Fractional general counsel for international groups headquartered in the US, Singapore, Hong Kong, Australia or Europe with UK operations, customers or regulatory obligations in telecoms, data protection or payments. Your group has UK-regulated activities but no UK-based legal resource with the regulatory depth to manage them. You need a senior English-qualified lawyer who understands the Communications Act 2003, UK GDPR and PSRs 2017, and who also understands the governance requirements of multinational organisations: group reporting lines, board committee structures, regional compliance frameworks and the practical reality of managing UK regulatory obligations within a parent company structure based in a different jurisdiction and time zone.

Who this is for

International business with UK operations or UK-facing customers and no in-house UK regulatory expertise? UK counsel for global businesses provides ongoing English-law regulatory advice on telecoms, data protection and payments obligations, including the post-Brexit UK/EU divergence that affects cross-border operations.

Parent HQ jurisdiction	Typical UK regulatory exposure	Governance considerations
United States	UK subsidiary providing telecoms or payments services; UK GDPR compliance for US SaaS platform with UK users	SEC/SOX reporting obligations, US parent board oversight, Delaware corporate governance interacting with UK regulatory duties
Singapore / Hong Kong	APAC telecoms group with UK network operations; payments business serving UK customers from Asian HQ	APAC holding structures, regional GC reporting lines, time zone management for UK regulatory deadlines
Australia	Subsea cable operator with UK landing points; Australian fintech with UK FCA authorisation	ASX continuous disclosure obligations, dual regulatory reporting to ACMA/Ofcom or ASIC/FCA
European Union	EU telecoms group with UK operations post-Brexit; GDPR adequacy and UK-specific requirements	Matrix reporting to EU group legal, managing UK regulatory divergence from EU frameworks
Middle East / Africa	Sovereign or PE-backed infrastructure investor with UK digital assets	Investment vehicle governance, regulatory approval for foreign ownership, NSIA mandatory notifications

Typical triggers

• Your group acquires a UK telecoms or payments business and needs a UK legal function from day one
• You are entering the UK market and need to understand Ofcom General Conditions, FCA authorisation requirements or UK GDPR obligations before launch
• Your UK subsidiary has been operating without dedicated legal support and a regulatory issue has surfaced
• Your global GC needs a UK-qualified counterpart for board papers, regulatory filings and local commercial contracts
• An investor requires a named UK legal contact as a condition of the investment or financing agreement
• You need to respond to an Ofcom information request, FCA supervisory enquiry or ICO investigation and have no UK legal resource
• An overseas telecoms or payments business is entering the UK market and needs a UK-qualified lawyer to manage the regulatory requirements without establishing a full UK legal team
• A global business needs advice on how UK GDPR applies to its UK-facing activities and whether it needs to appoint a UK representative
• A multinational needs to understand where UK telecoms or data protection regulation has diverged from EU requirements and what that means for its UK operations

What your general counsel delivers

The scope of an international fractional GC engagement is tailored to the group’s UK regulatory footprint. Typical deliverables include:

• UK regulatory status assessment: a clear opinion on which UK regulatory regimes apply to your business, covering telecoms (Communications Act 2003), payments (PSRs 2017, EMRs 2011) and data protection (UK GDPR)
• Ongoing regulatory compliance management: monitoring General Conditions obligations, FCA reporting requirements, safeguarding compliance and ICO accountability obligations
• Board and management support: attending UK subsidiary board meetings, preparing regulatory briefing papers and advising on UK-specific governance requirements
• Regulator relationship management: acting as your named legal contact for Ofcom, the FCA, the PSR and the ICO
• Commercial contract review: reviewing and negotiating UK commercial agreements, interconnection agreements, data processing agreements and supplier contracts
• Incident and enforcement response: managing UK regulatory investigations, complaints and enforcement action on behalf of the group
• UK market entry support: advising on authorisation applications, notification requirements and the regulatory steps to lawful UK operations

How the engagement works

All fractional GC work is delivered by Rob Bratby personally. Engagements are structured as a monthly retainer with a defined scope and agreed time commitment. We operate as an extension of your global legal team, reporting to your group GC or CEO and attending regular calls on your timetable. We work in your systems, use your templates where required, and adapt to your reporting structure. Where matters require local specialist input beyond our core practice areas, we coordinate with your existing panel firms.

The engagement can begin within 48 hours of instruction. There is no minimum term, though most international engagements run for 12 months or longer as the UK 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.

Frequently asked questions

How does this differ from instructing a London law firm?

A London firm gives you advice on specific matters. A fractional GC gives you a named senior lawyer embedded in your business who knows your operations, your regulatory position and your commercial priorities. You get continuity and context, not a standing start on every instruction.

What time commitment is typical?

Most international fractional GC engagements are 2 to 4 days per month. The commitment can flex up for specific matters such as an acquisition, regulatory investigation or product launch, and flex down during quieter periods.

Can you attend our board meetings?

Yes. We attend UK subsidiary board meetings, prepare board papers on regulatory matters and provide the legal input your directors need. We also attend group-level calls where UK regulatory issues are on the agenda.

Do you act as our UK representative under the UK GDPR?

We can advise on whether a UK representative is required under Article 27 UK GDPR and coordinate the appointment. We do not ourselves act as the statutory representative, but we manage the relationship with the ICO on your behalf as your UK legal counsel.

What if we need specialist advice outside your practice areas?

We coordinate with your existing panel firms for matters outside telecoms, data protection and payments regulation. The value of the fractional GC role is that you have a single UK legal contact who triages, instructs and manages the relationship with external advisors on your behalf.

Can you act as our UK legal presence without us having a UK office?

Yes. We act as fractional UK counsel for overseas businesses that operate in UK regulated markets but do not have a UK legal team. This includes managing UK regulatory obligations, acting as the point of contact for UK regulators, negotiating UK commercial contracts, and advising the overseas board on UK legal matters. You get a UK-qualified solicitor with specialist telecoms, data protection, and payments expertise without establishing a UK legal function.

How does UK data protection law apply to our business if we are based overseas?

The UK GDPR applies to organisations outside the UK that offer goods or services to individuals in the UK, or that monitor the behaviour of individuals in the UK. If your business falls within this extraterritorial scope, you may need to appoint a UK representative under Article 27, comply with UK data subject rights, and manage international data transfers under the UK’s own adequacy and transfer framework. We advise overseas businesses on their UK GDPR obligations and act as a practical point of contact for UK data protection compliance.

Can you help us understand the differences between UK and EU telecoms regulation?

Since Brexit, UK telecoms regulation under the Communications Act 2003 and the Telecommunications (Security) Act 2021 has diverged from the EU’s European Electronic Communications Code in specific areas, including security obligations, market review procedures, and the approach to net neutrality. We advise global telecoms businesses on the practical differences that affect their UK operations, compliance programmes, and commercial arrangements, ensuring they do not assume EU compliance automatically satisfies UK requirements.

Related fractional general counsel pages

See also our other fractional general counsel pages:

• Interim Counsel
• Project Counsel
• Joint Venture Counsel
• Tech Scale-Up Counsel
• Fractional General Counsel (overview)

If your international group needs UK regulatory counsel on a retained basis, we can usually start within two weeks of instruction.

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