Written evidence submitted by Professor Jeanette Steemers



Submission from Professor Jeanette Steemers, Department of Culture, Media and Creative Industries, King’s College London

DCMS Select Committee Inquiry into the Future of Public Service Broadcasting



In keeping with my research expertise as an academic in the area of children’s screen content, I confine most of my remarks to the future of public service broadcasting and its engagement with and impact on children.[1] 


Regulation – The BBC and commercial PSBs should be held accountable to existing obligations on children’s content.  If the YACF is to continue then its funding needs to be secured.  If SVoDs benefit from access to the UK market and infrastructure then a small levy could be applied for UK originations for children. Prominence for PSB children’s content is crucial for its distribution and discovery.

Representation – While the children’s component of PSB has sought to reflect minorities and the nations and regions on screen, more needs to be done.  Representation needs to be monitored and managed and this includes independent productions that feed into PSB.

Accessibility At this point in time wholly internet delivered PSB services run the risk of disenfranchising those who cannot access or afford online content.  It is too early to move to solely online services for children.  However PSBs need resources to develop online distribution.

Impact – Children’s content commissioned by UK PSBs and produced in the UK with a variety of partners is highly valued and economically valuable.



  1. In recent years the regulatory position of PSB children’s provision has been weakened by reductions in obligations for commercially-funded PSBs, following the abolition of quotas in the 2003 Communications Act, a loss compounded by a ban on advertising for ‘junk’ food around children’s broadcast content in 2007. Since then commercial PSBs’ commitment to children waned leaving the BBC as virtually the only commissioner of UK originated children’s content. Between 2006 and 2017 PSB investment in UK children’s originations fell from £116m to £70m.[2] 
  2. The removal of regulation provides a clear example of the market not delivering on children’s interests when left to its own devices.  Quota removal resulted in deficits in UK originated drama and factual programming for children, which became almost solely the preserve of the BBC.[3]
  3. Since April 2019 the Young Audiences Content Fund,  a three-year pilot hosted by the British Film Institute with £57m sourced from leftover licence fee funding, has offered a partial solution to funding PSB children’s content. The fund’s success depends on commercial PSBs committing to provide up to 50% of funding and a platform (on free-to-air channels or free video on demand) in line with the fund’s public service objectives of promoting innovative content and exploring new ways of circulating it to young people.
  4. The market for UK-originated children’s screen content does exhibit market failure, which requires regulatory interventions which are proportionate to maintaining provision that benefits all children living in the UK.
  5. Significant among these are BBC origination (400 hours for CBBC and 100 for CBeebies) and transmission quotas (1000 for drama, 85 for news, 675 for factual content), overseen by OfcomThe BBC’s attempt in December as part of an Ofcom inquiry to reduce origination on CBBC to 350 hours and reduce first-run news from 85 to 35 hours, was unfortunate.   It will need to be revisited by Ofcom in the light of the BBC’s post-Covid position, and any changes will need to be evaluated in the light of BBC ambitions to move more content online.
  6. Equally difficult to evaluate are the light-touch interventions around children’s content applied by Ofcom to commercial PSBs Channel 4, ITV and Five after amendments to the Digital Economy Act 2017.  Ofcom decided against quotas, preferring to encourage commercial PSB engagement with children, through the YACF which has approved several commercial PSB commissions.  The unknown element is whether commercial PSBs will pull back from these commitments in the light of Covid and falling advertising revenues, particularly as the YACF can only fund 50% of a programme’s budget.   
  7. The YACF is nevertheless a significant intervention as an alternative funding source for public service content on commercial PSBs, but it requires funding after three years to secure its future.  Top-slicing the licence fee would not benefit licence fee payers, but a small levy on SVOD providers could secure the YACF’s longer term future.
  8. In the light of PSB’s response to Covid-19 from all public service broadcasters, there is a need to think more carefully about how children are served within the PSB eco-system in the longer term.  This necessitates secure public funding for both the BBC and the YACF that does not damage either by drawing on the same licence fee pot.
  9. A major challenge for PSBs is the rise of online services including video-sharing sites like YouTube and paid for SVOD services.  Neither is regulated in the same way as PSB content.  SVOD services like Netflix do offer curated quality content[4], but they are not free at the point of access, and they are not obliged to support domestic production or particular types of content such as news and drama (see BBC quotas). Moreover they do not have any obligations to UK audiences, as their business model is aimed at the global market. According to a 2018 report, although Amazon Prime and Netflix combined, added 2,718 hours of children’s content to their catalogues in 2017, only 98 hours, were original commissions or first-run acquisitions – and only a handful of these would have been UK originations.[5]
  10. Closely linked to the popularity of commercial internationally oriented SVOD services is the need to ensure that PSB children’s content can be found by ensuring its  prominence on OTT and pay TV Platforms.  Prominence is important for discovery – particularly for those children and young people who are no longer watching linear TV. Without interventions to secure prominence young people will not otherwise see any PSB content.
  11. If there is agreement that PSB content needs to be accessed and found easily in the interests of choice and plurality, then there is a case for updating current legislation on PSB prominence to ensure a PSB presence on connected devices, online platforms and app stores that cater for on-demand viewing in addition to prominence on current linear EPGs. Manufacturers would have to ensure that PSB VOD players are given prominence at no extra cost on devices like smart TVs and  set-top boxes.
  12. Regulation of social media and SVoDs  is largely unregulated in respect of children, who can easily ignore the 13 plus age restriction. YouTube is immensely popular with children, but it does not have a public service remit.  Its purpose is different, and there are many occasions when its content does not adhere to the standards expected by parents and society in general. Nevertheless it does have benefits in allowing children, particularly older children to post their own content, and exercise their creativityThese opportunities suggest that broadcasters and producers are not really paying enough attention to young people’s own aspirations to be consulted on and participate in content provision.
  13. In summary UK originated public service children’s content does not thrive unless there are regulatory, funding and distribution structures to support it. It is no surprise that outside of the US, the strongest markets for children’s content are those with comparatively well-funded PSBs who support it in Benelux, Germany, and the Nordics.[6]
  14. Looking more broadly, for the licence fee as a whole, other options are needed that depoliticize the way it is set, and provide more stability and transparency. The involvement of an independent licence fee setting body and a move to an income-based system comparable to Finland, Norway and Sweden, might offer a more equitable solution in the longer term, particularly for those on lower incomes.[7]


  1. Mirroring PSB for adults, PSB children’s services should deliver a range of programming that reflects the diversity of children’s lives in respect of age, gender, class, ethnic background, ability and location. When other non-PSB providers, including SVODs, focus on internationally attractive animation and drama, PSBs should provide an alternative that reflects the concerns and interests of children living in the UK.
  2. While commercial channels run by Disney and Nickelodeon and the SVoDs are appreciated for curated high quality content, they are not in a position to represent UK communities as well as public service broadcasters , because they need to appeal to a transnational audience
  3. In terms of inclusion and diversity PSB children’s departments have been frontrunners with content that reflects the diversity that children encounter in their real lives.  Examples include preschool soap Appletree House, set in a tower block and preschool animation JoJo & Gran Gran (both CBeebies)
  4. However, Ofcom has continuously reported that a significant number of children do not see people that look like them on screen or represent their localities.  In 2018 Ofcom reported that  33% of 8-to-11-year olds and 36% of 12-15-year olds felt there were not enough TV programmes that show children like them. 41% of 12-15-year olds and 32% of 8-11s said there were not enough TV programmes that show children living in the same part of the country as them.[8]  In 2019 Ofcom reported that children in Wales and Northern Ireland are less likely to feel there are enough programmes for children their age, or that show children from the same part of the country as them. [9]
  5. It could be argued that older children are drifting online, because PSBs have failed to offer them something they want to watch or engage with on platforms that they use. This needs to be tackled. The launch of the Young Audiences Content Fund pilot with its remit to re-engage older children could help mitigate this, but BBC plans to reduce local and regional coverage do not instil confidence,
  6. Relevance is an important aspect of PSB and is also relevant  for children – so  geographical quotas should be maintained. However, representation is also a question of broader issues in society around education and access.  Public service broadcasters have a role to play in this through their employment policies and commissioning decisions, but this also needs to extend to those in the independent sector who supply content. Representation cannot be achieved by simply focussing on screen talent, and training.  It needs to be actively managed in ways that give a greater diversity of people access to those jobs where decisions are made.  


  1. The PSB model is important for children because it is accessible to all children.   Even if families do not subscribe to pay TV or SVoD  services, virtually all children have access to television, and it is noticeable that non subscription streaming services largely operated by PSBs, increased their share of  viewing among 2-15 year olds during the height of the Covid  crisis, alongside linear TV with slight reductions in viewing for subscription streaming and YouTube during April 2020.[10]  Access to WIFI and devices (tablets, laptops, smartphones) is still an issue and at the start of lockdown it was estimated that only 16% of working class households were taking part in home schooling, and only 23% of schools in the most deprived areas had access to online portals. [11]    A hasty move to a wholly internet based service risks excluding too many children and families from the most disadvantaged households at this difficult time.  
  2. Longer term the rise in children’s on-demand viewing, particularly on YouTube, which is ‘free’ poses existential threats to PSB children’s provision, as children shift their viewing online. Just like adults, children are attracted by the convenience of watching content at a time that suits them.[12] If children do not grow up watching PSB then they are unlikely to watch it as adults, with dire consequences for future PSB funding  and social cohesion as citizens.
  3. In the interim there is a need to resource developments within PSB  to recognise the shift to online viewing in ways that allow children to find and engage with PSBOne of the consequences for PSBs of the shift to online viewing is that they have to invest more in locating child audiences, through online marketing, YouTube teasers and ensuring discoverability in addition to investing in content.[13]
  4. There is a high risk  that PSBs won’t be able to respond adequately to market changes and developments online in the children’s market if their funding declines. The BBC’s responses are inhibited by pressure on the licence fee, and internal pressures which prioritise news and drama for adults over children’s services.
  5. As the UK heads into economic downturn and higher unemployment services like the BBC iPlayer and ITV player will become more important.  Not everyone will have the resources to afford a subscription to Disney + or Netflix and we risk a greater digital divide if public service provision is made less accessible as an internet-only based service. 
  6. More generally accessibility raises questions about affordability and how those on low incomes might benefit from a reduced licence fee Decriminalisation, as proposed by the Government, seems a blunt instrument, when a more equitable system based on income as in Finland, Norway and Sweden, might deliver better results.
  7. Accessibility is also about discoverabilityPSB involves curation in pursuit of PSB purposes. The risk of personalisation through algorithms is that children might never encounter anything that connects them with public service purposes that reflect citizens’ needs and society as a whole. Debates therefore need to be kept open on how new ways of searching and accessing material are likely to affect informed choice and plurality. Policymakers and regulators will need to be vigilant about these developments to ensure that PSB content is not unfairly penalised by commercial arrangements that promote other types of content through personalised market-driven recommendations. It is important that children can find public service content.

Impact and value

  1. PSB has value for children as a source of age-appropriate, high quality, original, curated children’s content that is trusted by both children and caregivers, and which speaks to and engages with children and young people living in the UK. PSB’s public benefit is even more important with concerns about social media, online harm and fake news, and is underpinned by a regulatory framework that is vital to PSB’s role as a provider of universally available content and services. BBC television is the top source for news among 12-15-year- olds[14] with ITV in third place, suggesting that PSB has a continuing role in supporting children’s interests as citizens-in-the-making who are knowledgeable about and engaged with issues of UK society.
  2. Children’s screen content has also been a significant contributor to the UK’s creative economy over decades as the success of Peppa Pig, Teletubbies, Bob the Builder, In the Night Garden, Wallace and Gromit, and Sean the Sheep shows.  Although many of these properties are now owned by US toy companies (Hasbro and Mattel), it was UK PSBs who took the risk in commissioning them in the first place, boosting the independent sector. If PSBs commission less then there will be fewer opportunities to repeat these global successes.


Looking ahead

  1. The current PSB system is an eco-system encompassing the BBC and commercially funded PSBs each of which approaches the children’s market differently.  Longer term, the way that PSBs reach out to children will have to change, but there is a danger of making hasty decisions too early, and shifting to a wholly internet-based service, when we are still in a transitional period, and when not all families with children have adequate access to online services because of geographical location or lack of resources or both.
  2. Children’s content needs adequate funding.  Although there is a consensus that provision for children is part of the PSB remit, the proportion of children living in the UK is not reflected in financial resourcing by PSBs. In fact, PSB funding on originations continued to decline to £70m in 2017, just 2.8% of the £2,459m, spent by PSBs on all first-run UK originations.[15] This is not an adequate response in the face of technological developments at a time when children’s content needs funding to remain fresh and innovative in more challenging and competitive times.
  3. PSB is  still important for  children as citizens-in-the-making,  but it needs to be allowed to develop and reach children in new ways, as well as reflect  the diverse communities in which children live.  In a more fractured society, where children are confronted with fake news and other difficult content online, the role of trusted content  for children is more important than ever.




[1] J. Steemers (2017) International perspectives on the funding of public service media content for children Media International Australia 163 (1), 42-55; J. Steemers, (2017) Public Service Broadcasting, Children’s Television and Market Failure: The Case of the United Kingdom International Journal on Media Management, 19, 298-314. J. Steemers and F. Awan (2016). Policy Solutions and International Perspectives on the Funding of Public Service Media Content for Children: A Report for Stakeholders. London: Communications and Media Research Institute.  Add Report.

[2] Ofcom (2018) Children’s Content Review, p. 3.

[3] Ofcom (2018) Children’s Content Review

[4] Broadcast (2018) Drama leads the way 4 April.

[5] Bisson and Deane (2018) Where Next for Kids’ TV. Predicting the future of children’s content, 9

[6] Steemers and Awan (2016)

[7] J. Steemers (2020) The Funding of Public Service Broadcasting in Europe – Funding Systems and Decriminalisation - Selected Territories Information Briefing 30 March 2020

[8] Ofcom (2018) Children and Parents Media Use and Attitudes Report 2018 – Research Annex, Figure 30.

[9] Ofcom (2018) Children and Parents Media Use and Attitudes Report 2019, p. 12

[10] Dubit (2020) Kids and Media in the time of Corona

[11] https://blogs.lse.ac.uk/politicsandpolicy/home-schooling-covid-19/

[12] Ofcom (2018) Children and Parents Media Use and Attitudes Report 2018 – Research Annex, Figure 29.

[13] BBC (2017) BBC announces biggest investment in children’s content and services for a generation, Press Release, 4 July

[14] Ofcom (2018) Children and Parents Media Use and Attitudes Report 2018 – Research Annex, Figure 67.

[15] Ofcom (2018) Media Nations, 6.