Upper 6 GHz Spectrum: Ofcom’s High-Density Area Consultation
In short: Ofcom’s consultation on how “high-density areas” are defined for Upper 6 GHz (6425–7125 MHz) subnational mobile licences closes on 6 July 2026. The definitions decide where MNOs can deploy new mid-band 5G capacity and what Wi-Fi equipment enterprise operators can run under licence exemption. Final statement expected by the end of 2026.
Ofcom’s technical consultation on how “high-density areas” should be defined for Upper 6 GHz spectrum mobile licences was published on 13 April 2026 and closes at 5pm on 6 July 2026. It is the operational follow-on to the January 2026 statement confirming that the 6425 to 7125 MHz band will be shared between low-power indoor Wi-Fi and outdoor mobile services. For mobile network operators the definitions decide where new mid-band 5G capacity can be deployed. For enterprise campus operators, building owners and private network integrators, they decide what equipment can be run without a licence.
Regulatory background to Upper 6 GHz spectrum sharing
Ofcom’s authority over UK spectrum derives from the Wireless Telegraphy Act 2006 (WTA 2006) and Part 2 of the Communications Act 2003 (CA 2003). Section 8 WTA 2006 makes it an offence to establish or use wireless telegraphy apparatus without a licence, unless the apparatus is exempted by regulations made under section 8(3). Wi-Fi devices operate under such an exemption. Mobile networks operate under individual licences granted under section 8(1). Ofcom’s general duty under section 3 CA 2003 includes securing the optimal use of the electromagnetic spectrum.
The Upper 6 GHz band (6425–7125 MHz) has historically been used by fixed links, point-to-point microwave and satellite earth stations. In January 2026 Ofcom published its statement confirming that the band will be opened to new uses on a shared basis: low-power indoor Wi-Fi across the full 700 MHz, and outdoor mobile services on a subnational basis in the upper 540 MHz. The UK is the first country in Europe to adopt this split-priority model. The current consultation, which closes on 6 July 2026, fills in the operational detail: how the geographic footprint of mobile priority is defined, and what that means for the Wi-Fi equipment authorised to use the same frequencies elsewhere.
Analysis of the Upper 6 GHz split-priority framework
The January 2026 statement fixed the core structure. The lower 160 MHz (6425–6585 MHz) has Wi-Fi priority: standard-power Wi-Fi 6E and Wi-Fi 7 devices can operate under licence exemption. The upper 540 MHz (6585–7125 MHz) has mobile priority in high-density areas, subject to subnational mobile licences awarded to MNOs. Outside those areas, higher-power Wi-Fi under Automated Frequency Coordination (AFC) control can also use the upper sub-band, giving way where and when mobile services are deployed.
AFC is a database-driven control system. A Wi-Fi access point seeking to transmit at higher power in the upper sub-band queries the AFC database with its location. The database returns the frequencies and power levels available at that point, block-listing channels that are reserved for mobile use in nearby high-density areas. The access point then operates only within the permitted envelope. The system is designed to protect mobile priority in near real time, without requiring individual coordination with each MNO.
The current consultation asks three questions. First, what geographic footprint should define a high-density area? Ofcom has published an illustrative list of 88 locations, broadly urban centres and major transport hubs. The question is whether those boundaries should follow local authority areas, postcode sectors or purpose-drawn polygons. Second, what interference margins and AFC behaviour should apply at the edges of those areas, both spatially and during temporary events? Third, how should the mobile licences themselves be structured? Subnational awards are unusual in UK mobile spectrum policy, which has historically used national licences. Ofcom has indicated it will use an approach similar to the mmWave award for defining the geographic footprint. Subnational structure affects auction design, spectrum trading rights and coverage obligations.
| Feature | Lower 160 MHz (6425–6585 MHz) | Upper 540 MHz (6585–7125 MHz) |
|---|---|---|
| Priority | Wi-Fi | Mobile (in high-density areas) |
| Typical device | Low-power indoor Wi-Fi 6E / Wi-Fi 7 | Outdoor 5G MNO cell; higher-power Wi-Fi under AFC outside high-density areas |
| Licensing | Licence-exempt under WTA 2006 s.8(3) | Subnational mobile licence under WTA 2006 s.8(1); licence-exempt under AFC outside high-density areas |
| Control mechanism | Indoor power limits | AFC database; mobile-priority footprint |
Commercial and operational implications for MNOs and enterprise operators
For MNOs, the consultation decides the addressable footprint of a new mid-band capacity layer. The 5G mid-band holdings of each operator (n77 and n78 in 3.4–3.8 GHz, with some 3.8–4.2 GHz) are already deployed. Upper 6 GHz spectrum is the next tranche. The subnational licence design means operators will not bid for a nationwide 540 MHz allocation. They will need to assess where 5G demand justifies a high-density mobile licence, what the auction or comparative selection process looks like in each geography, and how the new licence interacts with existing spectrum holdings and network-sharing arrangements in the same locations. For operators in transaction processes, this feeds directly into spectrum portfolio valuation and into regulatory due diligence on target MNOs and tower platforms.
For enterprise campus operators, building owners and private 5G integrators, the definitions determine which deployments proceed under licence exemption and which require an Ofcom award. A logistics hub or hospital campus deploying Wi-Fi 7 under AFC control will want predictable access to the upper 540 MHz outside high-density areas. A private 5G integrator serving the same sites will want predictable mobile priority where enterprise demand is concentrated. If you are assessing whether a planned enterprise deployment falls inside or outside licensed spectrum, see our guidance on regulatory perimeter and market entry and on telecoms product launch advice.
For investors in UK digital infrastructure, the consultation is due diligence territory. A target operator’s Upper 6 GHz footprint is part of spectrum portfolio value. A fibre or tower platform serving sites in candidate high-density areas will see increased mid-band capacity demand as licences are awarded. Our telecoms regulation practice advises acquirers and sellers on these points.
Parallel AFC consultation
AFC governance is being addressed in a separate, parallel consultation: Enabling automated frequency coordination (AFC) in the 6 GHz band. Ofcom does not intend to operate an AFC database itself; its position is that the function is best provided by industry, with multiple AFC service providers competing. Service providers will go through a three-phase registration process with Ofcom and must comply with technical calculations designed to protect incumbent users in the band. Responses on the high-density areas consultation should take that parallel framework as given; responses on AFC operator registration, database accuracy and availability standards should be directed at the AFC consultation.
Links
Ofcom high-density areas consultation: Expanding access to the 6 GHz band – approach to future mobile use and incumbent users. Parallel AFC consultation: Enabling automated frequency coordination (AFC) in the 6 GHz band. January 2026 statement: Ofcom pioneers sharing of upper 6 GHz spectrum. Primary legislation: Wireless Telegraphy Act 2006 and Communications Act 2003 Part 2.
How Bratby Law can help
Bratby Law advises MNOs, enterprise operators and digital infrastructure investors on UK spectrum policy, General Conditions compliance and regulatory due diligence. To discuss the Upper 6 GHz consultation or its implications for your deployment or transaction, contact Rob Bratby at Bratby Law.
