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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Financial Services and Markets Bill 2026: PSR absorbed into the FCA
In short: The Financial Services and Markets Bill 2026 provides for the abolition of the Payment Systems Regulator and the transfer of its functions to the FCA. The Bill is the legal mechanism; the substantive consolidation happens on commencement. For UK payment institutions and e-money institutions, the supervisor changes; the substance of payments regulation does…
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Framework contract termination: new PSRs 2017 regs 51 to 51D from 28 April 2026
In short: Framework contract termination by UK payment service providers operates under a new architecture from 28 April 2026. Closing a customer account opened on or after that date now requires 90 days’ written notice, sufficiently-detailed reasons and Financial Ombudsman Service signposting. Five carve-outs in regulation 51C and a fast-track regime in regulation 51D sit…
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FCA Approach Document v8: safeguarding regime consolidated, May 2026
In short: The FCA Approach Document version 8 sets the supervisory expectation for the safeguarding regime that took effect on 7 May 2026. UK PSPs and EMIs must operate segregation, daily reconciliation, monthly returns and an annual audit under CASS 15, CASS 10A, SUP 16.14A and SUP 3A. A designated senior individual is accountable for…
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Consumer Credit Act reform: FCA Handbook becomes the home for 1974 disclosure rules
In short: Consumer Credit Act reform takes the prescriptive paperwork rules for consumer credit out of the 1974 Act and puts them into the FCA Handbook. Agreement forms, pre-contract disclosure and copies-and-information duties are all in scope. HM Treasury announced this on 18 May 2026. The Financial Services and Markets Bill is the vehicle. The…
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UK | Data Protection | EU
Competition law and data protection: UK-EU convergence and where it goes next
In short: Competition law and data protection are no longer enforced as separate regimes. The EDPB and the European Commission announced joint guidance work on 28 April 2026, the latest in the EDPB’s cross-regulatory programme. The UK reached the same starting point in May 2021 through the CMA-ICO joint statement and runs the convergence through…
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ICO 2026 priorities: AI and biometrics, the Children’s Code and enforcement procedure
In short: There are three priorities for the ICO in 2026: AI and biometrics strategy, the Children’s Code and their enforcement guidance. They all share one test: can the data controller show how each decision was made, and are the safeguards proportionate to the risk? By Rob Bratby, Managing Partner, Bratby Law. Lexology Global Elite…
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FCA work programme 2026: payments, growth and financial crime
In short: FCA work programme 2026 sets out year-two delivery on four strategic priorities and confirms an annual funding requirement of £788.9m for 2026/27. The operational diary covers DPC/BNPL from 15 July 2026, cryptoasset applications from 30 September 2026 with regime go-live in October 2027, fund tokenisation guidance, captive insurance, T+1 settlement preparation, ESG ratings…
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Telecoms loyalty penalty class action: the 1 July 2026 CMC and non-parties
In short: The telecoms loyalty penalty class action against Vodafone, EE/BT, Three and O2 was certified by the Competition Appeal Tribunal on 14 November 2025 in its Certification and Limitation Judgment. Certification is procedural and does not validate the pleaded abuse theory. The post-certification CMC listed for 1 July 2026 will address procedural directions. Non-defendant…
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Ofcom Plan of Work 2026/27: the compliance calendar for telecoms and online services operators
In short: Ofcom Plan of Work 2026/27, published on 20 March 2026, maps the year’s regulatory deliverables for telecoms and online services operators. Key items: the connectivity work programme in spring 2026, the Online Safety Act categorisation register and additional duties consultation in July 2026, four clustered spectrum decisions, and UK preparations for WRC-27. By…
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DMA in-app payments: EU and UK pursue the same end through different machinery
In short: DMA in-app payments parity is here to stay. If you sell or process payments inside iPhone or Android apps, the EU rules forcing platforms to allow alternative wallets are locked in. The Commission confirmed that on 28 April 2026. In the UK, Apple and Google signed CMA commitments on 1 April 2026 and…
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King’s Speech 2026: four Bills to watch
In short: The King’s Speech 2026 puts four Bills on the parliamentary timetable that reshape the regulator architecture for payments firms, identity providers, data controllers and acquirers of regulated businesses. Three land directly: the Enhancing Financial Services Bill absorbs the Payment Systems Regulator into the FCA, the Digital Access to Services Bill creates a statutory…
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Telecoms security incident reporting: Ofcom’s section 105Y consultation
In short: Telecoms security incident reporting could be recalibrated. Ofcom’s draft statement of policy under section 105Y of the Communications Act 2003, published on 12 May 2026 and out for consultation until 4 August 2026, proposes cell site thresholds for mobile reporting, a single-site trigger for rural areas, and a new severity taxonomy of critical,…
Telecoms, data protection and payments regulation lawyers
Bratby Law advises on telecoms regulation, data protection, payments regulation and transactions across the communications, financial services and technology sectors.
How we work
Bratby Law works with clients in three ways: as direct legal advisors 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 on telecoms regulation, data protection, and payments regulation. 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 Oftel, senior in-house roles at network 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.
Unique perspective
Rob Bratby has sat on all three sides of the regulatory table: as a regulator at Oftel, as General Counsel at major operators, and as external counsel. That inside-out perspective informs every piece of advice. He currently holds fractional General Counsel appointments at TOTSCo, TelXL and Core, with further engagement in the payments sector.
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