Forget Iran, China, Russia or Zimbabwe. Rather than warning of the consequences should Britain adopt a “Stalinist-style state regulation” (The Sun, November 6), we could do well to compare ourselves to other countries abroad – that actually have a free press.

Common ground

In a whistle-stop European tour, Reuters Institute visiting fellow Lara Fielden compiled material from 6 countries for her report Regulating the Press: A comparative study of press councils. The report was submitted to Lord Justice Leveson during the Inquiry, with an eye to the questions he raised: How do they do things elsewhere? And what is the situation in Germany, Denmark, or other countries? “It may be voluntary, it may be mandatory, but it is complementary,” said Fielden earlier this month as she outlined the key themes of her report at University College London. Fielden argues that the UK government could benefit from keeping in mind one common feature that links the press councils in Germany, Finland, Sweden, Ireland, Denmark and Australia, regardless of their cultural, historical and political context: “the threat of statutory intervention followed by an expedient industrial accommodation.” Another area of shared ground is that these press councils all have publication of an adjudication or correction as their key sanction. This first-line punishment provides an ethical complement to the law and an easy alternative to fines, damages or legal proceedings.

Shared problems

While there are many shades of regulation to be found in these countries, all their press councils are grappling with the same challenges which we now face, regardless of recent scandals. These concerns – of media plurality and media power – were bubbling underneath the surface long before phone-hacking was unearthed and condemned. These countries all share a common interest in the free press and yet they have a tradition of press councils. While we can’t just take them as a blueprint, there are lessons to be learned. In particular, Fielden argues that the current regulatory framework for UK media – separating broadcast, newspaper and online content – has run its course. The starting point for regulatory reform should lie not in what the industry will reluctantly accept, nor what the state can get away with – but in the public interest of regulation itself. With this in mind, it will be interesting to see what lessons from overseas have been absorbed by the Leveson Inquiry. Tomorrows’ statement will provide many answers.

Erik Hoffmann