Telecoms | UK Regulatory Outlook January 2026

Ofcom Plan of Works for 2026: key themes for communications providers

On 5 December 2025, Ofcom published its proposed Plan of Works for 2026/2027. Although the final plan will not be released until March 2026, the proposal provides a great insight into the areas that it will be focusing on in the coming year. They key points of interest for communications providers are:

• Telecoms Access Review – The Telecoms Access Review aims to future-proof the UK’s broadband infrastructure by promoting competition and investment in gigabit-capable networks, improving services and choice for consumers. Ofcom will publish a new regulatory framework in March 2026, covering key access and connectivity markets for the period April 2026 to March 2031, and will monitor implementation and finalise rules to support copper retirement in 2026/27.
• Impact of AI in telecoms – In winter 2025, Ofcom invited contributions on how AI could affect the experience of residential and business broadband, mobile and pay TV customers. Ofcom's focus on AI will continue into 2026/27, including a further publication setting out any next steps in this area.
• Migration from legacy solutions – 2026 is a key year for the transition away from legacy services as preparations continue for the PSTN switch off in January 2027. Additionally, as 3G switch-off nears completion, Ofcom will switch focus to preparations for 2G switch-off and ensuring customers, particularly vulnerable users, are supported and protected through these changes.
• Meeting demand for spectrum – Ofcom will pursue a spectrum strategy focused on four areas: updating authorisation frameworks to meet growing space-related demand (including for MSS bands and terminals); releasing and pricing spectrum for wireless broadband (notably the 1.4 GHz band), exploring spectrum sharing and defragmentation; launching a multi‑year cross‑sector review of sub‑1 GHz use (including digital terrestrial television, mobile and critical infrastructure) to inform future policy; and driving more efficient spectrum use through sharing, improved access to the 6 GHz band (including higher‑power Wi‑Fi and new low‑power use cases such as XR), and closer work with defence and other public sector users.
• Enhancement of consumer supervision – Ofcom intends to further strengthen its consumer supervision programme to ensure that consumer protection measures and voluntary initiatives are properly implemented and deliver positive outcomes, including for vulnerable consumers. This will be done by increasing intelligence-gathering, monitoring and stakeholder engagement to identify and address policy issues, and they will also be reviewing the impact of the January 2025 changes requiring providers to state in‑contract price rises upfront in pounds and pence.

What this means for 2026: Communications providers should expect a more hands‑on Ofcom, reviewing how networks are secured, legacy services retired, prices communicated and spectrum used, with greater readiness to intervene where outcomes for consumers or competition fall short.

Practical steps for communications providers: In January, Ofcom will be holding events in Cardiff, London, Edinburgh and Belfast where providers will be able to hear more about the proposals and have a chance to offer their views. Providers should submit written responses no later than 5 February 2026.

Cyber Security and Resilience Bill: implications for telecoms

The government’s proposed Cyber Security and Resilience Bill signals a step-up in statutory resilience and incident reporting duties across critical infrastructure. For telecoms, expect strengthened expectations that sit alongside the Telecommunications (Security) Act, particularly around supply chain dependency (for example, cloud/managed services), operational resilience planning and consistent incident reporting.

What this means for 2026: The direction of travel is towards clearer, more enforceable resilience baselines and improved cross-sector coordination.

Practical steps for communications providers: Providers should review existing TSA programmes for gaps likely to be probed under the bill (such as business continuity in extended outages, third‑party assurance).

For a fuller cross-sector analysis, see: Cyber security | UK Regulatory Outlook November 2025.

Ofcom compliance programme into access to emergency services

Ofcom has launched an own‑initiative compliance programme to test how providers meet General Conditions on access to 999/112 (including reliability during power cuts and across IP voice and fibre migration).

Key focus areas include the adequacy of risk assessments, resilience measures (for example, battery back-up, mobile/alternative routing) and clear customer communications, especially for vulnerable users and those moving to digital voice. As highlighted in recent market commentary, this is not purely a technical compliance check: providers should be able to evidence end‑to‑end operational resilience, escalation and contingency plans, and that sales and migration scripts do not leave customers without a viable route to 999/112.

What this means for 2026: Communications providers should expect closer regulatory scrutiny of their emergency call arrangements, with Ofcom using its formal powers to check that providers have robust measures in place to ensure uninterrupted access to 999/112 and accurate caller location information, and to take targeted enforcement action (including potential financial penalties) where these General Conditions are not being met.

Practical steps for communications providers: Refresh emergency call risk assessments; validate power‑loss scenarios across product sets; stress‑test communications and support for vulnerable customers; and document mitigations and decision‑making.

Consumer pricing and protections: DSIT–Ofcom engagement and potential regulatory change

Earlier this year O2 decided to increase mid-contract price rises beyond what had been indicated to customers when they signed up. While they remained in compliance with their obligations under the General Conditions by providing customers with the necessary right of exit notices, Ofcom stated that it believed this went against "the spirit" of the rules. This subsequently triggered a series of correspondence with the government including:

• A letter from DSIT to Ofcom asking for a review of how easy it is for customers to switch providers when served with a right of exit notice;
• A response from Ofcom to DSIT expressing concern about companies introducing "mid-contract price rises in such a way that it risked undermining that clarity and certainty for consumers at the point of signing up to a contract"; and
• A letter from the chancellor and DSIT to Ofcom asking that it produce an interim review of the impact of the changes to mid-contract price rises introduced in January by spring 2026 with a full review due in 2027.

What this means for 2026: Communications providers should expect greater scrutiny of practices around mid-contract price rises, especially where providing services to consumers and small business customers. Ofcom consultations may look to further tighten obligations relating to transparency, right of exit notices and disincentives to switch.

Practical steps for communications providers: Providers should ensure that their terms and conditions, pre-contract documentation and customer journeys are fully compliant with the updated rules introduced in January 2025.

Launch of satellite direct to device services in mobile spectrum bands

Ofcom’s new authorisation framework for satellite direct‑to‑device (D2D) in mobile spectrum bands allows mobile network operators (MNOs) to use their existing sub‑3 GHz holdings (FDD and SDL) to deliver satellite connectivity to standard handsets, with device use covered by new licence‑exemption regulations. D2D will be enabled via variations to MNO wireless telegraphy licences, backed by detailed technical conditions (including PFD limits, radar protection in 2.6 GHz and non‑interference/non‑protection status) and coordination requirements, with a review of the framework planned after WRC‑27.

What this could mean for 2026: Ofcom’s satellite direct‑to‑device framework could signal a 2026/27 inflection point where terrestrial and satellite mobile begin to converge in the mass‑market handset ecosystem, paving the way for mainstream “always‑on” coverage propositions, new MNO–satellite partnership models and a shift in consumer expectations towards satellite‑enabled connectivity as a standard feature rather than a niche add‑on.

Practical steps for communications providers: UK MNOs and satellite partners can now move from trials to commercial D2D propositions, but only where they secure licence variations, demonstrate compliance with Ofcom’s technical and coordination conditions, and navigate cross‑border and radar‑related constraints, making early regulatory engagement a critical part of D2D business planning.

Implementation of new ADR rules

In July 2025, Ofcom published its statement on updating its rules on alternative dispute resolution (ADR). The key change set out under this statement was the reduction in the maximum timeframe for automatic access to ADR from eight to six weeks. This change will enter into force on 8 April 2026.

What this means for 2026: Communications providers should expect closer scrutiny of whether complaints are progressed and resolved within the six‑week window and how consistently consumers are signposted to ADR.

Practical steps for communications providers: Before the 8 April deadline, providers should update both customer-facing complaints policies and internal complaints-handling procedures, ensuring alignment with the new six-week threshold.