Written evidence submitted by the
UK Coalition for Cultural Diversity

Submission to DCMS Committee: Pre-Legislative Scrutiny of Media Bill

From UK Coalition for Cultural Diversity

The UK Coalition for Cultural Diversity is a not-for-profit, civil society organisation supporting the implementation of UNESCO’s 2005 Convention on Diversity of Cultural Expressions. We are the national representative of The International Federation which represents the interests of over 700 cultural and creator organisations. We monitor national cultural policy and advise the UK National Commission, government, civil society and creator organisations.

Public Service Broadcasting

We recommend that OFCOM impose discoverability obligations on all audio or audio-visual entertainment media content undertakings, as it deems appropriate, including:


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

The Bill does not appear to address terms of trade between independents and the PSB providers nor in particular, to address issues concerning IP rights

Independent film companies should retain or share IP rights with PSB providers to ensure the sustainability and presence of smaller local production companies in the UK marketplace and in order to guarantee the diversity and local focus of PSB programmes.


Independent companies should also fulfil qualifying requirements regarding their UK status.


On demand services should comply with discoverability/prominence requirements regarding PSB.

On demand services should be required to share data on their algorithms and the breakdown of user reception to inform necessary Ofcom monitoring of company’s compliance with matters of diversity and inclusivity as demanded by the PSB remit

General issues

1 The Media Bill requires a better definition of the PSB remit than in the current draft. As stated currently, Ofcom can only have a reactive rather than a proactive role in safeguarding public interest in our broadcasting environment.  As currently drafted Ofcom will not be measuring anything other than original productions, those produced outside the M25 and independent productions.


2 With regard to broad aims of public service broadcasting provision, UKCCD suggests Clause 5 be amended to include the following:


3 Clause 5 consistently refers to ‘audiovisual content’ with no specification of genres essential to support our creative industry and talent growth, and which are vulnerable to commercial failure; genres such as long-form and investigative documentary; arts and religious programming ; innovative and experimental drama and independent film

4 In order to facilitate Ofcom’s monitoring and reporting and in view of the change to broadcasters’ obligations from ‘requirements’ to ‘objectives in 2 (clause 2) UKCCD recommends that the Act be amended to ensure that public service broadcasters are obliged to provide data to include the following issues: sex; gender; race; equality; disability; regional output and original drama. If public service providers are obliged in this way it will strengthen and inform the intention in 5b of ‘what appears to Ofcom to be reasonable’.

5 In general, and in addition to points raised regarding clause 5 above, does the Bill grant Ofcom sufficient powers to defend PSB aims in the face of unwilling rather than willing providers and in the face of the culture clash of commercial companies with different programming criteria and company objectives?

Given evidence that 7-8 million people are not going to transfer to digital and given statistics showing that around 80% still access content through their TV sets, the schedule set for transferring to digital should be gradual and progress only on the basis of evidence demonstrating audience habits.  Universality of access must remain a guiding principle.

There is inadequate recognition that public service broadcasting has been a key driver in sustaining our creative economy, as well as in providing the resources for research and development of new programming and talent . These functions are essential to the future prosperity of the UK and jobs market. All companies benefitting from public funds and in particular the BBC, should be prepared to innovate and be supported to undertake the risk of the percentage of failures necessary in the discovery of new forms and talents.

Role of the BBC – the BBC’s critical role in sustaining PSB standards

The BBC is not a state broadcaster. It is essential it maintains its independence.

Given the failures highlighted in the appointment of its latest Chair, the Prime Minister should be uncoupled from this process, and proposals should go through the relevant cross-party committee with the Board as a second check.

The Board make-up should reflect a political balance and include representatives of the 4 nations. The number of non-executives appointed by the BBC to reflect civil society should be increased to ensure its independence


The World Service

Grant in Aid should be restored to the World Service. The Media Bill should make provision for a fund with the aim of maintaining the service for 1 billion people worldwide as a target.

International Trade

The White Paper should support a comprehensive cultural exemption in any agreement with another country or group of countries in order to safeguard British cultural sovereignty and to develop the British cultural industries. Such an exemption would ensure that the British Government is free to adopt measures vis-a-vis internet platforms on behalf of indigenous creative industries in a way which would be of benefit to the United Kingdom. It is also important to have the freedom to introduce the proposed provisions of the Online Harms Bill or any changes as outlined in the government’s new White Paper.

Please reference - UKCCD Briefing, May 2021. Free Trade Agreement UK – Canada:Briefing for Ministers




UKCCD Contact:

Holly Aylett, Director UKCCD