Ontology by the Back Door: How Ofcom, ARCEP and the Digital Networks Act Are Quietly Redefining Regulation

As ARCEP takes a victory lap,  Europe announces their new DNA and Ofcom finalises TAR 2026 we see new models emerging.

Europe’s connectivity regulation is undergoing a structural shift.  While policy debates tend to focus on investment incentives, pricing controls or access remedies, a more fundamental transformation is taking place. 

Regulators are now defining networks, markets and obligations through shared structures, identifiers and modelling assumptions.  In effect, regulation is becoming ontological, even if it is not labelled that way (yet).

From France’s GRACE THD framework, through Ofcom’s Telecoms Access Review (TAR) 2026, and now into the draft EU Digital Networks Act (DNA), regulation is moving beyond static reporting towards explicitly structured, machine-interpretable representations of infrastructure and competition. 

This evolution has profound implications for how regulation is designed, implemented and enforced and from our point of view how it is analysed and how the impacts are modelled.

France: GRACE THD and the physical ontology of fibre

France’s GRACE THD model is often described as a geospatial data standard, but its significance runs deeper.  By defining canonical objects such as technical nodes, optical cables, premises and deployment zones, along with their permitted relationships, GRACE THD establishes a shared representation of the national fibre network.  In effect, it fixes what the network is, in physical terms, for planning, reporting and oversight.

Crucially, GRACE THD separates physical topology from regulatory interpretation.  It does not encode access obligations or pricing rules; instead, it provides a stable substrate on which such rules can be applied. 

This distinction has allowed ARCEP to move beyond aggregated statistics towards systematic, repeatable analysis of coverage, mutualisation and investment gaps.

We have built a simple markup of how ARCEP has connected the dots.

The UK: TAR 2026 and distributed regulatory semantics

The UK has not adopted a single national infrastructure schema equivalent to GRACE THD.  Nevertheless, through the Telecoms Access Review 2026, Ofcom is effectively mandating a distributed semantic framework. 

Premises are anchored to UPRNs, physical infrastructure is represented through Physical Infrastructure Access (PIA) assets, and competitive conditions are expressed through geographically defined market areas.

Ofcom’s approach is notable not because it publishes an explicit ontology, but because it standardises the entities and relationships that all market participants must use.  Area 2 and Area 3 classifications, for example, are not declared as fixed facts but are derived from modelling assumptions about reachability, competition and infrastructure proximity.  Regulation, in this sense, is becoming semantic.

From schemas to systems: regulation embedded in operations

A further step change is occurring as regulatory structures move from documentation into live systems. 

Equivalence of inputs, PIA access, and network planning increasingly depend on shared operational models exposed through APIs rather than static submissions. 

Ducts, poles and chambers are no longer described after the fact; they are instantiated as persistent, stateful objects whose attributes have direct regulatory consequences.

This shift exposes a growing tension between internal operator systems and regulator-mandated representations.  Private tools may optimise for engineering efficiency, but regulatory frameworks increasingly require a common, external object model.  The contest is no longer over data access alone, but over which representation of the network is authoritative.

Buffer models and derived markets: regulation as computation

Ofcom’s recent consultations on leased lines markets make this transformation explicit.  Geographic markets are defined through buffer distances applied to physical infrastructure, producing reachability assertions and, ultimately, Area 2 or Area 3 classifications.  These outcomes depend on parameters, thresholds and regulatory judgement, all of which are now documented and debated.

This represents a clear departure from earlier practice.  Market boundaries are no longer static lists, but outputs of a model.  Evidence, uncertainty and sensitivity analysis become first-class elements of the regulatory process. 

In effect, Ofcom is publishing not just decisions, but the logic by which those decisions are reached.   These markup diagrams help to break out how we are making this work in our analysis.

The Ofcom ‘buffer’ model -

The Digital Networks Act: towards computable EU regulation

The draft Digital Networks Act extends this trajectory to the European level.  By consolidating large parts of the existing communications framework into a single Regulation, and by introducing mechanisms such as the Single Passport and EU-wide registries, the DNA moves decisively towards directly applicable, operational regulation.

The creation of the Office for Digital Networks (ODN) is particularly significant.  ODN is not merely an administrative body; it is designed as the operational backbone of EU connectivity regulation, responsible for maintaining databases, registries and reporting systems.  This institutional design presupposes shared, structured representations of networks, operators and obligations.

Knowledge graphs as the response layer

These approaches demand and enable new data frameworks.

Knowledge graphs provide a natural way to capture this emerging regulatory structure.  They allow physical infrastructure, regulatory norms and derived analytical outcomes to coexist within a single model, while preserving provenance, scope and uncertainty.  Rather than flattening complexity, they make it explicit and queryable.

In this context, knowledge graphs do not replace national standards such as GRACE THD or regulatory frameworks such as TAR or the DNA.  They sit above them, providing a semantic layer that connects physical reality, legal obligations and regulatory judgement.

Structure is now policy

Entering the second half of this decade, the defining feature of connectivity regulation will not be the volume of data collected, but the structure through which it is interpreted. 

ARCEP, Ofcom and the European Commission are converging on a model in which regulation is increasingly computable, auditable and embedded in shared systems.

Ontology by the back door?  We believe it is a significant move in that direction and those who recognise and engage with it will be better placed to understand, implement and influence the regulatory frameworks that will shape Europe’s digital infrastructure.