Interconnection agreements, peering and access arrangements are at the heart of the UK’s electronic communications framework. Operators must interconnect networks, exchange traffic, support number portability and provide a range of wholesale access services in accordance with the General Conditions of Entitlement and, where applicable, specific SMP obligations imposed by Ofcom.

Alongside this regulated environment, operators frequently negotiate commercial, non-regulated interconnection agreements and peering covering traffic exchange, IP interconnect, transit, hosted numbering, messaging, roaming enablement and access to specialist or value-added services.

Bratby Law advises new entrants, established operators and digital infrastructure providers on the commercial and regulatory aspects of interconnection, peering and access arrangements. We help clients navigate the regulatory background, understand SMP reference offers, and negotiate balanced, commercially workable agreements.

For broader information on SMP regime obligations and wholesale access requirements, see the Telecoms Regulation, Interconnection, and Significant Market Power (SMP) pages.

Our experience

Interconnection agreements between telecoms operators are negotiated within the framework of sections 73 to 76 of the Communications Act 2003, which require providers of public electronic communications networks to negotiate interconnection on reasonable request. Where one party holds SMP, Ofcom may impose access-related conditions under section 87, including requirements to provide specific interconnection services on regulated terms. Peering arrangements between IP networks operate on a commercial basis but may engage the interconnection framework where one party provides a public ECN.

• Fixed and mobile termination and transit
• IP interconnect and SIP trunking arrangements
• Peering, settlement-free interconnect and paid-peering models
• Hosted numbering, routing and messaging services
• Mobile signalling, roaming enablement and inter-operator messaging frameworks
• Access to SMP-regulated services and reference interconnection offers
• Non-regulated commercial agreements, including bespoke multi-service interconnect
• Disputes concerning refusal to interconnect, charges, quality and non-discrimination

This combination of regulatory insight and commercial drafting expertise allows us to support clients from market entry through long-term network growth Interconnection and access arrangements may involve licensed technology, proprietary network interfaces, and software systems where IP ownership and usage rights must be clearly defined..

Key issues for clients

• • Understanding the regulatory perimeter: what is regulated, what is commercial
• • Negotiating interconnection terms in the shadow of the General Conditions
• • Assessing SMP reference offers and determining what can be negotiated
• • Pricing structures: termination, transit, porting, messaging and value-added services
• • Managing number portability, routing and database access
• • Ensuring compliance with switching and migration requirements
• • Preventing disputes through clear SLAs, escalation and governance

How we help

Interconnection and access documents

Interconnection, peering and access projects require a suite of commercial and regulatory documents governed by the Communications Act 2003 and Ofcom regulatory conditions. We advise on all documents commonly used in interconnection, peering and access projects, including:

• Network-to-network interconnection agreements (NNI)
• IP interconnect and SIP trunking terms
• Peering agreements (settlement-free and paid)
• Termination and transit service schedules
• Hosted numbering and routing agreements
• SMS/MMS interworking and messaging access
• Routing, numbering and porting
• Inter-operator operational and billing
• SLA, KPI and service-credit regimes
• Security, routing integrity and fraud-prevention frameworks

The regulatory framework for interconnection spans the Communications Act 2003, General Condition A1, and SMP conditions imposed following Ofcom market reviews. We provide guidance on all regulatory aspects of interconnection and access, including:

• General Conditions of Entitlement (GCs), especially GC A1–A3 and B1–B4
• SMP obligations: access, price controls, transparency and non-discrimination
• Requirements for reference interconnect and access offers
• Mobile and fixed termination rate regulation
• Number portability and switching obligations
• CLI authentication, spoofing prevention and fraud controls
• Dispute resolution processes and Ofcom adjudication
• Compliance with the UK Telecoms Security regime

Security, resilience and interoperability

Interconnection services must meet security obligations under the Telecommunications (Security) Act 2021 and resilience standards required by Ofcom. We help clients ensure interconnection services meet modern security and interoperability expectations:

• Packet-based interconnect security standards
• Controls for signalling, messaging and routing integrity
• Prevention of traffic pumping, fraud and abusive routing
• Network security obligations under the Telecoms Security Act
• Resilience measures, redundancy and failover design
• Incident reporting, monitoring and inter-operator coordination

How Bratby Law helps

Interconnection, peering and access transactions involve regulatory requirements under the Communications Act 2003 alongside complex commercial structuring. We advise operators, ISPs, data centres, and investors on the regulatory and commercial dimensions of interconnection, peering, and transit arrangements. Our experience spans both the regulatory framework and the commercial negotiation of access agreements.

• Negotiating and drafting interconnection agreements, peering arrangements, and transit contracts
• Advising on regulatory obligations under the Communications Act 2003 and Ofcom’s General Conditions
• Dispute resolution for interconnection and access disputes, including Ofcom referrals under section 185
• SMP access remedies compliance and network access pricing
• Internet exchange point (IXP) membership agreements and governance
• Regulatory due diligence on interconnection arrangements in M&A transactions
• Advising on Ofcom market reviews and consultations affecting wholesale access markets

Representative experience

Recent and representative matters include:

• Negotiated interconnection agreements for a national fixed-line operator with multiple wholesale customers, covering voice termination, transit and number portability across legacy and IP networks.
• Drafted peering and private interconnect agreements for a data centre operator providing cross-connect and IP exchange services to carrier and enterprise customers.
• Advised on the renegotiation of legacy interconnection terms following a network migration from TDM to all-IP, including the transition of traffic hand-off points and charging structures.
• Supported an operator in Ofcom dispute resolution proceedings concerning interconnection charging terms under sections 185 to 191 of the Communications Act 2003.
• Advised on the interconnection and access implications of a fibre network acquisition, including the assignment of existing wholesale agreements and the novation of regulated access commitments.

Related transactions pages

See also our other transactions pages:

• Mergers and Acquisitions (M&A)
• SaaS and Cloud Services
• Private equity
• Subsea cables
• MVNOs and MVNEs
• Network sharing and co-location agreements
• Digital Infrastructure Projects

Related pages

• Telecoms Regulation lawyers
• Significant Market Power (SMP) Regulation lawyers
• Technology and telecoms transactions lawyers
• Network sharing and co-location agreements lawyers
• Digital infrastructure projects lawyers
• Fractional General Counsel
• Specialist Co-counsel

The regulatory framework for interconnection continues to evolve. Ofcom periodically reviews the terms on which operators must provide access and interconnection, and changes to the General Conditions or SMP conditions can affect existing agreements. Businesses with interconnection agreements need to monitor regulatory developments and ensure their contracts remain compliant. We advise on the implications of regulatory change for existing agreements and help clients negotiate amendments or new terms when the regulatory framework shifts.

Frequently asked questions

What types of interconnection agreements are used in the UK?

Operators commonly use network-to-network interconnection (NNI) agreements, IP interconnect and SIP trunking terms, peering agreements (settlement-free and paid), transit and termination schedules, hosted numbering agreements and messaging or routing interoperability arrangements.

How does regulation affect interconnection?

Interconnection operates against the background of the General Conditions of Entitlement and, for SMP operators, specific access, non-discrimination and transparency obligations. Some termination rates are regulated. Access must be provided on reasonable request where technically and commercially feasible.

How does SMP regulation affect interconnection agreements?

SMP operators must provide reference offers, observe non-discrimination, publish charges and comply with price controls. We help clients understand which elements are negotiable.

Do operators need to interconnect under UK regulation?

Yes. The General Conditions require the negotiation of interconnection agreements on reasonable request, subject to technical feasibility and lawful limitations.

How can Bratby Law help new entrants?

We interpret SMP reference offers, explain regulatory constraints, negotiate commercial improvements, draft bespoke interconnection agreements and network access arrangements and provide guidance through implementation.