Written evidence submitted by the Department for Digital, Culture, Media and Sport



Inquiry: the future of Public Service Broadcasting


Government submission and evidence


The Department for Digital, Culture, Media and Sport welcomes the Committee’s inquiry into the future of Public Service Broadcasting and acknowledges the call for evidence, undertaken during a period of unprecedented challenges for the sector due to COVID-19.


Public service broadcasting provides significant benefits to the UK

The PSB system provides significant economic, cultural and democratic value across the UK, reaching a wide audience and being free at the point of use. This provides immense value to the whole of the country, keeping people informed, educated and entertained every day.


The UK benefits greatly from its strong and independent public service broadcasters: the BBC, ITV and STV, Channel 4, Channel 5 and S4C in Wales. These PSBs produce shared moments of all types for people across the country, from high quality and trusted news coverage to the latest gripping drama or entertainment. They are also uniquely well-placed with their obligations, talent and knowledge of audiences to deliver value for money through the creation of high quality and distinctive content.


Maintaining these benefits in a digital age

The government recognises these benefits and is committed to supporting a modern public service broadcasting system that will meet the needs of UK audiences in the future and remain at the heart of our world class broadcasting sector.


The public service broadcasting system as a whole will need to adapt if it is to remain relevant and sustain its provision of public value. The PSBs themselves will also need to adapt in response to significant challenges from new technology, changing audience habits and increasingly competitive markets.


The Government must look closely at how the legislative and regulatory framework underpinning the PSB system may need to change, in order to ensure that it remains relevant and can continue to deliver public value in a sustainable way. We will engage closely with Ofcom as it undertakes its PSB Review, with a view to setting out a way forward in due course.


The impact of COVID-19

At no other point in recent times has the value of a strong and independent set of public service broadcasters been more evident than during the Covid-19 pandemic.


The Government acknowledges the scale of the challenge before broadcasters during this time and is grateful that the BBC and other PSBs have stepped up to deliver content that is educational, informative and entertaining. The public service broadcasters have a vital role to play in supplying information to the public and bringing together the nation in these unprecedented circumstances. They have been an important source of news and in countering misinformation; Ofcom research published on 9 April found that the BBC is by some distance the most sought-after source of news for individuals during the crisis. The Government recognised the key role that PSBs play and designated journalists and broadcasters who are providing public service broadcasting as critical workers to enable them to continue their operations during the lockdown. The Government also notes the success of initiatives taken by the PSBs during the Covid-19 pandemic, from the BBC’s work to educate children across the nation, ITV’s informative ‘stay at home’ campaign and Channel 4’s ‘Lockdown Academy’ of quick turn-around programming for socially isolated audiences.


Covid-19 has had significant financial and practical impacts across the broadcasting sector. Ofcom research[1] has shown that the UK population’s engagement with TV, radio, online news and other home media has grown since the Covid-19 crisis, while the appetite for news about the pandemic has boosted engagement with news across a number of sources, including PSBs. However, recent data[2] indicate that while average minutes viewed on linear TV remain much higher than last year, weekly reach is in decline. We have also seen a significant decline in advertising revenue, as well as considerable challenges in producing programming in line with social distancing restrictions.


These changes are likely to accelerate some pressures on PSBs and the wider system and will require careful consideration by the Government, Ofcom and the sector itself in the months ahead.


The Government’s response to the call for evidence

Given the scale of these challenges to the PSBs and the sector, the government’s primary focus is in supporting the UK’s public service broadcasters and the broadcasting industry in this uniquely challenging time.


The Government’s submission to the DCMS Select Committee’s call for evidence is drawn from the Government’s response to the House of Lords Communications and Digital Committee’s report ‘PSB: as vital as ever’ in February 2020.[3] This response also covers the important issues raised in the DCMS Select Committee’s call for evidence as published on 27 March, including the importance of regulation, representation, accessibility and impact, as set out below.


The Government remains committed to a programme of work to explore the future of the public service broadcasting system and looks forward to responding to the Committee’s findings and recommendations in due course.






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?


The Government believes that public service broadcasters play an important role in ensuring the broadcasting system properly provides for the whole country. Regional production should support production companies outside of London, and commissioning decisions being made in the regions and nations is vital to ensure the proper representation and reflection of audiences around the UK. The recent television shows ‘His Dark Materials’ being produced in Cardiff, and ‘Game of Thrones’ in Belfast are excellent examples of how both PSBs and commercial non-PSBs can support regional production companies.


The Government is supportive of a broadcasting system that supports balanced economic growth, stimulates regional creative industries and provides for audiences across the whole of the UK. In 2017 the PSBs spent around £1.1bn on network and regional programme commissions made outside the M25, delivering 6,453 hours of new network content, which accounted for almost half (49%) of all the PSBs’ total qualifying network hours.


The Government strongly supported Channel 4’s package of measures to increase its regional impact, announced in 2018. This included having 300 roles outside London and setting up its national HQ in Leeds, with smaller hubs in Bristol and Glasgow, and increasing its proportion of out-of-London commissions to 50% by 2023. Government-commissioned economic analysis found that this regional package could have an estimated overall regional benefit of around £390m (GVA) and 4,900 jobs.


The Government also welcomes the BBC’s recent commitment to increase to two-thirds the proportion of its staff out of London. The Government notes that in December 2018, Ofcom consulted on whether its guidance on regional TV production and programming required updating. In June 2019 it published a statement on the changes it intends to make as a result of its findings. The Government welcomes Ofcom’s work in this important area.


However, the Government thinks that more needs to be done as the future of the PSB system is considered. Public service broadcasters should do more to involve people from diverse backgrounds in their commissioning processes and behind the camera. UK television should reflect modern Britain, both on and off screen.


The Secretary of State noted in his speech at the Enders Media and Telecoms Conference in March 2020, that the BBC ‘needs to be closer to, and understand the perspectives of, the whole of the United Kingdom and avoid providing a narrow urban outlook. By this, I don’t just mean getting authentic and diverse voices on and off the screen - although of course this is important. But also making sure there is genuine diversity of thought and experience. And this matters, because if you don’t have that, you miss what’s important to people. And at a time of proliferating content, being relevant matters more than ever.’[4] The Government believes this need is vital for not just the BBC, but for the PSB system as a whole.


The Government is supportive of Ofcom’s work to drive improvements in this area. Ofcom has a duty to promote equality of opportunity in relation to employment in the broadcasting sector and has powers to ask broadcasters to provide information about their equal opportunities policies and the make-up of their workforce. Ofcom’s findings are published in their annual report on diversity and equal opportunities in television.


In July 2019 the Creative Industries Council announced their Diversity Charter, which commits the sector to improving the quality of its diversity data as well as recruitment practices, development, promotion and retention of staff at all levels in order to create a more diverse workforce and develop more output that appeals to people from all backgrounds and regions of the UK.


The Government is also supportive of Project Diamond, which is a diversity initiative backed by the main broadcasters including the PSBs, and collects and publishes the diversity data of people working on or off screen on all UK-originated productions. The Government recognises the challenges facing Project Diamond and encourages the industry to work together to make this data more readily available.



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?


The Government expects public service broadcasters to deliver high-quality, distinctive content for all audiences and licence fee payers across the UK. This is important in order to deliver what consumers want to watch, but also in terms of delivering content that supports the wider objectives of PSB, including to inform audiences, to stimulate learning, to reflect the UK’s cultural identity, and to make audiences aware of different viewpoints. In many cases this content would be underprovided or not provided at all by an unregulated market.


The Government also gave Ofcom new powers under the Digital Economy Act (2017) to publish criteria on commercial PSBs’ provision of children’s programming and, if appropriate, to set related conditions. Ofcom launched a children’s content review in 2017, and as part of this identified areas of concern for the commercial PSBs to address. In July 2018 Ofcom asked the commercial PSBs to develop and share their plans to address Ofcom’s concerns. The commercial PSBs responded in early 2019, and their plans were welcomed by Ofcom. Ofcom will continue to monitor the broadcasters’ implementation of their plans and will work with the industry to ensure young audiences receive a range of high-quality programmes.


Ofcom published its report (Small Screen: Big Debate) in February 2020 which reviewed how public service broadcasting has delivered for UK audiences over a five-year period (2014-2018). This is the latest part of Ofcom’s PSB Review and it aims to publish recommendations by Spring 2021, which will aid the Government in considering reform.


Any consideration of regulation for PSBs must also recognise the unique regulations set out for the BBC. The Government considered the appropriate regulatory framework for the BBC during Charter Review 2015-16 and the new Charter introduced Ofcom as the independent external regulator for the BBC. The White Paper noted that Ofcom represented ‘a strong regulator to match a strong BBC’ as set out in the findings of the Clementi Review; it had experience with the broadcasting sector and already fulfilled some regulatory functions in regard to the BBC.


This new BBC regulatory regime has only been in effect since April 2017. In this time, Ofcom has issued several reports which firmly hold the BBC to account on a range of issues, including with regard changes to its public services. The most recent Ofcom annual report on the BBC was published in October 2019.


In the coming years we will of course be taking a proper look at our public service broadcasting system, including how it should be funded, and the BBC’s central role within it. This will start with the consultation on whether to decriminalise TV licence evasion, which will be followed by the process for agreeing the next licence fee settlement. And then, the mid-term review of the BBC Charter, due to take place by the end of 2024, which is an important process and will consider key questions including whether the current regulatory arrangements for the BBC are working effectively and whether any reforms are necessary. All of this will be in the context of a licence fee based charter that runs until 2027. The Government will consider the future of wider PSB reforms throughout this period to ensure that public value is delivered in a sustainable way.


The Government will also be implementing regulatory change through the implementation of the revised Audiovisual Media Services Directive. The Directive was revised in November 2018 to take account of market changes, such as the growing amount of content consumed on video-sharing platforms. The updated Directive aligns rules for video on demand and linear television more closely, and extends new rules for video-sharing platforms (such as Youtube or Facebook) for the first time. The Government consulted on proposed plans for implementation through consultations closing on 22 August and 17 September 2019 respectively, and the response to these consultations has been published.


The revised Directive contains strengthened provisions to protect children from inappropriate audiovisual commercial communications for foods high in fat, salt and sodium and sugars, including by encouraging codes of conduct at EU level, where necessary. Importantly, certain audiovisual rules extend to video sharing platforms: services such as YouTube as well as audiovisual content shared on social media services, such as Facebook, are covered by the revised Directive. Video-sharing platforms are also required to take appropriate measures to protect people from incitement to violence or hatred and content constituting criminal offences. The revised Directive extends the obligation to protect minors also to video-sharing platforms, which now need to put in place appropriate measures.





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?


One crucial part of accessibility or ‘discoverability’ of PSB services is prominence. The Government recognises the importance of high-quality PSB content being discoverable and widely accessible to viewers as far as possible.


Under the Digital Economy Act 2017, the Government required Ofcom to publish a report which looks at the ease of finding PSB content across all platforms. In 2018 Ofcom consulted on how the prominence regime may need to change to ensure public service content remains discoverable regardless of how consumers are accessing it. Ofcom published its report and recommendations in July last year, including recommendations for legislation.


The Government has committed to act on Ofcom’s prominence recommendations and is exploring the potential for legislation. The Government will set out next steps in due course.


The Government has encouraged Ofcom to be ambitious and innovative in its approach to its PSB Review and to explore the issues that it considers relevant. This may include looking at whether the balance between benefits and obligations remains appropriate in the relationship between the PSBs and platform providers. The Government will continue to work closely with Ofcom over the coming months and will consider Ofcom’s recommendations when they are made.


The Government recognises the value of Digital Terrestrial Television (DTT) to many audiences, and therefore to the future of the PSB system. Several DTT multiplex licences are set to expire in the coming years and the Government is considering how to ensure that any changes to the DTT regime are proportionate, evidence based and fit for purpose. Next steps will be set out in due course.



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


The Government is clear that public service broadcasting plays a vital role in the wider UK media ecology and provides significant cultural, economic and democratic value to the UK at both local and national levels. It is free at the point of use and works for the public benefit to foster shared experiences, stimulate learning, and inspire change. The good that public service broadcasting can do and the impact it makes on our society, our economy and our standing around the world should not be lost.


PSBs spent around £2.5bn[5] on UK content in 2017, which contributed to supporting 194,000 high skilled jobs in the audio visual sector[6] and a thriving independent production sector. In addition, global demand for UK content - particularly that created by the PSBs - has been

cited as a factor in the UK’s consistently high ranking in global soft power indices, including placing second in Portland Communications’ ranking in 2019.


Ofcom’s recently published report: Small Screen: Big Debate found that: “The PSB system plays an important role in the UK’s wider creative economy. Investment by the PSB channels makes up the bulk of the UK production sector’s revenues and how the money is spent is underpinned by regulation that supports a vibrant and diverse production sector across the nations and region.”

The Government also welcomes the valuable contribution that commercial non-PSBs also make to the cultural, economic and democratic benefits provided by the sector as a whole. For example, the Government notes that COBA reports[7] that in 2018 commercial broadcasters invested more than £1.1 billion pounds a year in UK content; more than doubled their spend with UK external producers since 2011 to support independent production; and exported over 21000 hours of UK content across their international channels to provide a global platform for UK talent.


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 Government is supportive of a modern PSB system that can remain relevant and can continue to meet the needs of UK audiences in the future.


Ofcom’s PSB Review will play an important role in strengthening our understanding of how PSB, and the regulatory framework which supports it can adapt to ensure the system’s continued resilience in the changing technological environment. The Government welcomes that Ofcom’s ongoing PSB Review will “..bring together evidence not only about the main PSB services, but also the range of media services – television, radio, online and elsewhere – available to consumers in the UK”.


The Government’s consideration of reform will take into account changing technology, as well as wider developments in areas such as audience habits and expectations, and the overall structure of the market. Any additional financial or regulatory burdens would need to be considered as part of the overall impact of any wider package of reform, in ensuring a modern, sustainable and successful PSB system. The Government will set out further information on its work in this area in due course.




[1] Ofcom: Covid-19 News and Information: consumption and attitudes - weekly reports

[2]  Ofcom report: Effects of Covid-19 on TV viewing


[4] https://www.gov.uk/government/speeches/secretary-of-state-oliver-dowdens-speech-at-the-enders-media-and-telecoms-conference

[5] Ofcom Media Nations report 2018

[6] DCMS Ad-hoc statistical analysis: 2017/18 Quarter 3 - DCMS Sector Economic Estimates: Audio Visual

[7] COBA content report 2019: Multichannel investment in UK Television programming - Executive summary