The UK’s public service broadcasters (PSBs) are facing a series of interconnected and existential challenges. As well as declining audiences, disruptive technologies and global market pressures, our public media institutions have become increasingly commercialised, weakened by political interference and isolated from the publics they are supposed to serve.

Yet debates about our PSBs – and the wider ideals, principles and purposes of public media – are often conducted in exclusive, technical spaces dominated by commercial interests, government policymakers and the broadcasters themselves. The public, who should be at the centre of our public media system, are far too frequently left out of these crucial conversations.

READ the MRC’s initial submission to Ofcom’s PSM Review

In September, the media regulator Ofcom published the terms of reference for its latest Public Service Media (PSM) Review. This Review is a five-yearly assessment of how well the UK’s public service broadcasters have been serving audiences, and is part of Ofcom’s statutory requirements as the oversight body for PSM regulation. As well as detailing the delivery of PSM services and content over the last 5 years (covering 2019 to 2023), the Review intends to explore how the UK’s public service broadcasters – the BBC, Channel 4, ITV, Channel 5 and S4C – have been impacted by the ongoing shifts in audience habits, media technologies and market pressures. Ofcom will also consider recommendations to “support the sustainability of public service media” in the future.

This PSM Review comes at a critical moment for the UK’s public media. Following decades of deregulation and ideologically-motivated attacks, organisations like the BBC, Channel 4 and the wider ‘ecology’ of rules and regulations supporting PSM are under serious threat. The public’s own sense of the relevance of PSM, their connectedness to PSBs as national institutions, and their willingness to pay for measures like the TV licence fee, will determine whether this model can be sustained and enhanced in a widely dysfunctional media landscape.

With these challenges in mind, the Media Reform Coalition has produced an initial submission to Ofcom’s PSM Review, focussed on their ‘Phase 1′ assessment of how PSM has been delivered for UK audiences over the last five years. As well as outlining our own evidence and analysis on the state of UK PSBs’ content, investment and benefits to the public, we also outline our serious concerns about how Ofcom looks set to conduct the PSM Review, and offer recommendations on how the regulator can enhance its assessments by providing opportunities for the public to meaningfully contribute to, and lead, these conversations about how PSM is performing – and how it can be transformed for the future.

Our headline findings and recommendations for Ofcom’s Phase 1 examinations are:

PSM institutions – along with the fundamental purposes of public media as a policy intervention – face chronic and existential challenges. Financial insecurity, stemming from a decade of public funding cuts and the collapse of traditional commercial revenues, has accelerated the decline in UK PSBs’ provision of highly-valued and socially beneficial PSM genres. We are especially concerned that, without an immediate and significant change in policy, the public’s sense of the purpose and relevance of PSBs – and in particular citizens’ personal and shared connectedness with PSM as national institutions – will collapse.

PSM delivery has been seriously undermined by deregulation, public funding cuts and market capture in the UK production sector. Adjusted for inflation, total investment in broadcast TV and AV content by the PSB channels has fallen more than 30% from 2010 to 2023, a cut of just under £1.3bn from £4.28bn to £2.99bn. The BBC’s public funding has been cut by 38% in real terms since 2010, leading to extensive cuts in services and increasing monetisation of BBC productions for commercial gain. The 2024 Media Act, passed under the last parliament, is likely to worsen these trends due to its deregulation and narrowing of the legislative definition of Public Service Broadcasting.

The PSM Review needs to be informed by comprehensive qualitative assessment and guided by genuinely participatory public deliberation on the social and cultural impact of PSBs. This kind of interrogation will require sustained and active engagement with the public than is possible with consumer research methods. We urge Ofcom to extend its PSM Review to conduct large Citizens’ Assemblies with the public, just as it did in 2020, to generate novel findings on audiences’ views on the current performance of UK PSM and to enable participants to develop their own recommendations, priorities and ideals for future PSM policy.

Ofcom should use the PSM Review to communicate, authoritatively and unambiguously, the scale and significance of the many challenges threatening the future of UK public service media. Ofcom will need to impress upon government, policymakers and the industry the urgent need for radical reforms to sustain PSM as a vital and highly-valued media policy intervention. Given the rapid speed of market developments and shifting audience habits, further delays and continued disinterest from policymakers will lead to a continued failure to serve the needs and interests of the UK public.

Phase 1 and Phase 2 of the PSM Review will need to recognise and highlight the role of these persistent deregulatory trends in PSB policy as a major contributor to declining provision. Without an immediate and significant change in policy, the public’s sense of the purpose and relevance of PSBs – and in particular citizens’ personal and shared connectedness with PSM as national institutions – will collapse. This will fatally undermine the public consensus for sustaining PSM intervention in media markets, as mechanisms such as the TV licence fee (or any future public funding model for the BBC) and wider public regulations will be seen as less relevant, popular or impactful for audiences.