Insights
Analysis of telecoms, data, payments and technology regulation and transactions
Clear, practical commentary on legal and regulatory developments affecting telecoms operators, digital infrastructure providers, technology companies, financial institutions, fintechs and investors.
Our blogging history
We have been publishing insights since 2010, when Rob first built the website on WordPress. From the outset, the aim was the same: careful research, precise language and analysis that explains not just the legal issue, but its practical and commercial effect.
That remains our approach today. Artificial intelligence now helps with parts of the research and drafting process, and it has supported the development of this website. But technology does not replace judgement, experience or specialist expertise. Our insights are shaped by real advisory work across regulation, compliance and transactions.
Through this Insights section, Bratby Law aims to provide clear analysis that helps organisations make informed decisions in complex and fast-moving areas of law and regulation. For advice on a specific issue, regulatory strategy or a transaction, please get in touch.
Recent articles
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Ofcom innovation licensing: the drone proposals and the open question
In short: Ofcom innovation licensing is under review. Ofcom opened two spectrum consultations on 16 July 2026 and wants responses to both by 5pm on 30 September 2026. One proposes drone control spectrum at 450 MHz and 5030 to 5091 MHz, and a drone detection radar licence at 16 and 24 GHz. The other asks…
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Agentic payments liability: what UK payment law answers, and what it does not
In short: agentic payments liability is largely governed by the Payment Services Regulations 2017. Whether the payer consented under regulation 67 determines whether the provider must refund under regulation 76, and regulation 75 puts the burden of proving authentication on the provider. What the regulations do not settle is the scope of a delegation exercised…
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Regulatory appeals reform: Ofcom, the FCA and a single appeals system
In short: Regulatory appeals reform is the Department for Business and Trade’s proposal, published on 17 July 2026, to move economic-regulation appeals from the CMA to the Competition Appeal Tribunal and to apply one standard across every sector: judicial review principles taking due account of the merits. That is the standard already used for Ofcom….
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The NSI Act annual report 2025-26: what it means for data infrastructure and telecoms deals
In short: The NSI Act annual report 2025-26, published 14 July 2026, shows national security screening still concentrated in defence, government supply and dual-use activity, with data infrastructure the one commercial-technology sector to feature heavily: it drew three of the nine final orders. Notifications rose 15% to 1,324, with 60 call-in notices in total. Digital-infrastructure…
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The Information Commission: the end of the ICO as a one-person regulator
In short: The Information Commission is the statutory board that will replace the Information Commissioner as the UK data protection regulator. Sections 117 to 119 of the Data (Use and Access) Act 2025 abolish the Commissioner as a corporation sole and vest its functions in a body corporate led by a chair, chief executive and…
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Calling Line Identification: how CLI is regulated in the UK
In short: Calling line identification (CLI) is the caller information carried with a telephone call. In the UK it is governed by Ofcom General Condition C6 and by regulations 10 to 13 of PECR. Ofcom’s CLI guidance sets how providers must handle it. A further change, requiring inbound +447 presentation numbers to be withheld, applies…
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Funds for liabilities: Ofcom opens an enforcement programme into code operator compliance
In short: Ofcom opened a funds for liabilities enforcement programme on 16 July 2026 into code operators’ compliance with regulation 16 of the Electronic Communications Code (Conditions and Restrictions) Regulations 2003, with immediate investigations into six operators it has reasonable grounds to believe may not have complied. The most recent annual certificate deadline was 1…
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Revised Telecommunications Security Code of Practice 2026: now issued
In short: The revised Telecommunications Security Code of Practice was issued on 14 July 2026 as version 1.1, replacing the December 2022 Code as the guidance Ofcom measures Tier 1 and Tier 2 public telecoms providers against. The underlying law is unchanged, and the genuinely new measures carry compliance timeframes running to March 2028, December…
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UK | Data Protection | EU
The EDPB AMLA guidelines: what they mean for AML information sharing and UK firms
In short: The EDPB AMLA guidelines will set out how AML information sharing partnerships work under GDPR once Article 75 of the EU AML Regulation takes effect on 10 July 2027. The EDPB and AMLA announced the joint drafting project on 1 July 2026, with a draft consultation due in the first half of 2027….
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Agentic payments: what HM Treasury is consulting on
In short: agentic payments are the subject of HM Treasury’s Financial Services AI Adoption Plan and its Modernising Payment Services Regulation consultation, both published on 14 July 2026. Recommendation 10 proposes an agentic payments trust framework and a Know Your Agent standard. The consultation asks whether the PSRs 2017 need to change and closes on…
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Section 172 good faith governs conduct as well as belief: Saxon Woods v Costa
In short: in Saxon Woods v Costa [2026] UKSC 21, the Supreme Court held that section 172 good faith governs a director’s conduct as well as honest belief. A director may challenge the board’s strategy but may not secretly frustrate it. The ruling has practical implications for nominee directors, joint ventures and industry-owned companies. By…
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Consumer Duty monitoring for payment firms: CP26/23 may narrow the scope, but not the need for evidence
In short: Consumer Duty products and services monitoring asks a payment or e-money firm to show, not just assert, that its products give customers good outcomes. The FCA’s review of 10 July 2026 found firms that could describe their processes but could not demonstrate their interventions had worked. CP26/23 may make monitoring more explicitly proportionate…
Telecoms, data protection and payments regulation lawyers
Bratby Law advises on telecoms regulation, data protection, payments regulation, transactions and digital regulation across the communications, financial services and technology sectors.
How we work
Bratby Law works with clients in three ways: as direct legal advisers on specific matters, as specialist co-counsel supporting other legal teams, and as fractional general counsel on a longer-term retained basis. Each model delivers partner-level input without delegation.
Why Choose Bratby Law?
Sector expertise
Bratby Law advises exclusively across the telecoms, data and payments sectors. That concentration means deeper knowledge of the regulatory environment, faster analysis, and advice that reflects how regulators actually behave: not how the textbook says they should.
Senior delivery
Every instruction is handled by Rob Bratby personally. With 30 years’ experience spanning a secondment to Oftel, senior in-house roles at UK telecoms operators, and partnership at international law firms, you receive the analysis directly: not through a junior team. The firm uses AI tools to extend research capacity and accelerate document review, so senior judgment is applied to more of your matter, not less.
Current appointments
Rob Bratby currently holds fractional General Counsel appointments at TOTSCo, TelXL, Core and the UK Payments Initiative. These ongoing roles keep his advice grounded in how regulated businesses run day to day.
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