Transparency and accountability in the Media Bill

The Media Bill will allow Public Service Broadcasters (PSBs) to meet their obligations through online video services. We are calling for much greater transparency and accountability.

We believe all PSBs providing online video services in the UK should be required to disclose details about their platform’s algorithm and operating principles to the regulator (Ofcom), in return for PSB status. Algorithmic transparency is essential if Ofcom is to adequately monitor how PSBs prioritise and promote content to audiences through personalised online services.

Towards a digital-first Public Service Media

PSBs are rapidly pursuing ‘digital-first’ strategies that place online video services, such as BBC iPlayer and ITV X, at the heart of their operations. Streaming platforms are no longer simple catch-up services. In today’s on-demand world, they represent the fulcrum of public service media distribution; prioritised for investment, innovation, commissioning and promotion.

New productions are frequently released online first (often weeks ahead of linear schedules) whilst some genres, programmes, and channels are only available online. Even the identities of streaming platforms are fusing with those of the PSBs. For example, the All 4 platform was rebranded as simply Channel 4 in 2023, whilst BBC trailers now urge audiences to “watch on iPlayer” without even mentioning the broadcast channel.

Media Bill accelerates the digital transformation

The Media Bill enables PSBs to further this digital transformation by establishing parity between online video services and traditional linear channels. PSBs will no longer need to broadcast public service content on television channels to meet their obligations. Making programmes available online will be sufficient.

It should be noted that such freedoms do not apply to news and current affairs, which will retain linear-only quotas, suggesting there may be concern within government that public service content will not be prioritised in an on-demand environment.

The Bill obliges PSBs to ensure public service content is ‘readily discoverable and is promoted by the service’ (28/1, 362AA/3b), but this protection only extends to content set out in the revised remit.

The new ‘simplified’ remit excludes many key genres that embrace public service values (international issues, documentary, science, arts, religion, etc.), leaving them unprotected and without the guarantee of being discoverable, let alone promoted.

A lack of transparency and accountability

Linear television channels enable PSBs to offer a balanced diet of content and genres that inform, educate, and entertain their audiences. Programmes covering important social matters are scheduled alongside programmes of mass appeal, helping audiences to encounter new issues, information, and perspectives.

By contrast, online video services use algorithms to provide unique and tailored user experiences; recommending content according to each person’s particular viewing habits and presumed interests.

PSBs may be willing and able to recreate opportunities for serendipity within online services, but the Media Bill establishes no obligations for them to do so.

Critically, the Bill does not give Ofcom the necessary powers to access, understand, and evaluate the algorithms used by PSBs. Unlike linear channels with published schedules, the regulator and wider civil society cannot monitor how content is prioritised, presented and promoted within streaming services.

There is no way to evaluate whether important content is receiving the online equivalent of primetime or being consigned to the virtual graveyard. Without access to the algorithm and operating principles, we cannot know whether the values and principles of public service media are being applied online, or not.

Algorithmic transparency

We believe that algorithmic transparency should be a prerequisite to obtaining PSB status. The Media Bill must include obligations on PSBs to disclose the operating principles behind their online video services, including the algorithms used to determine how content is served to audiences, to Ofcom.

The EU’s Digital Services Act requires large online platforms (search engines, social media sites, etc.) to disclose information about their algorithms to regulators and submit relevant data to independent auditors.

We believe the EU’s approach to ‘algorithmic transparency’ should inform the Media Bill in developing safeguards and appropriate regulation for the online delivery of public service media.

The International Broadcasting Trust (IBT) is proposing an amendment to the Bill requiring algorithmic transparency from all PSBs, and helping protect public service media in a digital-first environment.

Contact IBT

Gareth Benest (Director of Advocacy)

Mark Galloway (Executive Director)