Fractional general counsel for telecoms, payments and data technology scale-ups whose regulatory obligations are growing faster than their headcount. You are building a regulated technology business. Your product touches telecoms infrastructure, payment services or personal data, and your regulatory obligations are becoming material. You need a senior lawyer who understands your sector, can advise the board, manage regulatory relationships and review commercial agreements, but a full-time GC hire is not yet justified or not yet affordable. We provide fractional general counsel to regulated tech scale-ups from Series A through to growth stage.

Who this is for

Growth-stage tech business navigating UK regulation for the first time? Tech scale-up counsel provides fractional legal leadership scaled to your stage and funding cycle, covering telecoms, data protection and payments regulatory requirements as your product and customer base grow.

Typical triggers

• The business reaches a stage where it must comply with Ofcom General Conditions, obtain FCA authorisation under the PSRs 2017 or EMRs 2011, or implement a UK GDPR accountability framework
• An investor requires the company to have a named regulatory counsel as a condition of funding
• The product roadmap includes a feature that may trigger new regulatory obligations and the CTO needs legal input before committing to the build
• The company is negotiating its first interconnection agreement, wholesale access arrangement or payment scheme membership and needs specialist regulatory drafting
• A regulatory enquiry or complaint arrives and the company has no qualified lawyer to respond
• The board wants to understand the regulatory risks in its business plan and needs a lawyer who can translate regulation into commercial language
• The company is preparing to enter a new market (UK or international) and needs to map the regulatory requirements
• A tech scale-up is preparing for a funding round and needs its regulatory and data protection compliance in order for investor due diligence
• The business is deploying AI features and needs to understand whether a DPIA is required and how to structure its data governance
• A product expansion may cross into regulated territory (payments or telecoms) and the business needs a regulatory perimeter assessment

What we deliver

The scope of a tech scale-up fractional GC engagement is shaped by the company’s growth stage and regulatory position. Typical deliverables include:

• Regulatory perimeter assessment: confirming which UK regulatory regimes apply to the business, covering telecoms (Communications Act 2003), payments (PSRs 2017, EMRs 2011) and data protection (UK GDPR)
• Product regulatory review: assessing new product features against applicable regulatory requirements before the technology build, avoiding costly rework
• FCA authorisation support: managing the authorisation or variation application, preparing the regulatory business plan and advising on conditions and ongoing requirements
• Compliance framework: building the compliance programme appropriate to the company’s stage, from a lightweight framework at Series A to a full governance structure at growth stage
• Board and investor reporting: preparing regulatory risk sections for board papers, investor updates and due diligence questionnaires
• Commercial contract review: reviewing and negotiating the contracts that matter at scale-up stage, including interconnection agreements, SaaS terms, partnership agreements, data processing agreements and funding documentation
• Regulator relationship management: acting as the named legal contact for Ofcom, the FCA, the PSR or the ICO

How the engagement works

All fractional GC work is delivered by Rob Bratby personally. Rob has direct experience as general counsel and company secretary inside operator-side businesses, including embedded GC roles at a major international telecoms operator and within industry JVs. He understands the operational reality of running a growing regulated business from the inside.

Engagements are structured as a monthly retainer with a defined time commitment, typically 1 to 3 days per month. The commitment can flex up for specific events such as an FCA application, funding round or material contract negotiation. We attend board meetings, join product calls where regulatory input is needed and are available between retained days for urgent matters. There is no minimum term, though most scale-up engagements run for 12 months or longer as the regulatory relationship requires continuity.

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.

Representative experience

Recent and representative matters include:

• Acted as fractional GC for a Series A telecoms platform, managing General Conditions compliance and the commercial contract suite from first revenue through Series B.
• Provided scale-up counsel to a payments fintech from pre-revenue through FCA authorisation, including regulatory business planning and board advisory throughout the application process.
• Served as fractional GC for a health-tech scale-up, managing UK GDPR compliance, the DPIA programme and data sharing agreements as the client expanded its NHS partnerships.
• Provided legal leadership to an IoT scale-up on regulatory classification, PECR compliance and commercial contracts through a seed-to-Series-A funding round.
• Acted as fractional counsel for a data analytics start-up, managing UK GDPR compliance, customer contracts and a strategic partnership that required regulatory structuring advice.

Frequently asked questions

At what stage does a scale-up need a fractional GC?

Typically at the point where the business has material regulatory obligations or is about to take them on. For telecoms businesses, this is often when they become subject to General Conditions. For fintechs, it is around the FCA authorisation application. For data businesses, it is when processing volumes or AI-related risks trigger the need for formal governance.

How does this differ from using a law firm?

A law firm advises on specific instructions. A fractional GC is embedded in your business, knows your product roadmap, understands your regulatory position and is available when you need a quick answer. You get continuity, context and commercial judgement, not a standing start on every matter.

Can you help with our FCA application?

Yes. We advise on FCA authorisation and variation applications under the PSRs 2017 and EMRs 2011, including the regulatory business plan, programme of operations and ongoing compliance requirements. The fractional GC model means we continue to support the business after authorisation, not just during the application.

What does the time commitment look like?

Most scale-up engagements are 1 to 3 retained days per month. The commitment flexes up for specific events, such as an authorisation application, funding round, or material contract negotiation. Between retained days, we are available for urgent questions by email or short call.

Do investors value a fractional GC appointment?

Yes. Investors in regulated businesses want to know that the company has qualified legal counsel managing the regulatory relationship. A fractional GC provides that assurance at a fraction of the cost of a full-time hire. Several of our scale-up engagements originated from investor requirements.

Do we need a DPIA for our new product feature?

If the feature involves processing personal data in a way that is likely to result in a high risk to individuals, you are required to carry out a data protection impact assessment under Article 35 of the UK GDPR before the processing begins. Common triggers include profiling, automated decision-making, large-scale processing of sensitive data, and systematic monitoring. As fractional GC, we assess the requirement at the product design stage and, where needed, conduct the DPIA as part of the development cycle rather than as a separate compliance exercise.

When does a tech scale-up need to think about regulatory compliance?

From the point your product touches personal data, payment processing, or electronic communications, regulation applies regardless of your company’s size. Data protection obligations under the UK GDPR apply from day one. If your product involves payment services, FCA authorisation requirements apply before you go to market. If it involves electronic communications, the General Conditions apply. The earlier you build compliance into the product, the less expensive it is to retrofit later, and investors expect to see it.

Can you help prepare the business for investor due diligence?

Yes. Investor due diligence on a regulated tech business will examine your regulatory status, compliance programme, data protection practices, and any enforcement history. As fractional GC, we ensure the regulatory house is in order before DD starts: up-to-date privacy notices, compliant data processing agreements, evidence of regulatory filings, and a clear record of your compliance activities. This reduces the risk of regulatory findings becoming deal issues or price adjustments.

Related fractional general counsel pages

See also our other fractional general counsel pages:

• UK Counsel for Global Businesses
• Interim Counsel
• Project Counsel
• Joint Venture Counsel
• Fractional General Counsel (overview)

If you are scaling a regulated tech business and need fractional GC support, we can usually start within two weeks.