Written evidence submitted by Fremantle UK
Fremantle UK Response to Call for Evidence on Draft UK Media Bill
Fremantle UK is the British production arm of global entertainment group, Fremantle. We are made up of a number of labels, each with its own creative signature, which produce best-in-class programming for all the main UK television networks and many global streaming platforms.
Fremantle wants to emphasise that it welcomes the upcoming Media Bill and broadly supports many of the provisions that have been set out. Increased harmonisation of standards and policy across broadcasters and VoD services is essential in creating an environment which can meet the modern media landscape. This policy cohesion will further support the UK’s position as a global leader in content production.
For this reason, Fremantle wants to ensure appropriate consideration and scrutiny is given throughout this process and with any future decisions regarding the industry. Primarily this concerns the protection of the UK’s independent production sector which is vital for supplying a broad and diverse range of content, something of paramount importance to UK consumers, as well as making a significant economic contribution across the UK. The UK’s position as a leader in programming diversity and novelty should be protected. This has been key in driving consistent revenue growth in the UK independent sector up to the 2019 COVID pandemic, and thereafter supported recovery in recent years to reach pre-pandemic levels in 2021, according to PACT figures.
Fremantle wants to specifically highlight the proposed changes to Channel 4 and its ability to produce its own content. Channel 4 has been an important driver of the UK independent production sector, through its commitment to programming diversity and commissioning of independently produced content. Any changes to Channel 4’s remit and quotas should be carefully assessed with broad industry consultation to ensure appropriate safeguards for the independent production sector. This should include a detailed impact assessment, following which substantive policy measures should be put in place to mitigate any negative impacts on the independent production sector.
Fremantle also wants to ensure that any change in measurement of content quotas - from proportion of programming to hours of content - follows a robust methodology and is consistently applied. There needs to be a clearer articulation of the application of quotas across linear channels and VoD services to ensure that the changes are not used as an opportunity to further reduce tariffs and margins – and therefore feasibility and quality – of the independent production sector. Without sufficient incentive, creativity will inevitably be stifled. For example, it should not be possible for all quota hours to be used on lower tariff services. Overall, through this process the independent production sector should be safeguarded against any provisions which have the potential to introduce extra irrecoverable costs for producers, which will put additional pressure on producers.
Finally, we understand that many of the nuances to the policies described in the Bill are yet to be clearly defined. This includes, but is not limited to, the criteria for VoD tiering, the VoD Code and content quotas. All of which are subject to future assessments and proposals by Ofcom and the Secretary of State. With this in mind, Fremantle is eager to see any future proposed developments of the Bill, and associated secondary legislation. These further decisions should be undertaken with a high level of scrutiny and wide and detailed consultation among the industry, with appropriate impact assessments undertaken.