Written evidence submitted by the International Broadcasting Trust









TO THE CULTURE, MEDIA ANDInternational Broadcasting Trust… SPORT (CMS) COMMITTEE


May 2023



The International Broadcasting Trust is a UK charity working to protect and expand the spaces for international stories to be heard within the media.

We provide support and guidance to our members – international NGOs from across the humanitarian, development, and environmental sectors – helping them to understand the rapidly changing media landscape and harness outlets to highlight key issues.

We campaign to protect and expand the few spaces remaining for international stories to be heard, across public service broadcasting and the wider media landscape.


Our members:

Age International, AMREF, Bond, British Red Cross, CAFOD, CharityComms, ChristianAid, Concern Worldwide, Disasters Emergency Committee (DEC), Global Canopy, HelpAge International, Hope and Homes for Children, Humanity & Inclusion, Institute of Development Studies (IDS), International Institute for Environment & Development (IIED), International Rescue Committee (IRC), Islamic Relief, Mines Advisory Group (MAG), Malaria Consortium, Malaria No More, Médecins Sans Frontières (MSF), Medical Aid for Palestinians (MAP), Muslim Hands, ONE, One World Media, Open Society Foundations, Overseas Development Institute (ODI), Oxfam, Plan International, Plan International UK, Practical Action, Restless Development, Saferworld, Save The Children, Sightsavers, Tearfund, The Donkey Sanctuary, The Freedom Fund, TreeAid, UNHCR (UK), UNICEF (UK), WaterAid, Weber Shandwick, Women for Women International, World Food Programme, WWF.



Executive Summary

  1. We welcome the Draft Media Bill and support the majority of changes proposed. We recognise the urgent need for changes to the legislation governing the UK’s Public Service Media system, which may help safeguard the needs and interests of providers and audiences in the digital age. We look forward to the introduction of the Media Bill itself in due course.
  2. Public Service Media is a window onto the world. For many people in the UK, it might be their only opportunity to see and hear from those living beyond our borders. Citizens’ understanding of domestic affairs (such as the arrival of refugees on our shores) and global concerns (such as the climate emergency) depend on access to reliable and trusted sources. Public Service Media has long been, and continues to be, the most reliable and trusted source of information from and about the wider world.
  3. We are concerned by some of the proposed changes to legislation, which we fear may adversely affect the quantity, quality, discoverability, and prominence of international content.
  4. In particular, the proposal to update and simplify the current public service remit is a cause for some alarm amongst those keen to see an increased presence of international coverage. The current remit obliges the system to provide content on ‘matters of international significance or interest’, which the simplified remit omits entirely.
  5. We want to ensure that changes to the Public Service Media system maintains and supports the outward-looking gaze of its institutions, commissioners, and content producers.



Public Service Broadcasting

Should the Media Bill provide a clear definition of what prominence in online services looks like?

  1. We are delighted to see the issue of prominence addressed in the Draft Media Bill. Public Service Media relies on the existing prominence regime to ensure their services are accessible and easily discoverable within the Electronic Programme Guide. It’s vital that the same, or even greater, levels of discoverability are replicated within the regulated television selection services (RTSS) such as smart TVs.
  2. We believe the Media Bill should go further in defining what constitutes an ‘appropriate degree’ of prominence within a designated internet programme service (IPS). Given the rapid pace of technological development in this area, the Bill needs to define its terms broadly whilst ensuring sufficient clarity as to future-proof the purpose and intention of the prominence regime.
  3. We propose that the Bill uses the term ‘significant prominence’, which we feel has greater force and creates an obligation on technology providers to ensure all PSM providers are given equal prominence within their services.

Are proposals allowing a Public Service Broadcaster to meet its remit by online programming as well as linear appropriate?

  1. We are broadly supportive of the proposed changes that would allow PSBs to deliver their remits through online services as well as linear. However, we are concerned the changes may inadvertently result in fewer programmes from/about the rest of the world being universally available through linear services.
  2. We are encouraged by the continuation of linear-only quotas for news programmes. We hope this will adequately safeguard the prominence and universal accessibility of this most important public service media, which we can only assume was the reason for its continuation.
  3. We believe that international content of all kinds and genres (not only international news) need some protection in law, helping to ensure their continuing prominence within the schedules (online and linear) long into the future. We are concerned that the Media Bill may inadvertently lead to a significant movement of international coverage from linear schedules to obscure corners of their streaming services, further diminishing the audiences for important programmes about our world and lessening their potential impact on audience perceptions and understanding.
  4. We are pleased to see that, under changes proposed in the Draft Media Bill, content would only contribute towards the new remit if providers make sufficient efforts to ensure it can be accessed by as much of its intended audience as is reasonably practicable. Likewise, it’s encouraging to see provisions for the Secretary of State to reimpose quotas for content that may fall by the wayside as a result of changes to the remit and means of its delivery.
  5. It remains unclear how Ofcom and/or the Secretary of State will know how well at-risk programming (international, arts, religion, etc.) is performing under the new remit, unless it is being closely monitored.
  6. It remains equally unclear how, in an age of personalised and algorithm-driven streaming services, anyone will be able to evaluate the accessibility and discoverability of content for individual members of the public.

Are the proposals in the draft Bill adequate for securing the future of Channel 4 and supporting independent content producers?

  1. We remain unconvinced of the need to alter Channel 4’s publisher-broadcaster status, given its strong performance over recent years.
  2. We are concerned that allowing Channel 4 to produce its own content will ultimately damage the independent production sector, which it has nurtured since its inception.

Do the proposals for S4C meet the legislative changes required by the independent S4C review in 2018, and are these changes still relevant and appropriate today?

No comment.

Is the draft bill sufficiently flexible to legislate for any future extension of the Listed Events regime to include digital content?

No comment.




Are the requirements for the Tier 1 standards code proportionate?

No comment.

Are accessibility requirements for Video on Demand set at an appropriate level?

No comment.

Do the proposals in the draft Media Bill create any risks to UK’s desirability as a market for VoD content?

No comment.

What should be the specific criteria for designating an on-demand programme service as Tier 1?

No comment.




Is the definition of a radio selection service appropriate?

No comment.

Is the definition of an internet radio service appropriate?

No comment.

Are the obligations on radio selection services proportionate?

No comment.

Does the draft Media Bill sufficiently protect the relevant internet radio service to be played in response to a voice command?

No comment.

Are the provisions in the draft Bill sufficient to protect the identity and content of local radio?

No comment.



General issues

Is Ofcom able to deliver its new and updated obligations set out in the draft bill?

  1. The role Ofcom is required to play is seemingly ever-expanding and shifting. Nevertheless, as we transition further towards a digital-first environment, its role will be even more important to the future of Public Service Media than ever before.
  2. The Draft Bill requires the regulator to monitor both linear and online platforms to ensure the delivery and availability of diverse content types without, in many cases, the help of quotas to determine the metrics for assessment. It is unclear how Ofcom will know when there is a reduced availability of certain content (e.g. programmes exploring matters of international significance or importance), let alone demonstrate a significant impact on the breadth and depth of programming available to UK audiences.
  3. The Draft Bill gives no indication as to how Ofcom will assess the discoverability and accessibility of important public service content, such as international coverage. This is particularly alarming given the rapid shift towards personalised user experiences. It remains unclear how Ofcom can know what prominence is afforded to particular genres of programmes, by algorithms that present different content to individual users.
  4. The Draft Bill places no obligation on Public Service Media providers to disclose any information about their algorithms to Ofcom. It remains unclear whether Ofcom has the expertise to understand the design and implementation of algorithms by providers. Without such expertise, it’s unclear how Ofcom will be able to regulate this space and evaluate the implications of algorithms on audiences. We would like to see more transparency by broadcasters about the algorithms that they use.
  5. Public Service Media providers have spent years developing their streaming platforms (BVoDs) as strictly commercial enterprises, for example ITVX. It remains unclear how a service that is commercial in design and purposes can be adapted to sufficiently deliver public service content to audiences. We are concerned that less commercially-viable programmes, such as those covering matters of international significance, will inevitably suffer from a diminished prominence on platforms designed to feature and promote commercially successful (and profitable) content.

Is the draft bill flexible enough to address future developments in audience habits and new technology?

No comment.

Does the draft Bill provide sufficient protection for those without internet access or who prefer to use broadcast services?

No comment.

Are the proposed powers to be given to the Secretary of State proportionate?

No comment.

Does the draft bill sufficiently address failures of retained EU law to operate effectively and other deficiencies arising from the withdrawal of the UK from the UK?

No comment.

Are there any issues missing from the draft Bill within the scope of public service broadcasting, video-on-demand or radio?

  1. We would like to see the definition of Public Service Media broadened in the new remit. We believe it is important to describe the wider purpose of Public Service Media and the impact it is intended to have on its audiences, civil society, and the health of our democracy.
  2. The definition should describe the system’s obligation to provide at risk content, which would no longer be freely available to a mass audience were they not provided by the Public Service Media. This would include programmes on international matters that help to provide context to audiences in today’s globalised world, news and investigative journalism from all corners of the globe, science and environmental concerns relevant to the global climate emergency, and current affairs programmes capable of informing and engaging children and young adults in the critical issues of our time.

Do you have any recommendations for additional or amended drafting to the draft Bill?

  1. We would like to see limits placed on the use of algorithms, to make recommendations and manipulate the viewer experience, within the BVoD streaming services. We are pleased to see the Public Service Media providers are adopting a mixed approach to content presentation - part curated and part algorithm generated - but there is nothing in the Bill to prohibit providers from creating entirely algorithm-generated user experiences, which is likely to result in siloed audiences trapped in ‘filter-bubbles’. We believe the use of AI within the presentation of Public Service Media needs to be carefully regulated and limits drawn around the acceptable extent of its use in this context.
  2. We would like greater clarity around how BVoD services will be regulated to ensure that content that embraces public service values, such as international coverage, is visible and easily discoverable within the platforms. We are concerned that, without sufficient regulation around the prominence of such content types, the BVoD services will inevitably push audiences towards more commercially-viable content and, in turn, give less visibility to at-risk content types whilst still (technically) meeting their obligations.






Mark Galloway (Executive Director)

Gareth Benest (Advocacy & Development Director)