Dear AFC team,
Please find below the FCS’ response to your consultation: Enabling automated frequency coordination (AFC) in the 6 GHz band. Our response is non-confidential, and we are happy for it to appear on the Ofcom website. It would be very helpful if you could please acknowledge receipt of this response.
The FCS represents companies which provide professional communications solutions to business users. Our members deliver telecommunications services via mobile and fixed line telephony networks, broadband, satellite, wi-fi and business radio. Our members’ customers range from SMEs, home-workers and micro-businesses up to the very largest private enterprises and public sector users. FCS is the largest trade organisation in the professional communications arena, representing the interests of circa 350 businesses which supply B2B services nationwide.
Given our membership base, we have not answered the individual questions posed by the consultation, but we do have a number of important points of principle to raise.
The FCS supports Ofcom’s aim to enable automated frequency coordination (AFC) in the 6GHz band, but the framework must not disadvantage small communications providers, resellers, or Business Radio operators. These groups are essential to UK connectivity, yet they can face disproportionate risks from complex compliance requirements, market concentration, and potential interference.
It will be important that there is due regard to harmful interference and that any issues relating to interference do not undermine the advantages of the scheme. This is particularly important to Business Radio providers who provide vital services to many businesses, logistics and emergency organisations. A defined interference-reporting process with guaranteed response times and clear responsibilities is vital and we support the introduction of a rigorous enforcement regime. The FCS believes that Ofcom’s spectrum assurance teams need to show vigilance to ensure that abuses are not permitted. We believe that it is important that Ofcom has the powers, resources and processes to resolve disputes and ensure effective enforcement in a way that allows for the efficient use of spectrum.
The importance of the complex supply chain should be recognised and there is a need to ensure that there is appropriate access to spectrum throughout the chain. In general terms, the FCS believes that each specific spectrum range is in effect a local monopoly, and should be treated as such, with access conditions on fair commercial terms that do not create artificial financial and/or any operational barriers. It will be important that smaller players can operate successfully and therefore any AFC obligations must be simple, affordable, and achievable without specialist compliance teams and there should be clear guidance provided on the requirements.
The FCS is also concerned that without safeguards, AFC could consolidate power among a few global vendors, limiting choice and raising costs and we encourage Ofcom to monitor AFC pricing and mandate interoperability to avoid vendor lock-in.
I hope these comments are helpful and would be very happy to discuss any of them with you if that would be helpful.
Stefanie Norman
Head of Regulation and Public Affairs
Federation of Communication Services
18 March 2026