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Defend public service broadcasters
The Freelance offers a response to the government: please send yours by 31 August 2026.
Graphic design is my passion: the Green Paper cover
SHOULD public service broadcasters be guaranteed prominence in YouTube video listings? Yes. If they are not, we may wave goodbye to the entire concept of regulated, trustworthy media in the UK. This would be a disaster – because it would be a win for the forces that despise truth.
You may, on seeing the first questions in a UK government consultation, think: “No, I don't want to give preference to state media. Let them compete with freelance YouTubers for eyeballs.”
You may think that at first glance. But: follow the money. At the end of the consultation – which we doubt many who have the reaction above will reach – is a proposal to shut down television broadcasting in 2034. That would “free up spectrum”. What that means is that the government could auction off use of the radio frequencies involved. The auction in 2000 of frequencies for 3G mobile service brought in £22 billion.
Instead, the government proposes that everyone watch TV on the internet. It quotes YouTube’s CEO Neil Mohan declaring in February 2025 that “YouTube is the new television”. It describes “an agreement between the BBC and YouTube... which will see the BBC making content specifically for YouTube”. It reports that the BBC and YouTube were neck-and-neck with 19 per cent each of video viewing in the third quarter of 2025. Netflix, at £70 to £220 per year, had 10 per cent.
Where this is going is clear. The government wants to sell the radio frequencies. What news and culture people see would be put in the hands of the YouTube algorithm – not “viewer choice” but the code that responds to viewer requests. In the consultation the government seeks to redefine “public service broadcasters” (PSBs) as “ public service media” ahead of that handover.
Alphabet Inc, owner of Google and YouTube, would thus be handed the key to turn off the BBC, Independent Television News and Channels 4 and 5.
Unless, that is, regulation ensures that online distributors of public service broadcasting prominently display it. This is not a new idea. The Media Act 2024 mandated that smart TVs do that. Though Alphabet/Google is averse to regulation, it is not averse to having monopoly status and must accept the consequences.
To preserve the important functions that regulated public service broadcasters are indented to fill, such regulation is required now.
This is not, of course, to claim that public service broadcasters are not perfect. London Freelance Branch last year held a meeting in Parliament largely about the refusal of BBC senior management to broadcast Gaza: Doctors Under Attack, even after BBC staff and legal teams had approved it. But, as Branch chair Pennie Quinton observed at a recent meeting: it is because the BBC is a public service broadcaster that the film-makers could argue with it. Netflix can simply say “no”.
And: PSBs are not “state media”. They are media regulated under the authority of the state and funded either by the licence fee or by advertising.
Regulation guaranteeing prominence for PSBs does not mean that independent sources will no longer be visible. For an explanation of how that can work see the Freelance answer to question 4a below.
The Freelance draft response
1. What are your overall views on the future of television and media in the UK, related to the topics in this green paper?
There is a crisis in truth and trust. Misinformation and disinformation are rife and are killing people. Authoritarians famously promise to “fill the zone with shit” to convince potential followers that there is “no such thing as truth”, so they may as well vote according to their irrational prejudices, or others’.
If anyone has a better remedy than ethical journalism distributed by trusted, regulated public service broadcasters, I would love to hear about it. Now, public service broadcasting must remain freely and prominently accessible to all.
2. What measures do you feel would be most effective for the government to take to overall address these challenges [of funding for PSBs]?
I refer you to the National Union of Journalists News Recovery Plan and to its proposal for an ongoing digital tax to provide sustainable future funding. Personally. I would extend a levy on the giant internet corporations to be sufficient to fund the BBC – still independently of general taxation – as well as the other measures that the NUJ proposes.
See www.nuj.org.uk/resource/news-recovery-plan.html
3. How often do you encounter news you feel is untrustworthy when online (for example, something you consider to be misinformation)?
Very often
4. Do you believe “trustworthy” news content should be more visible on social media?
Yes
4a. How would you like this to look in practice, so that audiences can access trustworthy news more easily on social media?
Regulation should ensure that users of all relevant services see a “mosaic” of results on all listings, with PSBs making up perhaps a third of the top 20 results. That way viewers clearly have a choice and self-publishers have a chance to appear at the top among the big players.
If anyone has any ideas for ways to give some preference to broadcasters such as Deutsche Welle - whose English service I now have open on my phone - I would be very interested to hear both.
It is a nonsense to suggest that this mosaic be optional: giving a viewer an easy option to lock themselves into, for example, a “silo” of anti-vaccine lies is not a freedom but an invitation to sell oneself into servitude.
5. If the government gives prominence to trustworthy providers of news (meaning by making them more visible online), should this prominence be ongoing, and “always on”, or only active during periods of crisis?
Ongoing and ‘always on’
6. Do you feel individual users should be given an option in whether prominence measures for trustworthy news content are switched on or off for them?
No
7. How concerned, if at all, are you about the impact of misleading or unreliable information on society?
Very concerned
8. How concerned, if at all, are you about the impact of misleading or unreliable information on democracy?
Very concerned
9. Public service media refers to organisations such as the BBC, ITV, Channel 4 and S4C. Which of the following statements most closely reflects your view on the role of public service media in helping people critically engage with news and other information they encounter online or offline? (select only one)
Public service media has a role in supporting critical engagement, and should do more
10. How important, if at all, do you think it is for people to be able to judge the accuracy and reliability of information they encounter, for example online or in the news?
Very important
11. How valuable, if at all, do you believe collaboration between public service media, civil society organisations (for example charities and education groups), and the media sector could be in supporting people to critically assess information?
Somewhat valuable
12. Which of the following models, if any, do you consider most effective for further media sector collaboration in this area? (select all that apply)
Informal coordination and sharing of learning
A structured forum with agreed objectives and reporting
12a. Please provide any supporting evidence as to why you think the model(s) you selected are effective for collaboration between public service media and the media sector.
As the National Union of Journalists has observed, the problem with this proposal is that new duties keep being piled on PSBs with no support and it “has stressed that any obligation must come with additional, demarcated government funding”.
13. To what extent do you agree or disagree with the government’s assessment of the case for change relating to the future of digital terrestrial television?
Strongly disagree - audiences should definitely not adopt IPTV and similar technologies
13a. Please provide further rationale for your answer and any relevant evidence.
I am deeply sceptical about turning transmitters off at all. Consider the problems already encountered with turning off traditional telephone service: no-one can now make an emergency call from a landline during a power cut. Consider the role of broadcasting in getting information out during a natural disaster.
I am startled to read in the Green Paper that an argument for turning off transmitters is to promote sales of broadband services, especially to the elderly or confused: “Digital exclusion is linked to a 0.8 to 0.9 point deficit on a 10-point well-being scale... Broadband adoption could mitigate this deficit by facilitating social connection and accessing essential services.” This is especially odd since the cessation of traditional analogue telephony means that everyone who has a landline has an Internet Protocol connection, whether or not they currently pay to be allowed to connect more digital devices than their phone to it.
14. Which option do you prefer as timing for [digital terrestrial television ] switch-off?
Neither 2034 or 2044
14a. Please provide further rationale for your answer and any relevant evidence.
See my answers to question 13a.
15. Do you have evidence that another timeframe is preferable to the ones specified in this consultation?
It is rather the duty of the government to provide evidence that the needs for communication to citizens in emergency and for adequate service to the elderly or confused can be met/
15a. For industry/organisations only: To deliver an IPTV transition would require collaborative working with audience groups, industry and across government. Please outline your organisation’s commitment to supporting this work, including relevant experience, resources, and innovative solutions as to how you would deliver this transition.
Not applicable.
16. To what extent do you agree or disagree that the challenges identified in the green paper (delivering for all audiences; maintaining a reliable television service; promoting competition and innovation in the television industry and supporting a sustainable future for PSM providers) capture all of the considerations when making a decision on whether, and how best, to support audiences to adopt IPTV and other similar technologies?
Strongly disagree - the challenges definitely do not capture all of the considerations
16a. Please provide further rationale for your answer.
See above, particularly the point about communication to citizens in emergency when power supply fails.
17. In your opinion, which, if any, of the challenges are most important to you? Please rank in order of importance, where 1 is the most important to you.
[3] Delivering for all audiences...
[2] Maintaining a reliable television service...
[4] Promoting competition and innovation in the TV industry...
[1] Supporting a sustainable future for public service media providers...
18. In the event of an IPTV transition, which of the following, if any, do you think are the most important to ensure everyone can still access television from their own home? Please rank in order of importance, where 1 is the most important to you.
No response.
19. What are the likely environmental impacts associated with both a 2034 transition and 2044 DTT switch-off (transition to IPTV)?
No response.
20. Is there anything else you would like to add regarding the future of TV distribution that has not already been captured?
No response, yet.
21. Chapter 3.2 of the green paper sets out some of the challenges regarding the future of TV regulation, such as which TV-like services should be regulated going forward, and to what standard. Is there any information or comment you would like to provide in relation to the future of TV regulation?
As noted above, there is a crisis in truth and trust. Regulation of and support for ethical journalism by public service broadcaster is an absolutely essential contribution to preventing a slide into a society governed through disinformation – which implies the end of meaningful democracy and, indeed, the end of free markets, which depend on accurate information.
Prominence of PSM content in the platform age
22. How easy or difficult is it for you to find culturally relevant content on video platforms, including video sharing platforms like YouTube and TikTok and streaming platforms like Netflix and Amazon Prime Video?
Somewhat difficult - I have some issues in finding culturally relevant content on these platforms
23. To what extent do you agree or disagree that content from public service media providers (like the BBC and Channel 4) should be easier to find on video platforms?
Strongly agree - it should definitely be easier to find Public Service Media content on these platforms
23a. What do you see as the benefits of content from public service media providers (like the BBC and Channel 4) being easier to find on video platforms?
See earlier responses, I reiterate my proposal that regulation should ensure that users of all relevant services see a “mosaic” of results on all listings, with PSBs making up perhaps a third of the top 20 results. That way viewers clearly have a choice and self-publishers have a chance to appear at the top among the big players.
23b. What types of content from public service media providers do you think should be easier to find on video platforms? (select all that apply)
Select all, even sport.
23c. On which video platforms do you think content from public service media providers should be easier to find?
Regulation on prominence should apply to all platforms that deliver PSB output in or to the UK.
24. Do you regularly create video content and upload it to video sharing platforms, such as YouTube and TikTok?
Prefer not to say
24a. As a content creator or someone who uploads content to video sharing platforms, are there additional changes or features that you would want video sharing platforms to offer?
Primarily in response to the following question: content should be discoverable through a deterministic search algorithm that permits rigorous queries of the form “fish AND chips NOT peas” - in addition to any other service. All recommendation algorithms that operate alongside this should be transparently documented, including publicly listing the sources of data used to “train” any “artificial intelligence” that is deployed.
24b. Thinking about the video sharing platforms you upload and share content on, do you have sufficient awareness of how content is shown to viewers through the algorithms?
I do not have sufficient awareness of how the algorithm works
A new system of public service media for television
25. Which of the following, if any, attributes of public service media content do you value the most? Please select (up to) your top three.
[2] Diverse programming - content that features people like me, and people from different backgrounds
[1] Quality news - news content that is accurate, and helps me better understand what is going on in the world today
[3] Regional coverage - programming or content that keeps me informed about my area
26. To what extent do you agree or disagree with the suggestion that the public service media system needs to be reformed away from the current model that uses broadcast licences?
Strongly disagree - I feel strongly that the system should continue to use broadcast licences
26a. Please provide a reason and any supporting evidence for your view.
Your questions make it difficult to expound on the view that PSB status (or, as you put it, prefiguring the outcome of the consultation, “public service media”) should continue to be bestowed on institutions.
The alternative is a regulatory hellscape that includes a government body that decides whether small channels or individual videos make the grade. No to that.
27. To what extent do you agree or disagree that each of the following should be considered by government as principles of the public service media system?
Universality: Strongly Agree
Public service media content: Strongly Agree
Systemic sustainability: Strongly Agree
A sustainable public service media compact: Strongly Agree
28. Please rank, in order, your preferred model of the public service media system, where 1 is your most preferred model:
[1] A model focused on PSM institutions
29. Do you have any further comments you would like to add on the content covered by this chapter, or any further information that will aid us in interpreting your responses?
Not yet.
30. Do you have any evidence of the equalities impacts of any proposals set out in the consultation?
No.
Again: the consultation closes on 31 August 2026. I welcome your comments at consult@londonfreelance.org
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