Key takeaways, 2026
- Roaming charges returned: all four UK networks reinstated EU surcharges between 2021 and 2022. Typical 2026 cost: £2 to £3 a day.
- Data adequacy renewed to 2031: EU-UK personal data flows continue without SCCs until at least mid-2031.
- €212m EU broadband funding lost: replaced by UK's £5bn Project Gigabit, with FTTP coverage now at 78% of UK premises.
- 2025-26 EU-UK Reset: veterinary deal, professional qualifications and energy trading agreed ; no return to single market or customs union.
£2-£3
EU roaming/day
Consumer-tier surcharge, 2026.
2031
Adequacy until
EU-UK data flows secured.
€212m
EU funding lost
Connecting Europe Facility.
78%
FTTP coverage
UK premises, May 2026.
Where we actually are, five years in
The UK formally left the EU on 31 January 2020 and the transition period closed on 31 December 2020. Since then, the EU-UK relationship has been governed by the Trade and Cooperation Agreement (TCA), a zero-tariff, zero-quota free trade agreement that nonetheless re-introduced customs declarations, regulatory checks and a hard border for services. The TCA is reviewed every five years ; the first review concluded in 2026 with no major reopening.
For broadband, telecoms and digital services specifically, the post-Brexit picture in 2026 is much narrower than was feared in 2019. The UK domestic market is regulated by Ofcom and supplied by UK-owned infrastructure, so the day-to-day cost of a business broadband line is unaffected. The pinch points are at the edges: roaming when you travel, data flows when you process EU personal data, and access to EU funding programmes that no longer include the UK.
Roaming charges: the most visible change
From 15 June 2017 until 31 December 2020, "Roam Like at Home" let UK customers use their domestic minutes, texts and data anywhere in the EU at no extra cost. That right disappeared on 1 January 2021. Despite repeated statements from each of the four major UK networks that they had "no plans" to reintroduce surcharges, all four did so by mid-2022.
| Network | Reintroduced surcharges | Consumer-tier cost | Inclusive on business plans |
|---|---|---|---|
| EE | March 2022 | £2.59/day "Roam Abroad Pass" | Smart and Business plans |
| Vodafone | January 2022 | £2.42/day in Zone B | Together Pro, Business plans |
| Three | May 2022 | £2/day "Go Roam" | Business plans, some legacy plans |
| O2 (Virgin Media O2) | August 2021 | Fair-use limit on data above 25 GB | Business plans |
Source: provider tariff pages, accessed May 2026. The picture changes frequently ; check current terms before each trip.
Data flows, UK GDPR and the adequacy renewal
The single most important post-Brexit issue for UK digital businesses was always going to be data. In 2021 the European Commission granted the UK an adequacy decision, the legal mechanism that lets EU personal data flow to a third country without additional safeguards. The original decision had a four-year sunset clause, expiring in June 2025.
In 2025, after a year of review covering the UK Data Protection and Digital Information Bill (and its 2025 successor, the Data (Use and Access) Act), the Commission renewed the adequacy decision for a further six years to mid-2031. The UK kept enough of the GDPR substance to satisfy Brussels, while introducing limited divergence on cookies, automated decision-making and AI training data. The renewal is the single most consequential piece of digital policy of the past two years for UK SaaS exporters: it preserves billions of pounds of EU-UK personal-data flows.
What still works the same
- ▸EU-UK personal data flows continue freely (adequacy to 2031)
- ▸UK GDPR substance still mirrors EU GDPR
- ▸ICO remains the supervisory authority
- ▸Cyber Essentials and ISO 27001 unaffected
What now diverges
- ▸EU AI Act vs. UK's principles-based AI framework
- ▸UK relaxed some cookie consent rules in 2025
- ▸Art. 27 EU Representative required if selling to EU
- ▸DSA does not apply to UK ; Online Safety Act does instead
Broadband investment: from EU funds to Project Gigabit
Before Brexit, UK broadband infrastructure benefited from the EU's Connecting Europe Facility and structural funds. Estimates of foregone allocation vary, but the most widely cited figure is around €212 million over the 2021 to 2027 programming period. The Treasury replaced that, at much larger scale, with Project Gigabit: a £5 billion UK-government programme to subsidise full-fibre rollout in commercially unviable rural areas.
As of May 2026, Project Gigabit has signed contracts covering 1.8 million premises with Openreach, CityFibre and a long tail of altnets. Combined with the commercial rollout, Openreach FTTP now reaches 78% of UK premises, with the government 99% target now slipped to 2032 from the original 2030 pledge. The practical impact for SMEs: full fibre is widely available, with a clear funding line in place even if your premises is rural.
Digital services trade under the TCA
UK-EU trade in digital services is governed by the Digital Trade chapter of the TCA. The chapter prohibits data localisation requirements between the parties, guarantees no customs duties on electronic transmissions, and provides for cooperation on cybersecurity and online consumer protection. What it does not do is give UK firms passporting rights into the EU single market for digital services.
In practice this means a UK SaaS company selling into the EU faces three frictions that did not exist before 2021: (1) VAT registration in the EU via the OSS scheme if selling B2C above €10,000 a year, (2) an Art. 27 GDPR representative in the EU, and (3) compliance with the EU AI Act if the product uses AI affecting EU users (since the Act's general-purpose AI obligations went live in August 2025). None of these are deal-breakers, but they add £2,000 to £15,000 a year of administrative overhead for a typical exporter.
The Windsor Framework and Northern Ireland
For Northern Ireland businesses, the 2023 Windsor Framework replaced the original Northern Ireland Protocol and is now embedded in the day-to-day operation of cross-border trade. The Framework created a green lane for goods staying in the UK internal market and a red lane for goods at risk of moving onward into the EU, dramatically simplifying paperwork for NI-based retailers and wholesalers.
For broadband, telecoms and digital services the Framework has effectively no impact: those services trade domestically across the UK and are governed by Ofcom and UK GDPR identically in NI, England, Scotland and Wales. NI businesses retain the EU GDPR's application to the extent they target EU customers, the same dual-regime situation as a business in Manchester.
The 2025 to 2026 EU-UK Reset: what changed and what did not
The Labour government elected in July 2024 opened a new negotiation track, branded the EU-UK Reset, focused on specific frictions without revisiting the headline questions of single-market or customs-union membership. By May 2026, the Reset has delivered three concrete agreements:
- A Sanitary and Phytosanitary (SPS) agreement easing food-product checks, signed in late 2025, that cuts paperwork for food and drink exporters ;
- A Mutual Recognition of Professional Qualifications framework for engineers, architects, accountants and certain healthcare professionals ;
- Closer cooperation on energy trading and emissions trading scheme linkage, paving the way for full ETS linking from 2027.
For broadband, telecoms and digital services specifically, the Reset has so far avoided regulatory re-alignment. The UK's Online Safety Act, in force since 2023 and enforced since 2024, remains separate from the EU's Digital Services Act. The UK's principles-based AI approach remains separate from the EU AI Act. The Reset has signalled willingness to cooperate on cyber security and infrastructure resilience without committing to harmonisation.
Practical checklist for UK SMEs in 2026
If you read only one section, read this one. Five concrete things every UK SME should check in 2026 to keep its post-Brexit house in order.
Audit your business mobile plans
If anyone travels to the EU monthly, move them to a business tariff with inclusive EU roaming. Typical saving: £50 to £200 per traveller per year.
Confirm your data flows
Adequacy runs to 2031 ; no SCCs needed for EU-UK personal data. If you also send data to the US, the EU-US Data Privacy Framework still applies via the UK extension.
Appoint an Art. 27 EU rep
If you offer services to EU residents, you need a representative in the EU under the EU GDPR. Specialist firms provide this for £200 to £1,500 a year.
Frequently asked questions
Not directly. The UK domestic broadband market is regulated by Ofcom and supplied predominantly by UK-owned infrastructure (Openreach, Virgin Media O2, the altnets), so Brexit had no first-order effect on monthly broadband bills. The indirect impact came through the loss of access to EU broadband investment funds: the UK forfeited around €212 million of the Connecting Europe Facility allocation. Project Gigabit, the UK government scheme, replaced that funding with £5 billion of domestic money, so rollout has continued.
Yes, in most cases. The EU "Roam Like at Home" rule no longer applies to UK SIMs since 1 January 2021. All four major UK networks reintroduced roaming surcharges between 2021 and 2022 (Vodafone, EE, Three, O2). In 2026 the typical structure is £2 to £3 per day for an EU roaming pass on consumer plans, while business plans and premium tariffs (BT Halo, EE Smart, Vodafone Together Pro) frequently include EU-inclusive minutes, texts and data. Check each line individually before any business trip.
Yes, broadly. The UK GDPR (the domesticated version of EU GDPR) and the Data Protection Act 2018 still mirror EU GDPR on substance. The UK data adequacy decision from the European Commission, originally due to lapse in June 2025, was renewed in 2025 for a further six years to mid-2031. This means personal data can continue to flow freely from the EU to the UK without Standard Contractual Clauses. The UK Data (Use and Access) Act 2025 introduced some divergence on cookies and AI training data, but stopped short of triggering the EU to revoke adequacy.
The 2023 Windsor Framework, which superseded the original Northern Ireland Protocol, is operational and stable in 2026. For broadband and telecoms it has effectively no impact, since the services traded in NI are domestic UK and not goods crossing the Irish Sea. For NI businesses selling physical goods into Great Britain or the EU, the green-lane / red-lane system applies and most SMEs use the UK Internal Market Scheme to avoid customs declarations. UK GDPR applies in Northern Ireland identically to England, Scotland and Wales.
The 2025 to 2026 "EU-UK Reset" is the negotiation track opened by the UK Labour government to repair specific parts of the post-Brexit relationship. As of May 2026, agreements have been reached on a veterinary (SPS) deal easing food-product checks, on mutual recognition of certain professional qualifications, and on closer cooperation on energy trading and emissions trading linking. There is no agreement returning the UK to the single market or customs union. Telecoms divergence (AI Act vs. UK AI framework, online safety, data governance) is being addressed bilaterally rather than via re-alignment.
If your UK business processes personal data of individuals located in the EU or EEA, you must appoint a European Representative under Article 27 of the EU GDPR (this is the EU regulation, separate from the UK one). The reverse also applies: EU businesses targeting UK residents must appoint a UK representative under Article 27 of the UK GDPR. Specialist firms provide this representation for £200 to £1,500 a year. The threshold is "offering goods or services to" or "monitoring the behaviour of" individuals in the relevant bloc.