Submission to the DCMS Media Green Paper
News-watch responds to proposals for privileged news prominence and public-service media literacy, arguing that BBC and Ofcom accountability must be strengthened before institutional authority is expanded.
Document type
Consultation submission
August 2026
AuthorS
This submission responds to the Department for Culture, Media and Sport’s 2026 Media Green Paper, Watch this space: a new strategic direction for UK media. The Green Paper proposes greater online prominence for public-service media and other qualifying news providers, alongside a wider media-literacy role involving broadcasters, Ofcom, civil-society organisations and technology companies.
News-watch argues that these proposals raise a prior question of accountability. Institutional status, regulatory inclusion and reported public trust do not in themselves establish that a provider’s output is consistently accurate or impartial. Any prominence system would influence which sources citizens encounter and which organisations receive additional authority.
Drawing on more than 25 years of monitoring, the submission explains that failures of due impartiality are often cumulative, arising through contributor selection, framing, language, omission and editorial emphasis across many items. The current BBC and Ofcom complaints framework is principally designed to assess individual programmes or narrowly linked series, making it poorly suited to testing evidence of sustained patterns.
The submission recommends that accountability should precede privilege. It calls for precise, viewpoint-neutral and appealable eligibility rules; a complaints route capable of considering tightly defined cumulative evidence; transparent governance for media-literacy initiatives; and safeguards for user choice and genuine source plurality.
Five principle arguments
1. Trustworthiness cannot be conferred by institutional status
Public-service designation, recognised-news-publisher status or membership of a regulator describes institutional form, not editorial performance. Any provider receiving privileged visibility should be assessed against published, auditable and independently appealable criteria.
2. BBC accountability must precede further privilege
Across the eight reporting years from 2017/18 to 2024/25, the BBC recorded 2,275,387 complaints. Only 4,944 reached its Executive Complaints Unit, while 38 due-impartiality complaints were upheld or partly upheld. Ofcom recorded four BBC breaches, only one concerning due impartiality.
3. The present system cannot test cumulative evidence
Imbalance often emerges across contributor choice, framing, language, omission and repeated coverage. Yet BBC and Ofcom processes usually assess individual programmes or narrowly linked series, leaving service-wide and cross-platform patterns largely outside regulatory adjudication.
4. Media literacy requires independence and transparency
Media literacy should strengthen citizens’ ability to examine every source, including government, regulators, public-service broadcasters and established publishers. Funding, governance and institutional relationships should be disclosed, with safeguards against contested editorial judgements being converted into trust signals or platform design.
5. Prominence must preserve choice and plurality
Any prominence system should explain why sources are favoured, remain viewpoint-neutral and allow users to alter or disable it. It should protect smaller and specialist providers and be tested against genuine source diversity rather than institutional convenience.
Accountability Before Privilege
The submission asks DCMS to reverse the sequence proposed by the Green Paper. Public-service media and favoured news providers should not receive additional prominence or authority until the standards used to justify that privilege are transparent, testable and subject to effective independent redress.
i. Withhold legislation for trustworthy-news prominence until Parliament has approved precise eligibility, transparency and appeal provisions.
ii. Reform BBC and Ofcom complaints law to permit tightly defined cumulative and cross-platform impartiality cases.
iii. Commission an independent audit of the BBC complaints system and the evidence used to describe public-service news as trustworthy.
iv. Publish a complete governance and funding map of Ofcom’s Making Sense of Media programme and the proposed joint media-literacy initiative.
v. Define media literacy as the development of independent critical judgement and prohibit its use to prescribe conclusions on contested political questions.
vi. Require user choice, explanation and source plurality in any prominence mechanism.
vii. Create structural separation and parliamentary oversight for Ofcom’s enforcement, convening, funding, standard-setting and complaints functions.