English law local counsel

International transactions and cross-border regulatory matters frequently require English-law or UK-regulatory input from a specialist who understands the sector, not just the jurisdiction. Foreign law firms, global project teams and international legal departments need a local counsel partner who can provide substantive regulatory analysis on UK telecoms, data protection and payments law, work to compressed cross-border timetables, and integrate cleanly with multi-jurisdictional teams. Bratby Law acts as English-law local counsel for firms and organisations that need sector-specialist UK regulatory input inside a wider international matter.

Who this is for

English-law local counsel is designed for legal teams leading cross-border matters who need UK-specific regulatory input. Typical clients include international law firms acting on multi-jurisdictional transactions where one or more target entities hold UK regulatory authorisations or operate under UK telecoms, data protection or payments regulation; overseas general counsel and regional legal teams managing UK-facing compliance from outside the UK; global project teams coordinating regulatory workstreams across multiple jurisdictions; and international consultancies or advisory firms delivering cross-border regulatory analysis that includes a UK component. The common requirement is English-law expertise in telecoms, data or payments regulation delivered as part of a coordinated international effort.

Cross-border use cases

The situations where English-law local counsel is needed typically involve a UK regulatory dimension within a wider international matter. A multi-jurisdictional M&A transaction where the target group includes a UK-authorised payment institution or electronic money institution, and the lead counsel needs an assessment of FCA change-in-control requirements under the Payment Services Regulations 2017. A global telecoms group restructuring its European operations, where UK entities hold Ofcom General Conditions authorisations, numbering allocations or spectrum rights that require regulatory analysis. An international data governance programme where the UK GDPR and Data Protection Act 2018 analysis needs to be coordinated with EU GDPR and other jurisdictional requirements. A cross-border JV or network-sharing arrangement where the UK regulatory framework under the Communications Act 2003 imposes specific conditions on the structure or operation of the arrangement.

The English-law role

As English-law local counsel, we take responsibility for the UK regulatory workstream within the wider matter. This means providing substantive English-law opinions on regulatory status, authorisation requirements and compliance obligations. It means drafting or reviewing UK-specific regulatory provisions in transaction documents, shareholder agreements and JV arrangements. It means advising on Ofcom, FCA, PSR and ICO notification and approval requirements, and managing those processes where instructed. It means producing regulatory due diligence reports and risk assessments for the UK component of multi-jurisdictional transactions. And it means contributing UK-law sections to international regulatory comparison exercises and compliance matrices.

We produce all deliverables in the format required by the lead counsel or coordinating firm, and we are experienced in working within multi-firm team structures where clear delineation of responsibility is essential.

Working model

Rob Bratby has over 30 years’ experience in UK telecoms and payments regulation. His career spans Oftel (the predecessor to Ofcom), senior in-house roles at COLT (a pan-European carrier), partnerships at international law firms, and current fractional General Counsel appointments at UK Payments Initiative Limited, TelXL, Core and The One Touch Switching Company. This background means he understands how UK regulators operate in practice, how operators respond to regulatory requirements, and how to present regulatory analysis in terms that international deal teams and boards can act on.

We are accustomed to cross-border working patterns: participating in multi-timezone calls, producing deliverables to coordinating-firm deadlines, and integrating UK-law analysis into international reporting structures. Instructions are typically given by the lead partner or coordinating firm, and we report directly into the international team structure.

Why sector-specialist local counsel

General English-law firms can advise on UK corporate and commercial law, but telecoms, payments and data protection regulation require specialist knowledge that most generalist practices do not hold. The difference is material. A generalist firm may identify that an FCA authorisation exists; a specialist will assess whether that authorisation covers the target’s current activities, whether any permissions gaps create enforcement risk, and how a change of control will affect the authorisation timeline. Similarly, a generalist may note Ofcom General Conditions obligations; a specialist will map those obligations to operational compliance, assess enforcement history, and identify conditions that could constrain post-acquisition integration.

For cross-border teams, instructing a sector-specialist local counsel also reduces coordination cost. The regulatory analysis is produced by someone who understands the commercial context, which means fewer iterations, more precise risk assessments, and deliverables that integrate cleanly with the wider matter.

Related practice areas

English-law local counsel work draws on expertise across Bratby Law’s practice areas. For the UK telecoms regulatory framework, see Telecoms Regulation. For UK GDPR compliance and data governance, see Data Protection. For FCA and PSR authorisation and payments compliance, see Payments Regulation.

Related specialist co-counsel services

See also our other specialist co-counsel services: Transactions Co-counsel for embedded regulatory support on deal workstreams, and Consultant Support for legal integration within consultancy mandates. For ongoing UK legal support for international groups, see UK Counsel for Global Businesses. For an overview of all co-counsel services, see Specialist Co-counsel.

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

What is English-law local counsel?

Local counsel provides jurisdiction-specific legal analysis within a cross-border matter led by another firm or legal team. We provide the English-law and UK-regulatory component, specialising in telecoms, data protection and payments regulation.

Can you work under our firm’s engagement terms?

Yes. We routinely accept instruction under coordinating-firm engagement structures and can work within your professional indemnity and conflicts framework. We are SRA-regulated (number 801942) and carry appropriate professional indemnity insurance.

How do you handle conflicts in cross-border matters?

We run standard SRA conflicts checks before accepting any instruction. Because we are a specialist boutique rather than a full-service firm, our conflicts profile is narrow, which means we are rarely conflicted on cross-border matters in our sector.

What sectors do you cover as local counsel?

We provide English-law local counsel services in telecoms regulation (Ofcom, Communications Act, spectrum, numbering), data protection (UK GDPR, DPA 2018, ICO), and payments regulation (FCA, PSR, PSRs 2017, electronic money). We do not act as general English-law counsel outside these areas.

Book a call

If your cross-border team needs English-law regulatory input in telecoms, data protection or payments, contact us to discuss how we can support your matter.