Project Counsel

Telecoms and payments businesses regularly face projects that require dedicated senior legal leadership for a defined period: a product launch, a regulatory remediation programme, a licensing application, a network build-out, a compliance transformation or an operational restructuring. These projects have a clear start, defined deliverables and a governance structure, but they require more legal capacity than the in-house team can absorb alongside its day-to-day workload. Bratby Law provides project counsel for defined initiatives in telecoms, data protection and payments regulation.

Who this is for

Project counsel is designed for businesses that need senior legal leadership for a specific initiative rather than ongoing general counsel support. Typical clients include telecoms operators launching new services or entering new markets that require Ofcom notification or regulatory approval; payment service providers and electronic money institutions applying for FCA authorisation or expanding the scope of their existing permissions; technology and platform businesses running GDPR compliance programmes or responding to ICO enforcement; infrastructure investors managing regulatory workstreams within acquisition integration or build-out programmes; and PE-backed businesses undertaking regulatory remediation as a condition of investment or in preparation for exit.

Project types

We provide project counsel support for regulatory and commercial projects that require sector-specialist legal leadership. Typical projects include FCA authorisation applications for payment service providers and electronic money institutions under the Payment Services Regulations 2017 or Electronic Money Regulations 2011. Regulatory remediation programmes following Ofcom, FCA or ICO enforcement action or compliance findings. Product launches involving new regulated services, open banking integrations, or activities that require regulatory notification or approval. Network infrastructure projects requiring wayleave negotiations, spectrum management, numbering allocation applications or compliance with Communications Act 2003 build-out obligations. GDPR compliance programmes including data mapping, DPIA completion, international transfer assessments and privacy notice updates under the Data Protection Act 2018. Operational restructurings that involve changes to regulatory authorisations, licence transfers or notification obligations.

Governance model

Project counsel engagements are structured around clear governance. We agree the project scope, deliverables, timeline and reporting lines at the outset. We report to the project sponsor, typically the CEO, COO, head of compliance or in-house GC. We provide regular progress reporting against agreed milestones and flag risks and dependencies as they emerge. The engagement has a defined end point, usually tied to a regulatory milestone (such as obtaining authorisation), completion of a compliance programme, or delivery of the project’s final outputs.

Rob Bratby has over 30 years’ experience across Oftel, COLT, international law firms, and current fractional GC appointments at UK Payments Initiative Limited, TelXL, Core and The One Touch Switching Company. This combination of regulatory, in-house and advisory experience means project governance is practical and commercially focused, not process-heavy.

The governance model scales to the project. For a straightforward authorisation application, governance may involve fortnightly progress calls and a shared tracker. For a complex remediation programme with multiple workstreams, it may involve weekly steering committee meetings, formal risk registers and board-level reporting. We adapt the governance framework to what the project requires, not to a standard template.

Outputs

Project counsel deliverables are defined at the outset and tailored to the project. Typical outputs include regulatory applications and supporting documentation; compliance frameworks, policies and procedures; risk assessments and remediation action plans; regulatory correspondence and submissions; board papers and progress reports; and handover documentation at project completion. All deliverables are produced to the client’s requirements and internal standards.

We also manage coordination with external specialists where the project requires it, including technical consultants, economic advisers and overseas counsel. This ensures the legal workstream integrates with the wider project rather than operating in isolation.

Why project counsel

A defined project requires dedicated legal focus. Adding a major regulatory project to an already stretched in-house team risks both the project and the day-to-day legal work suffering. Instructing external advisers on a time-and-materials basis can produce good advice but lacks the accountability and project ownership that an embedded project counsel provides. The project counsel model puts a senior lawyer in charge of the legal workstream with clear responsibility for delivery, direct access to the project team, and the regulatory expertise to identify and resolve issues as they arise rather than after they have become problems.

For businesses in regulated sectors, the project counsel model also provides a clear audit trail. The project has defined governance, documented decisions and accountable legal leadership. This is particularly valuable where the project involves regulatory submissions, compliance certifications or board-level reporting, because the regulator or the board can see that the legal workstream was managed by an experienced practitioner with defined responsibility.

Related practice areas

Project counsel work draws on expertise across Bratby Law’s practice areas. For the telecoms regulatory framework, see Telecoms Regulation. For FCA and PSR authorisation and payments compliance, see Payments Regulation. For corporate and infrastructure transactions, see Transactions.

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

How long does a project counsel engagement last?

Engagements are tied to the project timeline. A typical FCA authorisation application takes six to twelve months. A compliance remediation programme might take three to six months. The duration is agreed at the outset and adjusted if the project scope changes.

Can project counsel work alongside our existing legal team?

Yes. The project counsel model is designed to complement the in-house team, taking ownership of the project workstream while the in-house team continues with business-as-usual legal work.

What happens at the end of the project?

We deliver a comprehensive handover including all project documentation, a summary of the current position, and recommendations for ongoing management. The aim is a clean transition with no loose ends.

Do you manage the regulatory relationship during the project?

Where instructed, we manage direct engagement with Ofcom, the FCA, the PSR or the ICO on behalf of the client throughout the project.

Book a call

If you have a regulatory or compliance project that needs dedicated legal leadership, contact us to discuss project counsel support.