Peter Farmer

Co-founder · Regulatory economics & public affairs

Peter began his career selling ERP systems to car manufacturers. He has spent the twenty years since at the point where telecoms regulation meets the numbers underneath it.

He is not the accountant here — that is Carol, below. Peter's training is in economics and management, and his subject is regulatory economics: what a rule costs, whom it moves money to, and whether the model behind it survives contact with the evidence. At Gamma Communications plc he ran the regulatory and government affairs functions, responsible for the procurement of more than £100m a year in regulated wholesale inputs. He has followed almost every telecoms case before the Tribunal or above since 2009, in the room or in the transcript. Since founding Exonia he has advised operators, platforms, boards and their investors across the UK, the EU and North America, and clients with interests in the United States, Australia, France, Germany, Belgium, Portugal, Italy and Hong Kong. He works increasingly with AI-native platforms, and is currently operating principal of one.

Alongside the practice, he has taken equity stakes and fractional C-suite roles in operating businesses: he held both at Ziron, until its sale to Telcoswitch (now Yay), and he co-founded Telesmart (telesmart.io), where he also served in a fractional C-suite capacity. He also holds Licensed Access recognition from the Bar Standards Board — the right to instruct a barrister directly on contentious regulatory matters, without a solicitor in between.

He read Biomedical Sciences at Oxford. The subject changed; the habit did not — look at the evidence, ask what would falsify the claim, and treat a confident number with suspicion until you know how it was made. On forecasting he offers clients exactly one guarantee: that he is wrong. The work is in knowing by how much, and in which direction.

In legislative & regulatory work

• 2009–
  Communications Act, Competition Act & Enterprise Act — complaints, disputes & enforcement Disputes under section 185 and complaints under sections 96A–C of the Communications Act 2003 to Ofcom, on number portability and transit charging; competition complaints to Ofcom and the CMA under the Competition Act 1998, including margin squeeze; and allegations to the CMA of breaches of undertakings in lieu of a reference under the Enterprise Act 2002.
• 2014–15
  DG COMP — O2/Three merger control Submissions to the European Commission's Directorate-General for Competition on the proposed O2/Three UK merger.
• 2015–21
  Investigatory Powers Act 2016 & Telecommunications (Security) Act 2021 Written submissions during the bill stage of both Acts, and engagement with government stakeholders.
• 2022
  CRTC — 988 crisis line implementation Submission to Canada's telecoms regulator on implementing the 988 suicide crisis line across the country.

Further matters

• 2009– Consultation responses — Formal responses to substantially every Ofcom consultation touching telecoms since 2009, and to those from ComReg, the European Commission, DCMS, DSIT, and the Home Office on the same ground.
• 2009– Westminster — both Houses — Evidence and briefings to parliamentarians on fraud strategy, spectrum policy, interoperability, net neutrality, and consumer rights. Ongoing.
• 2012–18 Conservative Party Science & Technology Forum — Member of the party-affiliated think tank, engaging on science and technology policy.
• 2014–15 European Commission presidency — net neutrality — Advice and submissions on net neutrality to the Commission presidency.

In contested proceedings

• 2010–16
  Ladder charges Submissions to Ofcom, then witness statements to the Competition Appeal Tribunal in British Telecommunications plc v Ofcom [2011] CAT 24. Gamma intervened at the Supreme Court in British Telecommunications plc v Telefónica O2 UK Ltd [2014] UKSC 42, and again on remittal. The Court of Appeal's decision was set aside and the matter sent back to the Tribunal.
• 2016
  Average porting conveyance charges Referred the dispute under section 185 of the Communications Act 2003; Ofcom found for Gamma. On BT's appeal — British Telecommunications plc v Ofcom [2016] CAT 22 — Gamma intervened in support of Ofcom and the determination was upheld. Gave witness evidence and was cross-examined. The Chair of the Tribunal recorded that Mr Farmer was a straightforward and helpful witness.
• 2016
  — and the point that did not land The timing argument run in the same appeal was his. It was finely balanced, and it went against him. It settled the legal status of Ofcom's guidance, which the sector had not previously had.
• 2022
  Revenue share fraud International commercial court. Expert witness in sealed proceedings — the substance cannot be described.
• 2025
  Data centre energy supply dispute Advised the data centre operator in a commercial dispute over its energy supply. The action settled.

Further matters

• 2013 The Oftel Interest Rate — Referred a dispute under section 185 of the Communications Act 2003 over the interest rate in BT's Standard Interconnect Agreement; Ofcom determined the dispute on 25 October 2013 and published guidance alongside it. That isn't winning a case — it's causing a rule.
• 2014 Interconnect Extension Circuits — Appealed Ofcom's determination that BT had not overcharged on IEC charges (Gamma Telecom Holdings Ltd v Ofcom, Case No. 1234/3/3/14), pending the Ethernet Determinations case. Withdrawn once that appeal didn't go the way the argument needed.
• 2017 Dark fibre appeals — Gamma's intervention in British Telecommunications plc v Ofcom [2017] CAT 25, on Ofcom's decision to require BT to sell dark fibre on regulated terms. Cross-examined on market geography.
• 2020 AIT dispute — High Court. Expert witness. Settled prior to hearing.
• 2023 Disputed rating of regulated inputs — Advised a major communications provider on a dispute heading toward the High Court. Resolved before issue.

Carol Topley

Co-founder · Financial, tax & governance

Rigorous enough for a public company audit. Down to earth enough for a shoebox of receipts. Carol is the reason Exonia can call itself a chartered practice. She is a Chartered Professional Accountant in Canada and a Chartered Management Accountant in the United Kingdom, where she holds a CIMA practising certificate. She has spent 15 years on the statutory, tax and governance side of the businesses Peter argues about with regulators.

She qualified at Gamma Communications plc, where she worked on pricing and business analysis, before moving into the wealth management arm of Lloyds Bank. From there she worked on the flotation of The Gym Group, then moved in-house at BAE Systems. That range — telecoms, retail banking, an IPO, and defence — is now behind Exonia's small business statutory accounting and tax work, and her role advising clients on governance and capital structure. For scale-ups, that increasingly means designing and implementing EMI option and growth share schemes.

Increasingly, she and Peter take clients through exit together: pre-DD compliance and housekeeping first, then the due diligence itself, across commercial, legal, finance and tax.

She read Physics and Philosophy at Oxford, which is an unusual route into accountancy and, on reflection, a direct one. One half of the degree teaches you to measure something. The other teaches you to ask what the measurement is claiming. A set of accounts is both, and most of the interesting questions live in the second half.