Written evidence submitted by the BBC



DCMS Committee inquiry – The future of public service broadcasting




The BBC exists to serve all audiences. Paid for and owned by the British public, the BBC is a universal service – as everyone pays, everyone gets something in return. 91% of UK adults use the BBC every week and this rose to 94% in March during the COVID-19 pandemic.[1] On a single day – when the Prime Minister announced the lockdown – close to 45m UK adults came to the BBC. No other public service in the UK can reach that many people at one moment.


The BBC’s universal, public service mission has proved more important than ever in the COVID-19 crisis. The BBC has informed, educated and entertained the nation during this time of need, as it has for nearly 100 years. We have delivered trusted news to millions in the UK and worldwide Ofcom research at the start of lockdown shows that 83% of people trust coverage on BBC TV.[2] We have ensured every child in the UK can follow their nation’s curriculum. And we’ve kept the UK entertained, brought people together and supported the wider industry.


It will take time to emerge from the challenges the country faces, but the BBC is uniquely placed to help lead Britain through the challenges caused by COVID-19. We support creative economies all over the country and will help accelerate getting TV, radio and digital production back on its feet.


The current crisis has highlighted the unique role of the UK’s public service broadcasters. While other providers (e.g. global streaming services) also contribute to consumer choice, their offer and the scale of their investment in the UK is fundamentally different. The public service broadcasters have an unequivocal commitment to the UK, a range, breadth and quality of services and universal mission that is unmatched by other providers. Audiences agree – despite the explosion in choice, the concept of public service broadcasting retains large scale public support.


The UK’s public service broadcasters are the engine rooms of the nation’s creative success. PSBs’ £2.6bn investment in the UK delivered 32,000 hours of original, home-grown content last year – compared to just over 210 hours of UK-produced content on Netflix and Amazon Prime. The BBC is the single biggest investor in UK content and has production bases across the UK, including in Cardiff, Glasgow and Salford. PSBs investment in the UK is long-term. In contrast, The Crown’s producer Andy Harries asked “how quickly do you think Netflix or, indeed, Amazon will roll back the spend in the UK if the world changes?[3]


PSBs make a vital contribution to the UK’s culture, society and democracy. Culturally, the BBC is one of Britain’s strongest brands, reaching almost 430m people globally every week, investing in UK content and bringing the nation together in shared moments such as the VE Day commemorations. Socially, the impact of PSBs is more apparent than ever, with the BBC’s The Big Night In raising over £70m for those affected by COVID-19 and BBC Local Radio supporting communities through the floods and the pandemic. And democratically, record numbers are turning to the BBC news offer for the accurate, impartial and trusted news they need to navigate current events.


For PSBs to continue to thrive and serve all audiences in the face of changed viewing habits, it is vital they have the right regulatory and financial environment. We ask the Committee to support changes to:


While the Committee does not ask in depth about funding, we also argue that stable, universal funding is the bedrock upon which PSBs success has been built. If we want the BBC to continue to be a universal service, dedicated to serving all UK audiences, this should be the foundation for any funding model.


Looking ahead, the digital age strengthens the case for a strong PSB system. In a digital world awash with misinformation and disinformation, citizens need trusted, impartial news about the UK and the world. In an increasingly global marketplace, British audiences want programmes and services about their lives and their culture. And in difficult times, it’s never been more important to reflect, represent and invest in every part of the UK.


We set out more detailed comments below in line with the areas of interest outlined in the Committee’s call for evidence.









- Are the current regulations and obligations placed on PSBs, in return for benefits such as prominence and public funding, proportionate?

- What (if any regulation) should be introduced for SVoDs and other streaming services?


We agree that to deliver for the UK, PSBs should receive benefits and be regulated in return. In the broadcast world, this balance has driven a virtuous cycle of near-universal reach, funding and a high level of investment in UK content. This has made the UK a world-leading creative hub and incentivised others to invest here. We believe these benefits are worth sustaining in the digital age. 

But, the current regulations and obligations placed on PSBs, as well as regulatory benefits like prominence are rooted in the past. They require modernisation so they are proportionate and fit for a digital age.


We also wonder whether Ofcom’s duties to support the PSB system in the UK should be strengthened particularly taking in to account their public value and the role they play to deliver benefits across the UK culturally and economically. Public value can sometimes be undervalued in the broader consideration of how markets work and the positive additional benefits the PSBs can bring to the UK media ecology compared to purely commercial organisations should be recognised.


The PSB system has created a more dynamic and competitive environment for broadcasting and media than is seen elsewhere around the globe. For example, where the BBC takes risks, invests in new talent both in front of and behind the camera or microphone, the wider industry benefits.  Similarly, the BBC’s promotion of niche interests creates new audiences and de-risks investment by others which benefits the UK economy. Finally, the PSB system stimulates competition for quality by investing in high quality, British content that shapes and expands consumers’ demand and encourages the industry to respond in innovative ways.


Strengthened duties should require Ofcom to create the right regulatory and market conditions to ensure the benefits of PSB are being delivered. This could be similar to postal services where Ofcom has a duty to secure the provision of a universal service. Currently Ofcom’s duties extend only to “having regard” for delivering “the purposes of public service television broadcasting.” Given the strategic, cultural and export importance of public service broadcasting to the UK and given that the PSBs are the primary way in which the “purposes of public service television broadcasting in the UK” are met these duties should be strengthened.



Modernising BBC regulation


The BBC’s regulatory environment, and that for other PSBs, is to a large extent left over from a linear era. In the past, many argued that the BBC occupied too big a place in the market; that regulation was necessary to promote proper competition.

Today the BBC faces increasing competition from all sides. Many of the harms the BBC’s regulatory framework was intended to guard against are no longer relevant. The issues it seeks to remedy do not reflect the realities of the global, digital age. The licence fee enables the BBC to deliver public and wider economic value to the UK. The aim of regulating the BBC is to strike the right balance between protecting the BBC’s ability to deliver this public value and fulfil our PSB mission, while ensuring that the licence fee does not mean we are restricting competition.

Instead, regulation has in some cases been a break on innovation and competition. Netflix CEO Reed Hastings described regulation as “the best protector of Netflix in the world”, citing the decision to stop Project Kangaroo.[4] The BBC is regulated as if its work harms competition but, far from stifling competition, the BBC forces competitors to raise the bar. A shift is needed in the regulatory mind-set away from the presumption that BBC action is negative. Step-in powers should be used when there is actual evidence of harm, not hypothetical risk.

The BBC’s operating licence and the speed of the regulatory process are also areas which should be reformed for the digital age. The BBC’s operating licence contains nearly 200 broadcasting conditions. It means commissioners have to think about regulatory quotas for broadcast channels before prioritising ideas for audiences which could be delivered online. When the BBC wants to launch something new there is rightly a regulator process, but it is slow. Ofcom is allowed nearly eight months to consider material changes to the BBC. As with recent BBC iPlayer reform, this can act as a harmful break on PSB innovation and prevent us making the changes audiences want to see. We agree with the LordsPSB report that “the BBC needs to have the power to innovate at speed without undue regulatory burdens, or it risks becoming a minor player”[5]. We think Ofcom should consider how to enable the BBC to experiment and whether there should be a move to parallel running of trials and the regulatory process or ex-post regulation.


Strengthening the PSB ecology


The UK’s media ecology is one of the country’s greatest success stories. It has grown up over 100 years and is critical to the UK’s cultural, democratic and economic wellbeing. The very existence of the PSB sector, supported by regulation, has underpinned a virtuous cycle of near-universal reach, funding and high investment in a broad range of UK content. This has made the UK a world-leading creative hub and incentivised others to invest here. There is no guarantee that the market would deliver the same benefits to UK audiences. But the regulations that support this virtuous circle are from the broadcast age. Parliament and regulators should continue to proactively support PSBs in the digital age, by regulating the major platforms (e.g. Amazon Fire TV) that benefit from carrying PSB services, but which also carry their own competitor services (e.g. Amazon Prime Video). Specifically:





There may also be merit in the Committee thinking about whether further regulatory or economic interventions should be considered as part of the bigger debate on the role of global technology companies in the UK.




As the Committee has not asked in detail about the operation of PSB funding, it is not addressed in this submission. However, we would note the following. Firstly, any discussions about funding need to bear in mind that the current Licence Fee system is fixed under the Royal Charter until 2027. Secondly, and as this submission makes clear, the BBC is underpinned by the principle of universality – it is available for everyone and provides something for everyone. Far from growing less relevant in a digital age, this unique relationship with audiences has never been more necessary –through the Covid crisis the BBC has bought the nation together. Direct funding through a licence fee also ensures the BBC’s editorial independence.

As our Chairman, Sir David Clementi has made clear, the BBC may do well under an alternative model such as subscription, but “it would no longer be the BBC you and I know. And it would no longer serve everyone. Those who advocate such a model must be realistic and recognise that the Public Service Broadcaster principle of universality would be lost.”[7]




- How would representation be protected if changes were made to the PSB model?

- How would the nations and regions be affected by changes to the PSB model?

- Is the ‘quota’ system the most efficient way to maintain and improve representation in broadcasting?


One of the BBC’s purposes is to reflect, represent and serve the diverse communities of all of the United Kingdom’s nations and regions.” Underpinned by the principle of universality, the BBC is a service for the whole country. Representation is in our DNA.


Nations and regions


To ensure we represent and serve the whole of the UK, we are based in and make programmes around the whole country. The BBC has major production hubs in seven UK locations – Glasgow, Cardiff, Belfast, Bristol, Birmingham, Salford and London – and a network of 39 local radio stations. By 2027 our ambition is for two-third of our staff to be outside London.


The BBC has made the largest investment for decades in Scotland, Wales and Northern Ireland, including in the BBC Scotland channel, and supports native language channels, BBC Alba and S4C. More than 50% of our network spend is outside London and the BBC supports more small producers and more out-of-London producers than any other broadcaster. This fuels a thriving creative sector and ensures content is created by and in the places it represents. We’d already announced a £1m fund for small indies and have since launched a new package to help the sector through COVID-19.


While PSB quotas are a blunt tool, they are part of the system that has ensured PSBs fully invest in and represent communities across the UK. It is the PSB system that uniquely delivers these aims. SVOD investment outside London tends to follow PSB investment and it is far from clear that without PSBs such a diversity of content reflecting the UK would be made. As leading UK producer Sir Colin Callender told the Lords Communications Committee’s PSB inquiry, Netflix’s Sex Education, while made in Walescould be set anywhere.[8] In contrast, the BBC’s Normal People and This Country represent the distinctiveness of the communities in which they were filmed.


The Covid crisis is having a significant impact on the UK’s creative industries, which had been one of the fastest growing sectors of the economy. Those impacts will be most keenly felt in the production community for those businesses which are based outside of London – many of which don’t have the scale or resources to cope with the prolonged pause in filming and production that we have seen. The BBC is already taking a number of steps to help our suppliers in the regions. We think that more could be done to ensure that as the industry gets back up and running, so the recovery is felt right across the UK. In particular, we think there may be merit in looking at the existing tax credit system and whether they could be enhanced specifically for businesses based out of London – targeting economic stimulus measures in the places that need it most. That economic intervention would also have the benefit on ensuring that more diverse voices and talent could find their way to our screens.


Diversity & social mobility


The BBC exists to serve and represent everyone. We are doing more than any other broadcaster on diversity and, on and off-screen, are more diverse than ever. We have met or exceeded many of our diversity targets, have diverse commissioners and leaders to ensure on-air portrayal is fully representative and we’re more transparent on diversity than any other broadcaster. For example:


The BBC wants its workforce to fully represent the diversity of the UK. 31% of people in our apprenticeship and new talent schemes are from a BAME backgrounds and we run mentoring and development schemes for underrepresented groups, such as the RISE programme for BAME staff. We were the first broadcaster to measure and publish data on socio-economic diversity and have been included in the Social Mobility Employer Index as one of the top 30 companies in the UK.


The BBC is a market leader in skills and training and focuses its investment on improving diversity. Over 2% of the BBC’s workforce are apprentices and trainees and the BBC invests in targeted schemes, such the Continuing Drama New Directors’ Training Scheme to increase the number of BAME and female directors.


The BBC’s commitment to serve the whole nation is underpinned by the principle of universality – because we are funded by everyone, we represent everyone. Other providers, such as the global SVODs, are not underpinned by the same principle. Changes to the PSB model are likely to have a substantial negative impact on representation and on investment in the UK nations and regions. A mechanism is needed to ensure that broadcasters fully represent the diversity of the UK – and for nearly 100 years, that mechanism has been the principle of universality that underpins PSBs.





- How would changes to the PSB model affect the accessibility of services?

- How would a wholly internet-based service compare to the current PSB model?


BBC accessibility


The BBC is here to serve everyone. It makes its content available through multiple channels – TV, radio and online – to ensure that it reaches the widest possible audience. As a result, the BBC is the most-used media organisation in the UK, used by 91% of the UK adult population each week (rising to 94% during the pandemic). It is consumed for the most time each week: on average over 17 hours for adults, and over 7 hours for young adults in 2019.


One of our unique strengths is our ability to bring worlds together: live and on-demand, broadcast and internet-delivered, and across video, audio and text. During the COVID-19 crisis, we have shown the value of this mixed ecology, with usage of both traditional TV and online services up sharply. As a result of our strong performance – and even at the height of lockdown when VOD growth was sharpest – the BBC is roughly 24% of all UK video, audio and online time spent by the average adult in a week. Netflix is around 3% of that time.


Internet-only services


In contrast, wholly internet-based services exclude audiences – both deliberately, through paywalls, and through technological exclusions. Any changes to the PSB model that undermined the principle of university would inevitably lead to the exclusion of some audiences. For example, BBC Radio – including the 39 local radio stations that have played a vital role during the COVID-19 pandemic – is available to everyone in the UK via radio sets. Radio waves cannot be switched off nor put behind a paywall so, without the universal funding that underpins the BBC, these services would be at risk. 


Audiences would also be excluded from wholly internet-based services by technological limitations. Traditional TV and radio still account for the majority of content consumed and are particularly important to the elderly, vulnerable and those with limited internet connections. During COVID-19, the BBC ensured that BBC Bitesize Daily was available on the Red Button as well as online, so children without access to the internet could access it. There may also be reduced availability of access services (e.g. subtitles), which the BBC has pioneered.


Access to PSB content is already at risk in the world of internet-based platforms controlled by big tech companies. Global players have both the means and the incentive to prioritise their own content on their platforms at the expense of UK PSBs. As we have outlined, it is more important than ever to ensure audiences can access PSB services on platforms controlled by global tech giants.







- What value, if any, do PSBs bring to the UK in terms of economic (local and national), cultural and societal impact?


PSBs are the engine rooms of the nation’s creative success, providing sustainable investment for the production sector across a broad range of content made for UK audiences. With the BBC at its heart, this system delivers economic, cultural, social and democratic benefits across the UK.




The BBC is at the heart of the UK creative economy – the lead investor in, and platform for, British voices and talent. Every £1 spent on the BBC through the licence fee produces £2 GVA for the economy. We make unparalleled investment in UK content – spending over 95% of our income on content and delivery[9] – and support the independent production sector across the UK. The BBC works with more small producers and more out-of-London producers than any other broadcaster.[10]


Our investment in smaller communities beyond the nations’ capitals, in the North of England, and in the nations helps spread economic benefits around the whole of the UK. The BBC accounts for 40% of all jobs in the creative industries in Salford and 2% of total employment. Our activities in the North West contributed a total of £277m to the economy and the creative sector is now worth £3.1bn to Greater Manchester’s economy – double what it was in 2010.


The BBC has also more than doubled the proportion of our network TV programmes produced in Scotland, Wales and Northern Ireland. One year ago, we launched a brand new TV channel in Scotland. Our new BBC Wales HQ is the most technologically advanced broadcast centre in the world and is on course to deliver £1.1bn GVA to Cardiff over the next decade.[11] In Northern Ireland, the BBC has made its biggest investment in programmes and services in a generation.


As a leading investor in the UK’s creative economy, the BBC will play a key role in leading the UK out of the challenges caused by COVID-19. The creative industries are widely-acknowledged to be a vital part of the UK economy and the BBC can help get TV, radio and digital production back on its feet.




The BBC is a champion of British culture: reflecting the UK to the world, celebrating the diversity of the UK and bringing the nation together for event television and national sporting moments.


The BBC is one of Britain’s strongest and best-known brands. We reach nearly half a billion people globally each week and are the world’s most visited news website – outperforming the nearest rival CNN by 36% in the March/April peak of the coronavirus pandemic.[12] The World Service has completed the largest expansion since WWII and is widely recognised to be a vital part of sharing British values and creativity with the world. If Britain did not already have a media brand capable of exporting our values, talent and creative strength to the world, we would be desperate to build one. If we did not have a trusted global news service, we would need to create one to counter the state-backed actors of Russia and China.


At home, the BBC brings the country together and creates national conversations. Over 17m people joined the BBC for the VE Day commemorations, including a special address from Her Majesty The Queen at 9pm – the exact time her father spoke to the nation three quarters of a century ago. Last year, 28.1m people watched the BBC’s coverage of the 2019 Women’s World Cup47% of the population – showing how the BBC makes sport available to the widest possible audience[13].


Social impact


The social impact of the BBC has never been more apparent than as during this time of national crisis. BBC Local Radio’s Make a Difference initiative has made over 640,000 connections with people in their communities when they need it most. BBC Radio Cumbria was called by an 81 year-old who told host Mike Zeller he only had a few days of food left. An on-air appeal found a volunteer to deliver a shop while he was on air. At a time when schools are closed, the BBC is delivering the biggest education offering in its history. We have substantially expanded BBC Bitesize, the free online study resource for school-age children in order to provide ‘support and structure’ to home learners and parents while schools are closed. A record 5.2 million browsers visited the BBC Bitesize Daily website in the first week when Bitesize Daily Lessons launched – three times the equivalent figure last year. UK Culture Secretary Oliver Dowden described the initiative as “public service broadcasting at its best.”


PSBs also lead the way in commissioning programmes with social impact. For example, in the wake of Blue Planet II, there was a marked increase in internet searches on plastic recycling and the UK Government set the country the challenge of becoming “a world leader in tackling the scourge of plastic littering our planet and our oceans”. The BBC’s Mental Health season sparked conversations on mental health, and Jesy Nelson: Odd One Out shone a light on the effects of online bullying.




The BBC is the most trusted and popular source of news in the UK. BBC News services are used by eight out of ten UK adults each week. Eighty three percent of people trust coverage on BBC TV and 62% of UK adults say they are most likely to turn to the BBC for the news they trust the most – significantly more than any other provider[14]. During the coronavirus pandemic, on average, BBC TV Network and Regional News in late March / early April 2020 reached over 26 million people daily, and in the week social distancing began, a record 81m UK unique browsers came to BBC News online.[15]


The universal availability of accurate, impartial news and trusted information has never been more important, as harmful and misleading news about coronavirus has shown.[16] In response, the BBC’s Reality Check gives audiences context to understand claims and actively debunks hoax stories. We are using the BBC’s global reach and credibility to convene partnerships such as the ‘Trusted News Initiative’ with tech platforms and scope technological solutions to combat the spread of disinformation around COVID-19.[17] 


And at a time when commercial radio is moving away from locally-produced content and local news is an industry in crisis,[18] the BBC provides a strong voice for towns, cities and areas that have suffered a decline in media coverage. We bind communities together, particularly in times of emergency and stress, for instance during the floods earlier in 2020. And we play an important role in supporting other local media—for example, through our Local Democracy Reporters scheme where we invest up to £8m a year in a pioneering partnership with 120 local news publishers, funding 150 local reporters across the UK. The journalism from this initiative is now published in over 5,000 places every week.


Looking ahead


- What should a PSB look like in a digital age?

- What services should they provide, and to whom?

- In what way, and to whom, should they be accountable?

- Is the term ‘public service broadcasting’ still relevant and, if not, what is a suitable alternative?


The UK’s PSBs already operate in a digital age. We have always been innovators and we continue to pioneer new technology and services to best reach our audiences. The BBC has modernised iPlayer, released BBC Sounds and improved the BBC News app – all of which help us to deliver our mission to inform, educate and entertain all audiences in the digital age.  This investment has benefited the UK market as a whole.


And our live broadcast channels still reach tens of millions every week and are much loved by audiences. Through our channels we have the ability to talk to people live and in the moment, with content that is relevant to them. In the digital age, the PSBs’ linear and online offers work brilliantly together.


As we move further into the digital age, PSB services may be increasingly delivered online, but they should continue to be universal, free-to-access and accessible to all, delivering a wide-range of services, trusted independent news, and support for UK culture and the creative economy. The PSB system has been shown to work and deliver for the UK for almost a century. There is a real question as to why one would seek to unpick this.



PSBs and the public


PSBs are accountable to the UK public. The BBC believes accountability and transparency are both vital and in this area we lead the way. While rightly independent of Government, the BBC is regulated by Ofcom in line with the Royal Charter. The BBC has been found to be one of the most transparent organisations in the country, according to two independent reviews. We publish a wide range of information including Board minutes, diversity data and salaries over £150,000, and we have a robust complaints process.


UK audiences may not often use the term ‘public service broadcasting’ but the underlying principles of PSB are ones that the public hold dear – trusted news and information, high quality output and content that represents the UK. And the PSB brands they know – the BBC, ITV, Channel 4 and Channel 5 – are highly valued and trusted by audiences.


The BBC, in particular, is unique in the world. The BBC is a national asset that is local, national and global. If we were designing a brand-new media organisation to respond to our world today, we would call on precisely the same fundamental values of quality and relevance, independence, impartiality and universality – proof that ‘public service broadcasting’ is a concept that endures.


The BBC is owned by everyone. Its value has been more self-evident than ever in recent months and it is more important than ever to have a proper conversation with the British public about the BBC’s next 100 years. The British public own the BBC, they use it more than any other provider, and they pay for it. It is they who should have the primary voice in the debate about its future. 


Future of PSB


As the Committee looks to the future of public service broadcasting in an increasingly digital world, it should be in no doubt that the record success of the UK’s creative industries is as a result of PSBs – and in particular the BBC – investing in UK content across the whole of the UK. As the cornerstone of the UK’s public service broadcasting sector, the BBC’s universality and scale enables sustained, stable investment in UK talent, skills, creativity, and news both nationally and in local communities around the UK too – even in times of crisis and market uncertainty. We believe these benefits for the UK and audiences are needed now more than ever and PSB should be retained and strengthened in the digital future.


To achieve this we urge the committee to recommend:



[1] Usage peaked at 94% week beginning 16 March 2020 as social distancing began. Source: Ipsos MORI, BARB, BARB Establishment Survey, RAJAR, Adobe Digital Analytics (DAx)

[2] Populus for Ofcom, 2,232 UK online adults (Ofcom Coronavirus Survey, week 1, 27-29 March 2020) https://www.ofcom.org.uk/__data/assets/pdf_file/0031/193747/covid-19-news-consumption-week-one-findings.pdf

[3] Evidence given to the House of Lords Communications Committee inquiry, Public service broadcasting in the age of video on demand: http://data.parliament.uk/writtenevidence/committeeevidence.svc/evidencedocument/communications-and-digital-committee/public-service-broadcasting-in-the-age-of-video-on-demand/oral/102660.html

[4] Project Kangaroo was an initiative by the UK PSBs to launch a joint streaming service over a decade ago – blocked by the regulatory authorities.

[5] https://publications.parliament.uk/pa/ld201919/ldselect/ldcomuni/16/1602.htm

[6] ibid

[7] Speech by Sir David Clementi at the Voice of the Listener and Viewer, 20th November 2019 - https://www.bbc.co.uk/mediacentre/speeches/2019/clementi-vlv

[8] Oral evidence to the Lords Communications Committee, 30th April 2019

[9] 95% of the BBC’s controllable spend this year was focused on content and delivery, just 5% was spent on running the organisation. Source: BBC Annual Report 2018/19

[10] BBC, TV Commissioning Supply Report, 2018

[11] BOP Consulting, Economic Impact of the new BBC Wales broadcasting centre, April 2018

[12] This is a global reach figure which includes news services and the BBC’s commercial arm, BBC Studios.

[13] Women’s World Cup: Record total audience, July 2019

[14] The nearest provider is Sky News, which 8% of adults would choose as the one source they are most likely to turn to for news they trust the most

[15] w/c 16th March 2020

[16] 70% of UK online adults surveyed said they were concerned about ‘fake news’

[17] https://www.bbc.co.uk/mediacentre/latestnews/2019/disinformation

[18] The Cairncross Review found that between 2007 and 2017, the number of local newspapers dropped from 1,303 to 982.