Ofcom’s Plan of Work and Three-Year Plan: Key Updates

Ofcom has published both its Plan of Work for 2025-26 and its Three-Year Plan 2025-28. In line with the Government’s growth mission, the regulator has committed to an approach to regulation that fosters growth, encourages competition, and achieves sustainable outcomes for both consumers and the economy.

Below, techUK sets out key updates and areas of interest to members on both of these documents.

1. Plan of Work 2025-26

Key priorities

The Plan of Work sets out Ofcom’s priorities for the financial year ahead and how they plan to deliver on these. The priorities have been divided into four categories, each of whom contains several proposed actions.

In-Depth Look: ‘Living a Safer Life Online’ & ‘Enabling Wireless in the UK Economy’ chapters

Within each of these priorities, the Plan of Work sets out Ofcom’s major projects and programmes to deliver these, alongside those which are already ongoing. Naturally, the “living a safer life online” section is a particularly important priority for techUK members, and the year ahead has several important milestones for the implementation of the Online Safety Act, including:

• The commencement of the fees regime, whereby industry fees will fund the cost of regulation of online services, with invoices likely to be issued for the 2026/27 financial year. In addition, in July 2025, the regulator intends to publish a report on options to improve researchers’ access to data.
• In Summer 2025, Ofcom intends for the register of categorised services to be completed, allowing them to start establishing the rules for categorised services. Once the register is published, they will start issuing draft transparency notices, with the expectation that the first transparency reports mandated by these notices will be published by services late in 2025.
• By early 2026, Ofcom intends to publish draft Codes of Practice and draft guidance regarding additional duties on categorised services.
• The enforcement of the Protection of Children Code of Practice and, in late 2025, the finalising of the guidance on women and girls’ online safety. Beyond this, Ofcom will start building on these Codes, beginning with a consultation on additional measures to protect users in Spring 2025.
• Ofcom are preparing for early enforcement action in cases where they identify non-compliance causing serious harm to UK users.
•  A programme of work dedicated to helping all service providers in scope of the regime to understand and fulfil their new duties and obligations. This includes digital tools to help services providers to conduct risk assessments and identify which Codes’ measures applies to them.
• Ofcom has committed to continuing to work closely both with domestic and international regulators, whether that be through the DRCF, the Global Online Safety Regulators Network, and their coordination agreement with the European Commission.
• The development of the Act’s super-complaints process, which will enable eligible entities to highlight systemic issues that arise across services.

The following chapter, ‘enabling wireless in the UK economy’, is focused on ensuring that spectrum remains an effective enabler for wireless communication for all people, businesses and sectors. This is an ambition Ofcom seeks to fulfil through three primary areas of focus:

• International engagement on spectrum management, in order to ensure that consumers can benefit from international technological innovation and “harmonised equipment ecosystems”.
• Supporting innovation through timely spectrum availability and greater sharing. At present, Ofcom is preparing to award the mmWave (26 and 40 GHz) spectrum, designing rules for the award of 1.4 GHz spectrum and confirming their approach in making more spectrum available in the 6 GHz band for additional services. In addition to this, the regulator commits to consulting on making more spectrum available to support increased capacity for satellite services. Ofcom will work with the Government to ensure spectrum availability for critical national infrastructure.
• Sustained efficiency through advanced spectrum management capabilities. Ofcom will enhance its licensing platform to deliver greater automation, improve user experience and increase spectrum efficiency.

On Ofcom’s new Growth Duty, they note that, where appropriate, they will work to incorporate the impact of their regulatory activity on economic growth into impact assessments. The Plan also identifies three specific areas of alignment between this new duty and their existing remit:

1. Promoting competition in relevant markets.
2. Encouraging investment and innovation in relevant markets.
3. Encouraging the availability and use of high speed data transfer services throughout the UK.

techUK’s Response to Ofcom’s Proposed Plan of Work (2025-26)

Ofcom previously consulted on its proposed Plan of Work, which techUK submitted a response to. Recommendations included the provision of more evidence to illustrate the process behind decision making on online safety, ensuring the right regulatory framework is in place to enable the continued rollout of gigabit-capable broadband, and improving communication with the Government and industry on reducing fraud.

Beyond this, we proposed work to promote educational initiatives, such as the Making Sense of Media workstream, to address the critical shortage of digital skills in the UK, and requested further information as to how Ofcom will implement their new Growth Duty across their workstreams.

Our insight on the proposed Plan of Work can be accessed here.

2. Three-Year Plan 2025-28

The Three-Year Plan establishes Ofcom’s longer-term ambitions and priorities. This Plan accounts for the primary drivers of change across the sectors within its remit, which it has identified as changing consumer needs, the impact of digital transformation on businesses, and new technologies.

Ofcom assure that good regulation and economic growth “go hand in hand”, pledging to continue to support innovation and investment in new networks and services. Over these three years, Ofcom will therefore continue to:

• Promote investment in broadband and mobile.
• Use spectrum to power innovation across the economy.
• Support the UK’s creative industries.
• Help small businesses.

In the three-year plan, their priorities remain: internet and post we can rely on; media we trust and value; safer life online; and enabling wireless in the UK economy. Longer-term actions to achieve these aims include:

• Promoting competition and investment in gigabit-capable broadband for 2026-31.
• Monitoring and enforcing commitments established as part of the Vodafone/Three merger, which should improve coverage over an eight-year period.
• Continuing to use their horizon-scanning programme and data innovation centre to track emerging technologies and trends.
• Providing a Digital Support Service to help small low-risk businesses to comply with the new online safety regime.
• Continuing to modernise their spectrum management systems to improve their operational efficiency, automate licensing processes, and improve the information provided to licensees.

techUK continues engaging on key regulatory areas of work and look forward to supporting the regulators as they implement their Plans of Work.

Daniella Bennett Remington

Policy Manager - Digital Regulation, techUK

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Daniella Bennett Remington

Policy Manager - Digital Regulation, techUK

Dani joined techUK in February 2025 as a Policy Manager in the Digital Regulation team.

Prior to this, Dani worked in political monitoring where she was a consultant for Digital, Culture, Media and Sport. In this role, she developed a strong understanding of parliamentary procedure, closely following all of the major developments in the tech centre and working with several key stakeholders and regulators.  

She has an undergraduate degree in History from the University of Bristol and an MPhil in Modern European History from the University of Cambridge.

Outside of tech, Dani has a strong interest in addiction policy, particularly towards drugs, having written her dissertation on the topic as well as several subsequent research projects. In her spare time, she enjoys cooking and following all things motoring, whether that be F1, MotoGP or Formula E.

Email:

[email protected]

Twitter:

@danibenrem

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https://www.linkedin.com/in/daniella-bennett-remington/