 2003, TSA 2021, General Conditions, PSRs 2017 or UK GDPR, from scoping through to board sign-off
• Consultation responses: drafting submissions to Ofcom, FCA, PSR or ICO consultations, including market reviews, regulatory policy proposals and legislative reform
• Authorisation and licensing: managing FCA authorisation applications, variations and regulatory compliance processes on a project basis
• Data protection projects: conducting DPIAs, drafting data protection policies, mapping processing activities and building accountability frameworks under the UK GDPR
• Regulatory drafting: preparing or reviewing regulatory clauses in commercial agreements, including interconnection agreements, SaaS contracts, MVNO agreements and network sharing arrangements
• Board papers and regulatory briefings: producing standalone regulatory analysis for boards, investment committees or executive teams on specific issues
• Switching and migration projects: managing the legal and regulatory workstream for switching implementations, number portability projects or service migration programmes

How the engagement works

All project counsel work is delivered by Rob Bratby personally. Engagements are scoped at the outset with a defined set of deliverables, timeline and fee structure. We work on a fixed fee, capped fee or daily rate depending on the project. We integrate with your project team, attend project calls and deliver to your deadlines and reporting structure.

Project counsel engagements typically last 4 to 12 weeks. Shorter engagements (a single consultation response or regulatory opinion) and longer programmes (a full compliance implementation) are both standard.

Related practice areas

For the underlying regulatory frameworks, see Telecoms Regulation, Data Protection and Payments Regulation. For matter-specific advice on a single question rather than a project engagement, see Direct Legal Advice.

Representative experience

Recent and representative matters include:

• Acted as project counsel for a full-fibre network deployment, managing regulatory authorisation, wayleave negotiations and Electronic Communications Code rights across a multi-phase rollout programme.
• Provided project counsel services for an FCA authorisation application, managing the regulatory business plan, application drafting and FCA correspondence from pre-submission through to approval.
• Served as project counsel on a telecoms network migration, covering regulatory change notifications, customer contract amendments and interconnection agreement novations across the transition.
• Acted as project counsel for a UK GDPR compliance programme, managing the gap analysis, remediation plan, policy suite and staff training programme within a board-mandated timeline.
• Provided project counsel on a digital infrastructure joint venture formation, managing the regulatory approvals, shareholder agreement and operational agreements from heads of terms through to completion.

Frequently asked questions

How does project counsel differ from direct legal advice?

Direct legal advice answers a specific question. Project counsel owns a defined workstream over a period of weeks or months, integrating with your project team and delivering a set of agreed outputs. The distinction is between a single instruction and an embedded project role.

Can you manage external advisors as part of the project?

Yes. Where a project requires input from other specialist advisors, we coordinate the legal workstream and manage the relationship with external counsel. This is common in transactions and multi-jurisdictional compliance projects.

What fee structures are available?

We offer fixed fee, capped fee and daily rate structures depending on the project. Fixed fees work well for defined deliverables such as a consultation response or compliance report. Daily rates suit ongoing project work where the scope may flex. We agree the fee structure at the outset.

Do you work on site?

We work on site or remotely as the project requires. For projects involving close collaboration with a project team, regular on-site attendance is standard. For standalone deliverables such as a regulatory opinion or consultation response, remote working is the norm.

Can you take on a project at short notice?

Yes. We can begin project work within 48 hours of instruction. Consultation response deadlines, regulatory filing dates and deal timetables do not wait. We are structured for rapid deployment on time-sensitive regulatory projects.

Can you manage a regulatory approval process as project counsel?

Yes. Regulatory approval processes, such as FCA change of control applications, spectrum licence transfers, or Ofcom General Conditions compliance for a new service launch, are well-suited to project counsel engagements. We manage the application from start to finish: scoping the requirements, preparing the submission, liaising with the regulator, and reporting progress to the board. The project concludes when the approval is obtained.

What kind of projects are suited to this engagement model?

Project counsel works well for defined regulatory or transactional workstreams with a clear start and end point. Typical examples include: regulatory due diligence on an acquisition target, designing a compliance programme for a new regulatory obligation, managing a data protection remediation programme, negotiating a specific commercial agreement such as an interconnection or MVNO host network deal, or handling a regulatory investigation response. We agree the scope, timeline, and fee structure at the outset.

How do you handle a dispute as project counsel?

We manage regulatory and commercial disputes on a project basis, from initial assessment through to resolution. This includes disputes with regulators (responding to enforcement action, challenging regulatory decisions), disputes with counterparties (interconnection disputes, wayleave negotiations under the Electronic Communications Code), and internal disputes (shareholder disagreements in JV structures). We assess the merits, advise on strategy, and manage the process to resolution.

Related fractional general counsel pages

See also our other fractional general counsel pages:

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

If you have a defined regulatory or commercial project that needs a senior lawyer, we can scope the engagement and start within days.

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 – Telecoms” in London (TMT – IT & Telecoms): The Legal 500
• Lexology: Rob Bratby is featured on Lexology’s expert profiles as a Global Elite Thought Leader for data: Lexology