
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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CMA markets remedies review: 23 removals and what replaces them
In short: the CMA markets remedies review covers 33 market investigation remedies made between 1987 and 2017. On 12 August 2026 the Competition and Markets Authority provisionally decided to remove 23 in full, remove 4 in part and retain 6. Representations close at 5pm on 11 September 2026, with a final decision expected in October…
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ICO reprimand for cyber security failings: what Article 32 actually requires
In short: The ICO’s reprimand for cyber security failings, issued to ACRO Criminal Records Office on 7 August 2026, turns on named ownership of patch management and monitoring of security alerts under UK GDPR Article 32. A hacker held access to ACRO’s website for seven months, exposing sensitive data for up to 10,920 people. The…
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FCA high-growth firms: what the 2026 review repeats from 2023
In short: the FCA high-growth firms review, published on 10 August 2026, covers a pilot with 15 asset management, wealth management and payments firms. Four of its findings repeat the FCA’s 2023 fast-growing firms review. A payment institution’s obligations are unchanged: regulation 6(6) of the Payment Services Regulations 2017 still requires governance proportionate to its…
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EU | Telecoms Regulation | UK
Digital Networks Act copper switch-off: the EU mandate and the UK route
In short: Digital Networks Act copper switch-off provisions would oblige every EU Member State to mandate copper retirement by binding legal act, in all switch-off areas by 31 December 2035. The first lists of qualifying areas are due by 30 June 2029, which is the operative date. The UK has no equivalent statute and is…
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Bank of England AI Consortium: the June 2026 minutes and UK AI rules already in force
In short: the Bank of England AI Consortium published minutes of its fourth quarterly meeting on 5 August 2026, covering the meeting held on 3 June 2026. Four workshops reported on explainability, AI-accelerated contagion, concentration risk and AI edge cases. Under its terms of reference the Consortium has no decision-making capacity, so nothing in the…
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CMA Microsoft investigation: subscription enforcement before the DMCCA regime commences
In short: In the CMA Microsoft investigation, opened on 27 July 2026, the CMA is examining whether Microsoft 365 Personal and Family subscribers received clear information before plans that added Copilot renewed at higher prices. The CMA is applying consumer protection law already in force; the government anticipates that the DMCCA subscription contracts regime will…
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Specific Direction 17: what the Confirmation of Payee consultation proposes
Specific Direction 17 expires on 1 November 2026. The PSR’s CP26/2 consultation proposes to remove the expiry date and seeks views on directing voluntary CoP providers as a new Group 3.
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AI Office enforcement: the AI Act’s new powers over platform AI
In short: AI Office enforcement covers a company only where it built the AI system on its own general-purpose AI model, or where the system operates inside a platform designated under the Digital Services Act. Every other business remains subject to national regulation. The difference matters, because the AI Office can enter and seal premises…
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Data Protection | EU | UK
GPAI enforcement: a year of duties, and now the power to fine
In short: GPAI enforcement began on 2 August 2026. If you build a product on someone else’s AI model, the duties in Articles 53 to 55 of the EU AI Act apply to that supplier and not to you. They still matter, because they entitle you to information from your supplier, and because very substantial…
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Card scheme and processing fees: the PSR compliance clock has started
The PSR gave Specific Directions 22 and 23 to Mastercard and Visa on 30 July 2026. Pricing governance obligations start on 30 November 2026 and the information requirements on 30 July 2027.
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Payments Regulation | EU | UK
Payment services perimeter: the money remittance question Betaal Garant leaves open
The Court of Justice in Betaal Garant (C-51/25) decided the credit transfer question and nothing else. Money remittance, defined more widely in regulation 2(1) of the PSRs 2017, is where a UK analysis now has to go.
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Radio selection services: designating Alexa, Siri and Google Assistant without a market power test
In short: Radio selection services are voice-activated services that let a user pick a UK radio station and play it by spoken command. The Department for Culture, Media and Sport (DCMS) proposed on 15 July 2026 to designate Amazon’s Alexa, Google Assistant and Apple’s Siri under section 362BB of the Communications Act 2003. The consultation…
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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