Watch this Space: Designing the future of UK television
The UK Government’s Watch this Space: A new strategic direction for UK media Green Paper asks some important questions about the future of television.
At Spicy Mango, we broadly agree with its starting point.
Television is becoming an IP-led medium. The distinction between broadcast and online video is increasingly difficult to sustain. Audiences move fluidly between linear television, broadcaster streaming services, global subscription platforms, YouTube and other video-sharing services. As DTT audiences decline, maintaining a nationwide transmission network for an ever-smaller proportion of viewing will inevitably become harder to justify.
There is therefore a strong case for reform. Where we are more cautious is over what that reform is intended to achieve.
The transition to IP creates an opportunity to design a more open, innovative and competitive television market. It should not become an exercise in reproducing the structures and audience dynamics of the broadcast era within a new generation of digital platforms.
That distinction informed much of our response to the consultation.
Our underlying principle is relatively simple:
Regulate harms, not competitors. Protect outcomes, not incumbents.
Audience change is not necessarily market failure
One of the challenges running through the Green Paper is the declining reach and influence of traditional broadcasters, particularly among younger audiences.
The Government describes domestic broadcasters, including public service media providers, as increasingly having to fight to be “seen and heard” in a fragmented and competitive market.
That is a legitimate policy consideration. Public service broadcasters play an important role in UK media, and there are clear public-interest outcomes that Government may reasonably want to preserve.
But there is a danger in treating the declining reach of institutions we value as evidence that the market itself has failed. They are not the same thing. Audiences have moved for many reasons, and not all of them are problems requiring regulatory correction.
Streaming platforms, video-sharing services and digital-native publishers have changed expectations around personalisation, interfaces, content formats, search, recommendation, accessibility across devices and the ability to consume content whenever and wherever people choose.
In many cases, newer services have gained attention because they have built products that audiences prefer using. That is competition.
It may be uncomfortable for established broadcasters, and it may create legitimate questions about how certain public-interest outcomes are sustained, but competitive displacement should not automatically be reclassified as market failure simply because the organisations losing share are culturally or institutionally important.
This matters because the diagnosis determines the regulatory response. If audiences cannot access important public-interest content because of structural barriers, intervention may be justified.
If audiences are choosing other products, formats or services, attempting to reverse that change through regulation is a much harder proposition to defend.
At its worst, prominence or platform intervention could become a mechanism for trying to recreate historic patterns of audience attention. We do not think regulation should do that.
The objective should be to preserve clearly defined public-interest outcomes, not historic levels of institutional influence.
An IP-first future should arrive sooner rather than later
On the underlying technology transition, our view is considerably less cautious.
We support a managed DTT switch-off by 2034 rather than 2044.
The fundamental technical question has already been answered. IP networks routinely deliver video services to very large audiences, including around major sporting, entertainment and national events.
The question is no longer whether television can be delivered over IP. It is how the remaining barriers to universal adoption should be addressed.
That does not mean a transition would be trivial.
Universal television over IP creates genuine challenges around broadband availability, affordability, resilience, accessibility and consumer equipment. But we see these as engineering and implementation requirements for a successful transition rather than reasons to maintain parallel infrastructure for another decade.
Modern IP platforms can be designed with geographic redundancy, multiple delivery routes, distributed content delivery, automated capacity management, extensive monitoring and graceful degradation.
No distribution system is immune from failure. The objective should be to engineer appropriate resilience across the whole delivery chain, from contribution and cloud infrastructure through to broadband access and the consumer device.
Notably, the Green Paper itself identifies potential benefits from a 2034 transition, including earlier cost efficiencies, spectrum benefits and faster innovation in content, services and user experience.
The more productive question is therefore not whether IP can replace DTT. It is what needs to be true by 2034 for everybody to make that transition successfully.
Our ranking of the principal transition challenges reflected that:
Promoting competition and innovation.
Delivering for all audiences.
Maintaining a reliable television service.
Supporting a sustainable future for public service media providers.
The ordering is intentional.
The future television ecosystem should first be designed to be competitive, open and capable of innovation. Universality and resilience must then be engineered into that environment. Public service organisations should be enabled to succeed within it.
The sustainability of today’s institutions should not be the first principle from which the architecture of the future market is designed.
Put another way:
Build a competitive and innovative market. Ensure everybody can participate. Make it resilient. Enable public service media to succeed within it.
Not:
Design the future market around preserving the structures of the existing one.
Moving to IP must not mean moving from one dependency to another
DTT has many limitations, but it provides a relatively common distribution environment.
IP changes that.
Television distribution can increasingly depend on operating systems, television manufacturers, streaming devices, application stores, identity platforms, proprietary interfaces and content-discovery systems.
As a result, the transition also shifts where market power can accumulate.
Spectrum and transmission infrastructure become less strategically significant. Device ecosystems, operating systems, search, recommendation and discovery become more significant.
For that reason, we believe open standards and interoperability should be treated as central components of the transition, not optional technical details to be considered later.
Government should encourage an environment in which:
services can operate across devices and platforms without unnecessary technical or commercial barriers;
consumers can retain compatible equipment for sensible periods;
common interfaces and standards are used where practical;
platforms and technology providers remain contestable;
services are portable between environments; and
broadcasters and new entrants do not become excessively dependent on a small number of proprietary providers.
A successful transition should increase competition, not merely exchange one form of infrastructure dependency for another.
Platform power is real. That does not make prominence the automatic answer
The Green Paper is right to focus on content discovery.
In the broadcast world, prominence was relatively easy to understand. Position within an electronic programme guide could materially affect whether audiences found a channel.
In an IP environment, discovery is much more complex.
Search results, recommendation algorithms, home-screen placement, personalised feeds, metadata, viewing history and editorial curation can all influence what somebody watches.
These systems undoubtedly confer significant power on platforms, and it is reasonable for policymakers to examine how that power is exercised.
Where we depart from some of the Green Paper’s reasoning is over the proposed response.
The paper argues that public service media content should be accessible and appropriately prominent across the platforms and devices audiences increasingly use to watch television.
We agree with the diagnosis that platforms exercise significant influence over discovery.
We are less convinced that institutional prominence is necessarily the right remedy.
There is an important difference between ensuring that a service cannot be unfairly excluded and requiring that it is positively advantaged.
The first protects competition. The second can distort it.
Content from the BBC, ITV, Channel 4, Channel 5 and other PSM providers should be capable of competing alongside commercial services, specialist publishers, independent producers and individual creators.
But no provider should receive preferential treatment purely because of its institutional status.
Otherwise, prominence risks becoming less about ensuring fair access and more about engineering a preferred audience outcome.
That should make policymakers cautious.
If audiences increasingly choose YouTube, Netflix, TikTok, a specialist publisher or something that has not yet been invented, the fact that those choices reduce the relative reach of traditional broadcasters is not, by itself, a reason to override them.
This is not an argument that public service media has no distinctive role. It is an argument that institutional status alone should not determine the outcome of search and recommendation systems. If particular content provides sufficient public value to justify special treatment, there is a legitimate debate to be had about that. But eligibility should follow objective characteristics of the content or service rather than simply the identity of the organisation producing it.
Public value should arise from demonstrable qualities and outcomes, not from the logo displayed before the content.
Transparency is different from regulating recommendation outcomes
There is another way of responding to concerns about platform influence.
Rather than attempting to prescribe what recommendation systems should recommend, policymakers could concentrate more heavily on transparency and accountability around how those systems operate.
Creators, publishers and service providers would benefit from:
clearer information about the principal factors affecting discoverability;
better analytics explaining how audiences find content;
meaningful notification when material platform changes affect reach;
stronger metadata, provenance and attribution;
effective review mechanisms where distribution is restricted; and
fair access to new platform functionality.
Transparency does not require platforms to publish source code, reveal every signal or make their systems easier to manipulate.
It means providing enough meaningful information for publishers and creators to understand the environment in which they operate, challenge material errors and make informed decisions.
That distinction is important: Transparency of recommendation systems is different from regulation of recommendation outcomes.
The former can help create a more accountable marketplace while leaving audiences and platforms substantial freedom over what they choose to surface. The latter risks regulators becoming progressively involved in determining which organisations should receive attention.
That is a considerably more interventionist proposition.
“Trustworthy news” requires particularly careful treatment
A related proposal is the possibility of giving greater prominence to “trustworthy” news.
The Government has not yet determined the criteria by which a trustworthy news provider would be identified and is consulting on how such a framework might operate.
We support the policy objective behind this.
Strong journalism, transparent editorial standards and access to reliable information are important components of a healthy media environment. Nor are we suggesting that all sources are equally rigorous or accountable.
There is useful common ground in the Green Paper’s focus on factors such as editorial controls, standards, complaints processes and transparency.
Our concern is that these process-based characteristics should remain at the centre of any future framework, rather than institutional status becoming a proxy for truthfulness.
Established broadcasters can have sophisticated editorial governance and still make mistakes, omit relevant context, exercise questionable editorial judgement or reach conclusions that later prove incorrect.
Conversely, specialist publishers and independent journalists can produce exceptionally rigorous work without belonging to the traditional broadcasting establishment.
We therefore think:
Trustworthiness should attach to process, not to an official determination of truth.
Relevant criteria might include:
editorial governance;
transparent ownership;
corrections policies;
complaints mechanisms;
provenance;
appropriate separation of reporting and opinion;
accountability; and
transparency around the use of AI-generated material.
These are characteristics that can be assessed comparatively objectively.
They do not guarantee that every output will be correct. No process can do that. But they provide a defensible basis for assessing whether a publisher behaves responsibly and can be held accountable.
Government deciding which organisations, viewpoints or individual pieces of journalism are officially “trustworthy” would be a much more problematic proposition.
Intervention also needs strong evidence
The Green Paper uses audience data to illustrate the changing competitive landscape, including BARB figures showing both the BBC and YouTube accounting for 19% of “total identified viewing” in the third quarter of 2025.
BARB is an established industry measurement system, and our concern is not with the legitimacy of audience measurement itself.
It is with the conclusions policymakers may draw from highly aggregated figures.
Presenting:
BBC - 19%
alongside:
YouTube - 19%
creates an intuitively powerful comparison.
But these are very different organisational categories.
The BBC is presented as a broadcaster, while YouTube is classified as a video-sharing platform. Each aggregates very different forms of content, creators, services and consumption behaviour beneath a single percentage.
A broadcaster and a platform are not necessarily equivalent units of competition.
The numbers may therefore be statistically valid within the methodology while still inviting conclusions about competitive equivalence that deserve closer examination.
That distinction becomes particularly important if such figures are subsequently used to justify intervention in search, recommendation or platform interfaces.
Before Government seeks to correct an alleged competitive imbalance, it should demonstrate that a genuine market failure exists using evidence in which the relevant services, audiences and forms of consumption are genuinely comparable.
Significant intervention deserves a correspondingly high evidential threshold.
Public service media should become more content-centric
The transition also provides an opportunity to rethink the meaning of public service media itself.
Historically, public service obligations have been closely connected to broadcast licences. In an IP-first environment, that relationship becomes increasingly artificial.
Public value does not inherently depend on whether something reaches an audience through DTT, IPTV, a broadcaster-owned application, a streaming service or a third-party video platform.
Here, there is significant common ground with the Green Paper.
Government proposes exploring a move away from regulating public service media principally through broadcast licences and considers institution-, service- and content-centric alternatives.
We strongly support that direction. Of the models explored, we believe a content-centric approach most closely reflects the future media environment. That does not diminish the role of existing PSM organisations.
The BBC, Channel 4 and other public service providers possess substantial production expertise, trusted brands, archives, journalism operations, commissioning capability and the scale to invest in ambitious UK content. They are likely to remain central to the delivery of public-service outcomes - but they need not be the only organisations capable of creating public value.
Independent producers, specialist organisations, digital-native publishers and individual creators may also produce content that advances clearly defined public-service objectives.
A more content-centric framework could recognise that contribution while allowing established PSM providers to continue playing a major role.
The critical safeguard is that the definition of qualifying public-service content must be objective, transparent and contestable. Otherwise, a content-centric system could simply reproduce institutional preferences through a different mechanism.
Universality needs a more precise definition
Universality remains an important principle, particularly as television moves away from DTT - but we think the terminology needs updating.
The Green Paper proposes that public service content should remain universally available and “free of charge”.
That wording masks several different concepts.
There is a distinction between:
universal availability;
free-at-the-point-of-consumption access;
the mechanism through which a service is funded; and
the connectivity and equipment required to receive it.
BBC television and iPlayer operate within the television licensing regime. Commercial PSM services are funded through advertising and wider commercial models. In an IPTV environment, households will also generally require broadband connectivity and compatible equipment.
A service may therefore be available without a subscription while still carrying material access costs for the household receiving it.
Those distinctions become considerably more significant once DTT is no longer available as an alternative.
Affordability is a real universality issue
For us, affordability is one of the most important practical questions surrounding the transition.
The Green Paper’s central forecasts suggest that around 880,000 households could still require suitable broadband to access IPTV in 2034.
Forecasts of this kind are necessarily sensitive to assumptions, but the scale illustrates why universality cannot be treated purely as a question of technical coverage.
Our preferred priorities are:
Affordable broadband suitable for television.
Targeted low-cost or subsidised broadband for low-income households.
Simple, inexpensive devices that make existing televisions IP-capable.
Accessibility built into devices and services.
Simple and intuitive user experiences.
Digital-skills support.
Subsidised replacement televisions where adaptation is not practical.
The principle is that Government should remove structural barriers before behavioural barriers.
A household that cannot afford broadband has a more fundamental problem than one that needs help navigating a menu. Accessibility and digital-skills support remain important, but neither can compensate for the absence of an affordable connection.
We would also strongly favour simple adapters over wholesale television replacement wherever practical. That would reduce the cost for households, simplify the transition and avoid rendering functional equipment obsolete unnecessarily.
The environmental calculation needs to consider the whole system
The environmental impact of an IP transition also deserves careful treatment.
Encouragingly, the consultation recognises that this question extends beyond the operational energy consumed when content is delivered. It asks respondents to consider infrastructure, consumer equipment, lifecycle impacts and technological change as part of the wider assessment.
We think that whole-system perspective is essential.
A simple comparison between the electricity required to deliver one hour of DTT and one hour of streaming risks overlooking the infrastructure required to support both models over time.
The more relevant policy comparison is closer to:
IPTV in 2034
versus:
IPTV plus another ten years of DTT infrastructure.
Broadcasters operate technology estates containing transmission infrastructure, specialist equipment, facilities, cooling, monitoring systems, redundancy and operational support. Extending DTT means continuing to operate and maintain much of that estate alongside the IP services that audiences are already adopting.
At the same time, the technology underpinning IP delivery will continue to evolve. Improvements in semiconductors, video codecs, networking, cloud infrastructure, CDNs, storage, consumer devices and software architecture all have the potential to change the efficiency profile of streaming over the coming decade.
We would therefore be cautious about extrapolating today’s IPTV energy consumption directly to 2034, just as we would be cautious about assuming that the cost and environmental impact of maintaining DTT will remain static.
The calculation should also include embodied carbon and electronic waste.
A transition to IP should not unnecessarily require millions of households to replace otherwise functional televisions. Wherever practical, simple and affordable adapters should be used to extend the useful life of existing equipment.
The environmental question is therefore not simply which delivery technology consumes less energy today.It is which transition pathway produces the best overall outcome across infrastructure, operations, consumer equipment and the full technology lifecycle.
Modernisation should not mean expanding yesterday’s regulation
Perhaps our broadest concern is what policymakers mean when they talk about “levelling the playing field”.
Technology-neutral regulation is a sensible objective - but there is a trap hidden inside the phrase.
A level playing field does not necessarily mean taking every obligation accumulated by traditional broadcasters over decades and imposing an equivalent version on every successful digital competitor. Sometimes the field is not uneven because a new entrant is insufficiently regulated. Sometimes an incumbent is carrying regulatory obligations designed for a market that no longer exists.
Those are very different problems.
Where traditional broadcasters face outdated or disproportionate requirements, the first question should therefore be:
Does this regulation still need to exist?
Only after answering that should policymakers ask whether equivalent obligations need to be applied elsewhere. Otherwise, “levelling the playing field” can become a one-way ratchet in which regulation continually expands but is rarely reconsidered. That risks freezing yesterday’s assumptions into tomorrow’s market.
A broadcaster exercising editorial control over a scheduled channel is not identical to a video-sharing platform hosting millions of creators. A connected-TV operating system is not the same as either of them - nor is an on-demand catalogue, a search service or a recommendation engine.
They exercise different forms of control, create different risks and have different relationships with audiences.Regulation should reflect those differences.
Technology neutrality should mean that comparable harms are treated comparably. It should not mean imposing identical obligations on fundamentally different services.
A modern framework therefore needs to distinguish carefully between:
editorial responsibility;
platform responsibility;
accessibility;
content discovery;
technical distribution; and
audience protection.
Proportionality matters too.
Obligations should follow demonstrable risk, responsibility and market power rather than simply the fact that a service has become popular.
The purpose of reform should be to create rules appropriate to the media market we are building, not to make new services resemble the businesses for which the existing rules were originally written.
A chance to build the next media market
There is much in Watch this Space that we welcome.
The Government has recognised that television is becoming IP-led, that the boundary between broadcasting and online media is disappearing and that a regulatory architecture developed for another technological era will need substantial reform.
Those are important conclusions - and the bigger question is what Government does with them.
There is a natural temptation when an established industry is disrupted to identify the institutions that mattered in the previous market and ask how regulation can preserve their position in the next one.
We think that would be a mistake. The historic influence of UK broadcasters is not, by itself, a public-interest outcome.
Trusted journalism matters. Universal access matters. UK-originated production matters. Accessibility matters. Plurality, cultural representation, children’s programming and coverage of events of national importance can all matter.
Those are outcomes that can be debated, defined and supported. Maintaining a particular organisation’s historic share of audience attention is something different. Regulation should not become a mechanism for trying to recreate historic patterns of audience attention.
Traditional broadcasters can and should play an important role in the next media era. They possess considerable creative, editorial and technical capability and remain responsible for some of the UK’s most important content.
But the strongest future for those organisations is one in which they continue to innovate successfully within a competitive market, not one in which the surrounding market is designed to reproduce the audience dynamics of the broadcast era.
The UK therefore has a much bigger opportunity than recreating the broadcasting environment of the past inside the technology platforms of the future.
It can create an IP-first ecosystem that is:
open;
interoperable;
competitive;
accessible;
resilient;
technology-neutral; and
capable of recognising public value irrespective of which institution creates it.
It can also regulate genuine harms without treating every successful challenge to an incumbent as evidence that something has gone wrong.
For us, that leaves one central question for the next phase of policy development.
It is not:
How do we preserve the position traditional broadcasters held in the broadcast era?
It is:
What outcomes genuinely matter in the next media era, and what is the least distortive way of achieving them?
That is a more difficult question.
But answering it is far more likely to produce a media market designed for where audiences are going, rather than one designed around where they used to be.
Watch this Space: Designing the future of UK television
The UK Government’s Watch this Space: A new strategic direction for UK media Green Paper asks some important questions about the future of television.
At Spicy Mango, we broadly agree with its starting point.
Television is becoming an IP-led medium. The distinction between broadcast and online video is increasingly difficult to sustain. Audiences move fluidly between linear television, broadcaster streaming services, global subscription platforms, YouTube and other video-sharing services. As DTT audiences decline, maintaining a nationwide transmission network for an ever-smaller proportion of viewing will inevitably become harder to justify.
There is therefore a strong case for reform. Where we are more cautious is over what that reform is intended to achieve.
The transition to IP creates an opportunity to design a more open, innovative and competitive television market. It should not become an exercise in reproducing the structures and audience dynamics of the broadcast era within a new generation of digital platforms.
That distinction informed much of our response to the consultation.
Our underlying principle is relatively simple:
Regulate harms, not competitors. Protect outcomes, not incumbents.
Audience change is not necessarily market failure
One of the challenges running through the Green Paper is the declining reach and influence of traditional broadcasters, particularly among younger audiences.
The Government describes domestic broadcasters, including public service media providers, as increasingly having to fight to be “seen and heard” in a fragmented and competitive market.
That is a legitimate policy consideration. Public service broadcasters play an important role in UK media, and there are clear public-interest outcomes that Government may reasonably want to preserve.
But there is a danger in treating the declining reach of institutions we value as evidence that the market itself has failed. They are not the same thing. Audiences have moved for many reasons, and not all of them are problems requiring regulatory correction.
Streaming platforms, video-sharing services and digital-native publishers have changed expectations around personalisation, interfaces, content formats, search, recommendation, accessibility across devices and the ability to consume content whenever and wherever people choose.
In many cases, newer services have gained attention because they have built products that audiences prefer using. That is competition.
It may be uncomfortable for established broadcasters, and it may create legitimate questions about how certain public-interest outcomes are sustained, but competitive displacement should not automatically be reclassified as market failure simply because the organisations losing share are culturally or institutionally important.
This matters because the diagnosis determines the regulatory response. If audiences cannot access important public-interest content because of structural barriers, intervention may be justified.
If audiences are choosing other products, formats or services, attempting to reverse that change through regulation is a much harder proposition to defend.
At its worst, prominence or platform intervention could become a mechanism for trying to recreate historic patterns of audience attention. We do not think regulation should do that.
The objective should be to preserve clearly defined public-interest outcomes, not historic levels of institutional influence.
An IP-first future should arrive sooner rather than later
On the underlying technology transition, our view is considerably less cautious.
We support a managed DTT switch-off by 2034 rather than 2044.
The fundamental technical question has already been answered. IP networks routinely deliver video services to very large audiences, including around major sporting, entertainment and national events.
The question is no longer whether television can be delivered over IP. It is how the remaining barriers to universal adoption should be addressed.
That does not mean a transition would be trivial.
Universal television over IP creates genuine challenges around broadband availability, affordability, resilience, accessibility and consumer equipment. But we see these as engineering and implementation requirements for a successful transition rather than reasons to maintain parallel infrastructure for another decade.
Modern IP platforms can be designed with geographic redundancy, multiple delivery routes, distributed content delivery, automated capacity management, extensive monitoring and graceful degradation.
No distribution system is immune from failure. The objective should be to engineer appropriate resilience across the whole delivery chain, from contribution and cloud infrastructure through to broadband access and the consumer device.
Notably, the Green Paper itself identifies potential benefits from a 2034 transition, including earlier cost efficiencies, spectrum benefits and faster innovation in content, services and user experience.
The more productive question is therefore not whether IP can replace DTT. It is what needs to be true by 2034 for everybody to make that transition successfully.
Our ranking of the principal transition challenges reflected that:
Promoting competition and innovation.
Delivering for all audiences.
Maintaining a reliable television service.
Supporting a sustainable future for public service media providers.
The ordering is intentional.
The future television ecosystem should first be designed to be competitive, open and capable of innovation. Universality and resilience must then be engineered into that environment. Public service organisations should be enabled to succeed within it.
The sustainability of today’s institutions should not be the first principle from which the architecture of the future market is designed.
Put another way:
Build a competitive and innovative market. Ensure everybody can participate. Make it resilient. Enable public service media to succeed within it.
Not:
Design the future market around preserving the structures of the existing one.
Moving to IP must not mean moving from one dependency to another
DTT has many limitations, but it provides a relatively common distribution environment.
IP changes that.
Television distribution can increasingly depend on operating systems, television manufacturers, streaming devices, application stores, identity platforms, proprietary interfaces and content-discovery systems.
As a result, the transition also shifts where market power can accumulate.
Spectrum and transmission infrastructure become less strategically significant. Device ecosystems, operating systems, search, recommendation and discovery become more significant.
For that reason, we believe open standards and interoperability should be treated as central components of the transition, not optional technical details to be considered later.
Government should encourage an environment in which:
services can operate across devices and platforms without unnecessary technical or commercial barriers;
consumers can retain compatible equipment for sensible periods;
common interfaces and standards are used where practical;
platforms and technology providers remain contestable;
services are portable between environments; and
broadcasters and new entrants do not become excessively dependent on a small number of proprietary providers.
A successful transition should increase competition, not merely exchange one form of infrastructure dependency for another.
Platform power is real. That does not make prominence the automatic answer
The Green Paper is right to focus on content discovery.
In the broadcast world, prominence was relatively easy to understand. Position within an electronic programme guide could materially affect whether audiences found a channel.
In an IP environment, discovery is much more complex.
Search results, recommendation algorithms, home-screen placement, personalised feeds, metadata, viewing history and editorial curation can all influence what somebody watches.
These systems undoubtedly confer significant power on platforms, and it is reasonable for policymakers to examine how that power is exercised.
Where we depart from some of the Green Paper’s reasoning is over the proposed response.
The paper argues that public service media content should be accessible and appropriately prominent across the platforms and devices audiences increasingly use to watch television.
We agree with the diagnosis that platforms exercise significant influence over discovery.
We are less convinced that institutional prominence is necessarily the right remedy.
There is an important difference between ensuring that a service cannot be unfairly excluded and requiring that it is positively advantaged.
The first protects competition. The second can distort it.
Content from the BBC, ITV, Channel 4, Channel 5 and other PSM providers should be capable of competing alongside commercial services, specialist publishers, independent producers and individual creators.
But no provider should receive preferential treatment purely because of its institutional status.
Otherwise, prominence risks becoming less about ensuring fair access and more about engineering a preferred audience outcome.
That should make policymakers cautious.
If audiences increasingly choose YouTube, Netflix, TikTok, a specialist publisher or something that has not yet been invented, the fact that those choices reduce the relative reach of traditional broadcasters is not, by itself, a reason to override them.
This is not an argument that public service media has no distinctive role. It is an argument that institutional status alone should not determine the outcome of search and recommendation systems. If particular content provides sufficient public value to justify special treatment, there is a legitimate debate to be had about that. But eligibility should follow objective characteristics of the content or service rather than simply the identity of the organisation producing it.
Public value should arise from demonstrable qualities and outcomes, not from the logo displayed before the content.
Transparency is different from regulating recommendation outcomes
There is another way of responding to concerns about platform influence.
Rather than attempting to prescribe what recommendation systems should recommend, policymakers could concentrate more heavily on transparency and accountability around how those systems operate.
Creators, publishers and service providers would benefit from:
clearer information about the principal factors affecting discoverability;
better analytics explaining how audiences find content;
meaningful notification when material platform changes affect reach;
stronger metadata, provenance and attribution;
effective review mechanisms where distribution is restricted; and
fair access to new platform functionality.
Transparency does not require platforms to publish source code, reveal every signal or make their systems easier to manipulate.
It means providing enough meaningful information for publishers and creators to understand the environment in which they operate, challenge material errors and make informed decisions.
That distinction is important: Transparency of recommendation systems is different from regulation of recommendation outcomes.
The former can help create a more accountable marketplace while leaving audiences and platforms substantial freedom over what they choose to surface. The latter risks regulators becoming progressively involved in determining which organisations should receive attention.
That is a considerably more interventionist proposition.
“Trustworthy news” requires particularly careful treatment
A related proposal is the possibility of giving greater prominence to “trustworthy” news.
The Government has not yet determined the criteria by which a trustworthy news provider would be identified and is consulting on how such a framework might operate.
We support the policy objective behind this.
Strong journalism, transparent editorial standards and access to reliable information are important components of a healthy media environment. Nor are we suggesting that all sources are equally rigorous or accountable.
There is useful common ground in the Green Paper’s focus on factors such as editorial controls, standards, complaints processes and transparency.
Our concern is that these process-based characteristics should remain at the centre of any future framework, rather than institutional status becoming a proxy for truthfulness.
Established broadcasters can have sophisticated editorial governance and still make mistakes, omit relevant context, exercise questionable editorial judgement or reach conclusions that later prove incorrect.
Conversely, specialist publishers and independent journalists can produce exceptionally rigorous work without belonging to the traditional broadcasting establishment.
We therefore think:
Trustworthiness should attach to process, not to an official determination of truth.
Relevant criteria might include:
editorial governance;
transparent ownership;
corrections policies;
complaints mechanisms;
provenance;
appropriate separation of reporting and opinion;
accountability; and
transparency around the use of AI-generated material.
These are characteristics that can be assessed comparatively objectively.
They do not guarantee that every output will be correct. No process can do that. But they provide a defensible basis for assessing whether a publisher behaves responsibly and can be held accountable.
Government deciding which organisations, viewpoints or individual pieces of journalism are officially “trustworthy” would be a much more problematic proposition.
Intervention also needs strong evidence
The Green Paper uses audience data to illustrate the changing competitive landscape, including BARB figures showing both the BBC and YouTube accounting for 19% of “total identified viewing” in the third quarter of 2025.
BARB is an established industry measurement system, and our concern is not with the legitimacy of audience measurement itself.
It is with the conclusions policymakers may draw from highly aggregated figures.
Presenting:
BBC - 19%
alongside:
YouTube - 19%
creates an intuitively powerful comparison.
But these are very different organisational categories.
The BBC is presented as a broadcaster, while YouTube is classified as a video-sharing platform. Each aggregates very different forms of content, creators, services and consumption behaviour beneath a single percentage.
A broadcaster and a platform are not necessarily equivalent units of competition.
The numbers may therefore be statistically valid within the methodology while still inviting conclusions about competitive equivalence that deserve closer examination.
That distinction becomes particularly important if such figures are subsequently used to justify intervention in search, recommendation or platform interfaces.
Before Government seeks to correct an alleged competitive imbalance, it should demonstrate that a genuine market failure exists using evidence in which the relevant services, audiences and forms of consumption are genuinely comparable.
Significant intervention deserves a correspondingly high evidential threshold.
Public service media should become more content-centric
The transition also provides an opportunity to rethink the meaning of public service media itself.
Historically, public service obligations have been closely connected to broadcast licences. In an IP-first environment, that relationship becomes increasingly artificial.
Public value does not inherently depend on whether something reaches an audience through DTT, IPTV, a broadcaster-owned application, a streaming service or a third-party video platform.
Here, there is significant common ground with the Green Paper.
Government proposes exploring a move away from regulating public service media principally through broadcast licences and considers institution-, service- and content-centric alternatives.
We strongly support that direction. Of the models explored, we believe a content-centric approach most closely reflects the future media environment. That does not diminish the role of existing PSM organisations.
The BBC, Channel 4 and other public service providers possess substantial production expertise, trusted brands, archives, journalism operations, commissioning capability and the scale to invest in ambitious UK content. They are likely to remain central to the delivery of public-service outcomes - but they need not be the only organisations capable of creating public value.
Independent producers, specialist organisations, digital-native publishers and individual creators may also produce content that advances clearly defined public-service objectives.
A more content-centric framework could recognise that contribution while allowing established PSM providers to continue playing a major role.
The critical safeguard is that the definition of qualifying public-service content must be objective, transparent and contestable. Otherwise, a content-centric system could simply reproduce institutional preferences through a different mechanism.
Universality needs a more precise definition
Universality remains an important principle, particularly as television moves away from DTT - but we think the terminology needs updating.
The Green Paper proposes that public service content should remain universally available and “free of charge”.
That wording masks several different concepts.
There is a distinction between:
universal availability;
free-at-the-point-of-consumption access;
the mechanism through which a service is funded; and
the connectivity and equipment required to receive it.
BBC television and iPlayer operate within the television licensing regime. Commercial PSM services are funded through advertising and wider commercial models. In an IPTV environment, households will also generally require broadband connectivity and compatible equipment.
A service may therefore be available without a subscription while still carrying material access costs for the household receiving it.
Those distinctions become considerably more significant once DTT is no longer available as an alternative.
Affordability is a real universality issue
For us, affordability is one of the most important practical questions surrounding the transition.
The Green Paper’s central forecasts suggest that around 880,000 households could still require suitable broadband to access IPTV in 2034.
Forecasts of this kind are necessarily sensitive to assumptions, but the scale illustrates why universality cannot be treated purely as a question of technical coverage.
Our preferred priorities are:
Affordable broadband suitable for television.
Targeted low-cost or subsidised broadband for low-income households.
Simple, inexpensive devices that make existing televisions IP-capable.
Accessibility built into devices and services.
Simple and intuitive user experiences.
Digital-skills support.
Subsidised replacement televisions where adaptation is not practical.
The principle is that Government should remove structural barriers before behavioural barriers.
A household that cannot afford broadband has a more fundamental problem than one that needs help navigating a menu. Accessibility and digital-skills support remain important, but neither can compensate for the absence of an affordable connection.
We would also strongly favour simple adapters over wholesale television replacement wherever practical. That would reduce the cost for households, simplify the transition and avoid rendering functional equipment obsolete unnecessarily.
The environmental calculation needs to consider the whole system
The environmental impact of an IP transition also deserves careful treatment.
Encouragingly, the consultation recognises that this question extends beyond the operational energy consumed when content is delivered. It asks respondents to consider infrastructure, consumer equipment, lifecycle impacts and technological change as part of the wider assessment.
We think that whole-system perspective is essential.
A simple comparison between the electricity required to deliver one hour of DTT and one hour of streaming risks overlooking the infrastructure required to support both models over time.
The more relevant policy comparison is closer to:
IPTV in 2034
versus:
IPTV plus another ten years of DTT infrastructure.
Broadcasters operate technology estates containing transmission infrastructure, specialist equipment, facilities, cooling, monitoring systems, redundancy and operational support. Extending DTT means continuing to operate and maintain much of that estate alongside the IP services that audiences are already adopting.
At the same time, the technology underpinning IP delivery will continue to evolve. Improvements in semiconductors, video codecs, networking, cloud infrastructure, CDNs, storage, consumer devices and software architecture all have the potential to change the efficiency profile of streaming over the coming decade.
We would therefore be cautious about extrapolating today’s IPTV energy consumption directly to 2034, just as we would be cautious about assuming that the cost and environmental impact of maintaining DTT will remain static.
The calculation should also include embodied carbon and electronic waste.
A transition to IP should not unnecessarily require millions of households to replace otherwise functional televisions. Wherever practical, simple and affordable adapters should be used to extend the useful life of existing equipment.
The environmental question is therefore not simply which delivery technology consumes less energy today.It is which transition pathway produces the best overall outcome across infrastructure, operations, consumer equipment and the full technology lifecycle.
Modernisation should not mean expanding yesterday’s regulation
Perhaps our broadest concern is what policymakers mean when they talk about “levelling the playing field”.
Technology-neutral regulation is a sensible objective - but there is a trap hidden inside the phrase.
A level playing field does not necessarily mean taking every obligation accumulated by traditional broadcasters over decades and imposing an equivalent version on every successful digital competitor. Sometimes the field is not uneven because a new entrant is insufficiently regulated. Sometimes an incumbent is carrying regulatory obligations designed for a market that no longer exists.
Those are very different problems.
Where traditional broadcasters face outdated or disproportionate requirements, the first question should therefore be:
Does this regulation still need to exist?
Only after answering that should policymakers ask whether equivalent obligations need to be applied elsewhere. Otherwise, “levelling the playing field” can become a one-way ratchet in which regulation continually expands but is rarely reconsidered. That risks freezing yesterday’s assumptions into tomorrow’s market.
A broadcaster exercising editorial control over a scheduled channel is not identical to a video-sharing platform hosting millions of creators. A connected-TV operating system is not the same as either of them - nor is an on-demand catalogue, a search service or a recommendation engine.
They exercise different forms of control, create different risks and have different relationships with audiences.Regulation should reflect those differences.
Technology neutrality should mean that comparable harms are treated comparably. It should not mean imposing identical obligations on fundamentally different services.
A modern framework therefore needs to distinguish carefully between:
editorial responsibility;
platform responsibility;
accessibility;
content discovery;
technical distribution; and
audience protection.
Proportionality matters too.
Obligations should follow demonstrable risk, responsibility and market power rather than simply the fact that a service has become popular.
The purpose of reform should be to create rules appropriate to the media market we are building, not to make new services resemble the businesses for which the existing rules were originally written.
A chance to build the next media market
There is much in Watch this Space that we welcome.
The Government has recognised that television is becoming IP-led, that the boundary between broadcasting and online media is disappearing and that a regulatory architecture developed for another technological era will need substantial reform.
Those are important conclusions - and the bigger question is what Government does with them.
There is a natural temptation when an established industry is disrupted to identify the institutions that mattered in the previous market and ask how regulation can preserve their position in the next one.
We think that would be a mistake. The historic influence of UK broadcasters is not, by itself, a public-interest outcome.
Trusted journalism matters. Universal access matters. UK-originated production matters. Accessibility matters. Plurality, cultural representation, children’s programming and coverage of events of national importance can all matter.
Those are outcomes that can be debated, defined and supported. Maintaining a particular organisation’s historic share of audience attention is something different. Regulation should not become a mechanism for trying to recreate historic patterns of audience attention.
Traditional broadcasters can and should play an important role in the next media era. They possess considerable creative, editorial and technical capability and remain responsible for some of the UK’s most important content.
But the strongest future for those organisations is one in which they continue to innovate successfully within a competitive market, not one in which the surrounding market is designed to reproduce the audience dynamics of the broadcast era.
The UK therefore has a much bigger opportunity than recreating the broadcasting environment of the past inside the technology platforms of the future.
It can create an IP-first ecosystem that is:
open;
interoperable;
competitive;
accessible;
resilient;
technology-neutral; and
capable of recognising public value irrespective of which institution creates it.
It can also regulate genuine harms without treating every successful challenge to an incumbent as evidence that something has gone wrong.
For us, that leaves one central question for the next phase of policy development.
It is not:
How do we preserve the position traditional broadcasters held in the broadcast era?
It is:
What outcomes genuinely matter in the next media era, and what is the least distortive way of achieving them?
That is a more difficult question.
But answering it is far more likely to produce a media market designed for where audiences are going, rather than one designed around where they used to be.
Watch this Space: Designing the future of UK television
The UK Government’s Watch this Space: A new strategic direction for UK media Green Paper asks some important questions about the future of television.
At Spicy Mango, we broadly agree with its starting point.
Television is becoming an IP-led medium. The distinction between broadcast and online video is increasingly difficult to sustain. Audiences move fluidly between linear television, broadcaster streaming services, global subscription platforms, YouTube and other video-sharing services. As DTT audiences decline, maintaining a nationwide transmission network for an ever-smaller proportion of viewing will inevitably become harder to justify.
There is therefore a strong case for reform. Where we are more cautious is over what that reform is intended to achieve.
The transition to IP creates an opportunity to design a more open, innovative and competitive television market. It should not become an exercise in reproducing the structures and audience dynamics of the broadcast era within a new generation of digital platforms.
That distinction informed much of our response to the consultation.
Our underlying principle is relatively simple:
Regulate harms, not competitors. Protect outcomes, not incumbents.
Audience change is not necessarily market failure
One of the challenges running through the Green Paper is the declining reach and influence of traditional broadcasters, particularly among younger audiences.
The Government describes domestic broadcasters, including public service media providers, as increasingly having to fight to be “seen and heard” in a fragmented and competitive market.
That is a legitimate policy consideration. Public service broadcasters play an important role in UK media, and there are clear public-interest outcomes that Government may reasonably want to preserve.
But there is a danger in treating the declining reach of institutions we value as evidence that the market itself has failed. They are not the same thing. Audiences have moved for many reasons, and not all of them are problems requiring regulatory correction.
Streaming platforms, video-sharing services and digital-native publishers have changed expectations around personalisation, interfaces, content formats, search, recommendation, accessibility across devices and the ability to consume content whenever and wherever people choose.
In many cases, newer services have gained attention because they have built products that audiences prefer using. That is competition.
It may be uncomfortable for established broadcasters, and it may create legitimate questions about how certain public-interest outcomes are sustained, but competitive displacement should not automatically be reclassified as market failure simply because the organisations losing share are culturally or institutionally important.
This matters because the diagnosis determines the regulatory response. If audiences cannot access important public-interest content because of structural barriers, intervention may be justified.
If audiences are choosing other products, formats or services, attempting to reverse that change through regulation is a much harder proposition to defend.
At its worst, prominence or platform intervention could become a mechanism for trying to recreate historic patterns of audience attention. We do not think regulation should do that.
The objective should be to preserve clearly defined public-interest outcomes, not historic levels of institutional influence.
An IP-first future should arrive sooner rather than later
On the underlying technology transition, our view is considerably less cautious.
We support a managed DTT switch-off by 2034 rather than 2044.
The fundamental technical question has already been answered. IP networks routinely deliver video services to very large audiences, including around major sporting, entertainment and national events.
The question is no longer whether television can be delivered over IP. It is how the remaining barriers to universal adoption should be addressed.
That does not mean a transition would be trivial.
Universal television over IP creates genuine challenges around broadband availability, affordability, resilience, accessibility and consumer equipment. But we see these as engineering and implementation requirements for a successful transition rather than reasons to maintain parallel infrastructure for another decade.
Modern IP platforms can be designed with geographic redundancy, multiple delivery routes, distributed content delivery, automated capacity management, extensive monitoring and graceful degradation.
No distribution system is immune from failure. The objective should be to engineer appropriate resilience across the whole delivery chain, from contribution and cloud infrastructure through to broadband access and the consumer device.
Notably, the Green Paper itself identifies potential benefits from a 2034 transition, including earlier cost efficiencies, spectrum benefits and faster innovation in content, services and user experience.
The more productive question is therefore not whether IP can replace DTT. It is what needs to be true by 2034 for everybody to make that transition successfully.
Our ranking of the principal transition challenges reflected that:
Promoting competition and innovation.
Delivering for all audiences.
Maintaining a reliable television service.
Supporting a sustainable future for public service media providers.
The ordering is intentional.
The future television ecosystem should first be designed to be competitive, open and capable of innovation. Universality and resilience must then be engineered into that environment. Public service organisations should be enabled to succeed within it.
The sustainability of today’s institutions should not be the first principle from which the architecture of the future market is designed.
Put another way:
Build a competitive and innovative market. Ensure everybody can participate. Make it resilient. Enable public service media to succeed within it.
Not:
Design the future market around preserving the structures of the existing one.
Moving to IP must not mean moving from one dependency to another
DTT has many limitations, but it provides a relatively common distribution environment.
IP changes that.
Television distribution can increasingly depend on operating systems, television manufacturers, streaming devices, application stores, identity platforms, proprietary interfaces and content-discovery systems.
As a result, the transition also shifts where market power can accumulate.
Spectrum and transmission infrastructure become less strategically significant. Device ecosystems, operating systems, search, recommendation and discovery become more significant.
For that reason, we believe open standards and interoperability should be treated as central components of the transition, not optional technical details to be considered later.
Government should encourage an environment in which:
services can operate across devices and platforms without unnecessary technical or commercial barriers;
consumers can retain compatible equipment for sensible periods;
common interfaces and standards are used where practical;
platforms and technology providers remain contestable;
services are portable between environments; and
broadcasters and new entrants do not become excessively dependent on a small number of proprietary providers.
A successful transition should increase competition, not merely exchange one form of infrastructure dependency for another.
Platform power is real. That does not make prominence the automatic answer
The Green Paper is right to focus on content discovery.
In the broadcast world, prominence was relatively easy to understand. Position within an electronic programme guide could materially affect whether audiences found a channel.
In an IP environment, discovery is much more complex.
Search results, recommendation algorithms, home-screen placement, personalised feeds, metadata, viewing history and editorial curation can all influence what somebody watches.
These systems undoubtedly confer significant power on platforms, and it is reasonable for policymakers to examine how that power is exercised.
Where we depart from some of the Green Paper’s reasoning is over the proposed response.
The paper argues that public service media content should be accessible and appropriately prominent across the platforms and devices audiences increasingly use to watch television.
We agree with the diagnosis that platforms exercise significant influence over discovery.
We are less convinced that institutional prominence is necessarily the right remedy.
There is an important difference between ensuring that a service cannot be unfairly excluded and requiring that it is positively advantaged.
The first protects competition. The second can distort it.
Content from the BBC, ITV, Channel 4, Channel 5 and other PSM providers should be capable of competing alongside commercial services, specialist publishers, independent producers and individual creators.
But no provider should receive preferential treatment purely because of its institutional status.
Otherwise, prominence risks becoming less about ensuring fair access and more about engineering a preferred audience outcome.
That should make policymakers cautious.
If audiences increasingly choose YouTube, Netflix, TikTok, a specialist publisher or something that has not yet been invented, the fact that those choices reduce the relative reach of traditional broadcasters is not, by itself, a reason to override them.
This is not an argument that public service media has no distinctive role. It is an argument that institutional status alone should not determine the outcome of search and recommendation systems. If particular content provides sufficient public value to justify special treatment, there is a legitimate debate to be had about that. But eligibility should follow objective characteristics of the content or service rather than simply the identity of the organisation producing it.
Public value should arise from demonstrable qualities and outcomes, not from the logo displayed before the content.
Transparency is different from regulating recommendation outcomes
There is another way of responding to concerns about platform influence.
Rather than attempting to prescribe what recommendation systems should recommend, policymakers could concentrate more heavily on transparency and accountability around how those systems operate.
Creators, publishers and service providers would benefit from:
clearer information about the principal factors affecting discoverability;
better analytics explaining how audiences find content;
meaningful notification when material platform changes affect reach;
stronger metadata, provenance and attribution;
effective review mechanisms where distribution is restricted; and
fair access to new platform functionality.
Transparency does not require platforms to publish source code, reveal every signal or make their systems easier to manipulate.
It means providing enough meaningful information for publishers and creators to understand the environment in which they operate, challenge material errors and make informed decisions.
That distinction is important: Transparency of recommendation systems is different from regulation of recommendation outcomes.
The former can help create a more accountable marketplace while leaving audiences and platforms substantial freedom over what they choose to surface. The latter risks regulators becoming progressively involved in determining which organisations should receive attention.
That is a considerably more interventionist proposition.
“Trustworthy news” requires particularly careful treatment
A related proposal is the possibility of giving greater prominence to “trustworthy” news.
The Government has not yet determined the criteria by which a trustworthy news provider would be identified and is consulting on how such a framework might operate.
We support the policy objective behind this.
Strong journalism, transparent editorial standards and access to reliable information are important components of a healthy media environment. Nor are we suggesting that all sources are equally rigorous or accountable.
There is useful common ground in the Green Paper’s focus on factors such as editorial controls, standards, complaints processes and transparency.
Our concern is that these process-based characteristics should remain at the centre of any future framework, rather than institutional status becoming a proxy for truthfulness.
Established broadcasters can have sophisticated editorial governance and still make mistakes, omit relevant context, exercise questionable editorial judgement or reach conclusions that later prove incorrect.
Conversely, specialist publishers and independent journalists can produce exceptionally rigorous work without belonging to the traditional broadcasting establishment.
We therefore think:
Trustworthiness should attach to process, not to an official determination of truth.
Relevant criteria might include:
editorial governance;
transparent ownership;
corrections policies;
complaints mechanisms;
provenance;
appropriate separation of reporting and opinion;
accountability; and
transparency around the use of AI-generated material.
These are characteristics that can be assessed comparatively objectively.
They do not guarantee that every output will be correct. No process can do that. But they provide a defensible basis for assessing whether a publisher behaves responsibly and can be held accountable.
Government deciding which organisations, viewpoints or individual pieces of journalism are officially “trustworthy” would be a much more problematic proposition.
Intervention also needs strong evidence
The Green Paper uses audience data to illustrate the changing competitive landscape, including BARB figures showing both the BBC and YouTube accounting for 19% of “total identified viewing” in the third quarter of 2025.
BARB is an established industry measurement system, and our concern is not with the legitimacy of audience measurement itself.
It is with the conclusions policymakers may draw from highly aggregated figures.
Presenting:
BBC - 19%
alongside:
YouTube - 19%
creates an intuitively powerful comparison.
But these are very different organisational categories.
The BBC is presented as a broadcaster, while YouTube is classified as a video-sharing platform. Each aggregates very different forms of content, creators, services and consumption behaviour beneath a single percentage.
A broadcaster and a platform are not necessarily equivalent units of competition.
The numbers may therefore be statistically valid within the methodology while still inviting conclusions about competitive equivalence that deserve closer examination.
That distinction becomes particularly important if such figures are subsequently used to justify intervention in search, recommendation or platform interfaces.
Before Government seeks to correct an alleged competitive imbalance, it should demonstrate that a genuine market failure exists using evidence in which the relevant services, audiences and forms of consumption are genuinely comparable.
Significant intervention deserves a correspondingly high evidential threshold.
Public service media should become more content-centric
The transition also provides an opportunity to rethink the meaning of public service media itself.
Historically, public service obligations have been closely connected to broadcast licences. In an IP-first environment, that relationship becomes increasingly artificial.
Public value does not inherently depend on whether something reaches an audience through DTT, IPTV, a broadcaster-owned application, a streaming service or a third-party video platform.
Here, there is significant common ground with the Green Paper.
Government proposes exploring a move away from regulating public service media principally through broadcast licences and considers institution-, service- and content-centric alternatives.
We strongly support that direction. Of the models explored, we believe a content-centric approach most closely reflects the future media environment. That does not diminish the role of existing PSM organisations.
The BBC, Channel 4 and other public service providers possess substantial production expertise, trusted brands, archives, journalism operations, commissioning capability and the scale to invest in ambitious UK content. They are likely to remain central to the delivery of public-service outcomes - but they need not be the only organisations capable of creating public value.
Independent producers, specialist organisations, digital-native publishers and individual creators may also produce content that advances clearly defined public-service objectives.
A more content-centric framework could recognise that contribution while allowing established PSM providers to continue playing a major role.
The critical safeguard is that the definition of qualifying public-service content must be objective, transparent and contestable. Otherwise, a content-centric system could simply reproduce institutional preferences through a different mechanism.
Universality needs a more precise definition
Universality remains an important principle, particularly as television moves away from DTT - but we think the terminology needs updating.
The Green Paper proposes that public service content should remain universally available and “free of charge”.
That wording masks several different concepts.
There is a distinction between:
universal availability;
free-at-the-point-of-consumption access;
the mechanism through which a service is funded; and
the connectivity and equipment required to receive it.
BBC television and iPlayer operate within the television licensing regime. Commercial PSM services are funded through advertising and wider commercial models. In an IPTV environment, households will also generally require broadband connectivity and compatible equipment.
A service may therefore be available without a subscription while still carrying material access costs for the household receiving it.
Those distinctions become considerably more significant once DTT is no longer available as an alternative.
Affordability is a real universality issue
For us, affordability is one of the most important practical questions surrounding the transition.
The Green Paper’s central forecasts suggest that around 880,000 households could still require suitable broadband to access IPTV in 2034.
Forecasts of this kind are necessarily sensitive to assumptions, but the scale illustrates why universality cannot be treated purely as a question of technical coverage.
Our preferred priorities are:
Affordable broadband suitable for television.
Targeted low-cost or subsidised broadband for low-income households.
Simple, inexpensive devices that make existing televisions IP-capable.
Accessibility built into devices and services.
Simple and intuitive user experiences.
Digital-skills support.
Subsidised replacement televisions where adaptation is not practical.
The principle is that Government should remove structural barriers before behavioural barriers.
A household that cannot afford broadband has a more fundamental problem than one that needs help navigating a menu. Accessibility and digital-skills support remain important, but neither can compensate for the absence of an affordable connection.
We would also strongly favour simple adapters over wholesale television replacement wherever practical. That would reduce the cost for households, simplify the transition and avoid rendering functional equipment obsolete unnecessarily.
The environmental calculation needs to consider the whole system
The environmental impact of an IP transition also deserves careful treatment.
Encouragingly, the consultation recognises that this question extends beyond the operational energy consumed when content is delivered. It asks respondents to consider infrastructure, consumer equipment, lifecycle impacts and technological change as part of the wider assessment.
We think that whole-system perspective is essential.
A simple comparison between the electricity required to deliver one hour of DTT and one hour of streaming risks overlooking the infrastructure required to support both models over time.
The more relevant policy comparison is closer to:
IPTV in 2034
versus:
IPTV plus another ten years of DTT infrastructure.
Broadcasters operate technology estates containing transmission infrastructure, specialist equipment, facilities, cooling, monitoring systems, redundancy and operational support. Extending DTT means continuing to operate and maintain much of that estate alongside the IP services that audiences are already adopting.
At the same time, the technology underpinning IP delivery will continue to evolve. Improvements in semiconductors, video codecs, networking, cloud infrastructure, CDNs, storage, consumer devices and software architecture all have the potential to change the efficiency profile of streaming over the coming decade.
We would therefore be cautious about extrapolating today’s IPTV energy consumption directly to 2034, just as we would be cautious about assuming that the cost and environmental impact of maintaining DTT will remain static.
The calculation should also include embodied carbon and electronic waste.
A transition to IP should not unnecessarily require millions of households to replace otherwise functional televisions. Wherever practical, simple and affordable adapters should be used to extend the useful life of existing equipment.
The environmental question is therefore not simply which delivery technology consumes less energy today.It is which transition pathway produces the best overall outcome across infrastructure, operations, consumer equipment and the full technology lifecycle.
Modernisation should not mean expanding yesterday’s regulation
Perhaps our broadest concern is what policymakers mean when they talk about “levelling the playing field”.
Technology-neutral regulation is a sensible objective - but there is a trap hidden inside the phrase.
A level playing field does not necessarily mean taking every obligation accumulated by traditional broadcasters over decades and imposing an equivalent version on every successful digital competitor. Sometimes the field is not uneven because a new entrant is insufficiently regulated. Sometimes an incumbent is carrying regulatory obligations designed for a market that no longer exists.
Those are very different problems.
Where traditional broadcasters face outdated or disproportionate requirements, the first question should therefore be:
Does this regulation still need to exist?
Only after answering that should policymakers ask whether equivalent obligations need to be applied elsewhere. Otherwise, “levelling the playing field” can become a one-way ratchet in which regulation continually expands but is rarely reconsidered. That risks freezing yesterday’s assumptions into tomorrow’s market.
A broadcaster exercising editorial control over a scheduled channel is not identical to a video-sharing platform hosting millions of creators. A connected-TV operating system is not the same as either of them - nor is an on-demand catalogue, a search service or a recommendation engine.
They exercise different forms of control, create different risks and have different relationships with audiences.Regulation should reflect those differences.
Technology neutrality should mean that comparable harms are treated comparably. It should not mean imposing identical obligations on fundamentally different services.
A modern framework therefore needs to distinguish carefully between:
editorial responsibility;
platform responsibility;
accessibility;
content discovery;
technical distribution; and
audience protection.
Proportionality matters too.
Obligations should follow demonstrable risk, responsibility and market power rather than simply the fact that a service has become popular.
The purpose of reform should be to create rules appropriate to the media market we are building, not to make new services resemble the businesses for which the existing rules were originally written.
A chance to build the next media market
There is much in Watch this Space that we welcome.
The Government has recognised that television is becoming IP-led, that the boundary between broadcasting and online media is disappearing and that a regulatory architecture developed for another technological era will need substantial reform.
Those are important conclusions - and the bigger question is what Government does with them.
There is a natural temptation when an established industry is disrupted to identify the institutions that mattered in the previous market and ask how regulation can preserve their position in the next one.
We think that would be a mistake. The historic influence of UK broadcasters is not, by itself, a public-interest outcome.
Trusted journalism matters. Universal access matters. UK-originated production matters. Accessibility matters. Plurality, cultural representation, children’s programming and coverage of events of national importance can all matter.
Those are outcomes that can be debated, defined and supported. Maintaining a particular organisation’s historic share of audience attention is something different. Regulation should not become a mechanism for trying to recreate historic patterns of audience attention.
Traditional broadcasters can and should play an important role in the next media era. They possess considerable creative, editorial and technical capability and remain responsible for some of the UK’s most important content.
But the strongest future for those organisations is one in which they continue to innovate successfully within a competitive market, not one in which the surrounding market is designed to reproduce the audience dynamics of the broadcast era.
The UK therefore has a much bigger opportunity than recreating the broadcasting environment of the past inside the technology platforms of the future.
It can create an IP-first ecosystem that is:
open;
interoperable;
competitive;
accessible;
resilient;
technology-neutral; and
capable of recognising public value irrespective of which institution creates it.
It can also regulate genuine harms without treating every successful challenge to an incumbent as evidence that something has gone wrong.
For us, that leaves one central question for the next phase of policy development.
It is not:
How do we preserve the position traditional broadcasters held in the broadcast era?
It is:
What outcomes genuinely matter in the next media era, and what is the least distortive way of achieving them?
That is a more difficult question.
But answering it is far more likely to produce a media market designed for where audiences are going, rather than one designed around where they used to be.
Watch this Space: Designing the future of UK television
The UK Government’s Watch this Space: A new strategic direction for UK media Green Paper asks some important questions about the future of television.
At Spicy Mango, we broadly agree with its starting point.
Television is becoming an IP-led medium. The distinction between broadcast and online video is increasingly difficult to sustain. Audiences move fluidly between linear television, broadcaster streaming services, global subscription platforms, YouTube and other video-sharing services. As DTT audiences decline, maintaining a nationwide transmission network for an ever-smaller proportion of viewing will inevitably become harder to justify.
There is therefore a strong case for reform. Where we are more cautious is over what that reform is intended to achieve.
The transition to IP creates an opportunity to design a more open, innovative and competitive television market. It should not become an exercise in reproducing the structures and audience dynamics of the broadcast era within a new generation of digital platforms.
That distinction informed much of our response to the consultation.
Our underlying principle is relatively simple:
Regulate harms, not competitors. Protect outcomes, not incumbents.
Audience change is not necessarily market failure
One of the challenges running through the Green Paper is the declining reach and influence of traditional broadcasters, particularly among younger audiences.
The Government describes domestic broadcasters, including public service media providers, as increasingly having to fight to be “seen and heard” in a fragmented and competitive market.
That is a legitimate policy consideration. Public service broadcasters play an important role in UK media, and there are clear public-interest outcomes that Government may reasonably want to preserve.
But there is a danger in treating the declining reach of institutions we value as evidence that the market itself has failed. They are not the same thing. Audiences have moved for many reasons, and not all of them are problems requiring regulatory correction.
Streaming platforms, video-sharing services and digital-native publishers have changed expectations around personalisation, interfaces, content formats, search, recommendation, accessibility across devices and the ability to consume content whenever and wherever people choose.
In many cases, newer services have gained attention because they have built products that audiences prefer using. That is competition.
It may be uncomfortable for established broadcasters, and it may create legitimate questions about how certain public-interest outcomes are sustained, but competitive displacement should not automatically be reclassified as market failure simply because the organisations losing share are culturally or institutionally important.
This matters because the diagnosis determines the regulatory response. If audiences cannot access important public-interest content because of structural barriers, intervention may be justified.
If audiences are choosing other products, formats or services, attempting to reverse that change through regulation is a much harder proposition to defend.
At its worst, prominence or platform intervention could become a mechanism for trying to recreate historic patterns of audience attention. We do not think regulation should do that.
The objective should be to preserve clearly defined public-interest outcomes, not historic levels of institutional influence.
An IP-first future should arrive sooner rather than later
On the underlying technology transition, our view is considerably less cautious.
We support a managed DTT switch-off by 2034 rather than 2044.
The fundamental technical question has already been answered. IP networks routinely deliver video services to very large audiences, including around major sporting, entertainment and national events.
The question is no longer whether television can be delivered over IP. It is how the remaining barriers to universal adoption should be addressed.
That does not mean a transition would be trivial.
Universal television over IP creates genuine challenges around broadband availability, affordability, resilience, accessibility and consumer equipment. But we see these as engineering and implementation requirements for a successful transition rather than reasons to maintain parallel infrastructure for another decade.
Modern IP platforms can be designed with geographic redundancy, multiple delivery routes, distributed content delivery, automated capacity management, extensive monitoring and graceful degradation.
No distribution system is immune from failure. The objective should be to engineer appropriate resilience across the whole delivery chain, from contribution and cloud infrastructure through to broadband access and the consumer device.
Notably, the Green Paper itself identifies potential benefits from a 2034 transition, including earlier cost efficiencies, spectrum benefits and faster innovation in content, services and user experience.
The more productive question is therefore not whether IP can replace DTT. It is what needs to be true by 2034 for everybody to make that transition successfully.
Our ranking of the principal transition challenges reflected that:
Promoting competition and innovation.
Delivering for all audiences.
Maintaining a reliable television service.
Supporting a sustainable future for public service media providers.
The ordering is intentional.
The future television ecosystem should first be designed to be competitive, open and capable of innovation. Universality and resilience must then be engineered into that environment. Public service organisations should be enabled to succeed within it.
The sustainability of today’s institutions should not be the first principle from which the architecture of the future market is designed.
Put another way:
Build a competitive and innovative market. Ensure everybody can participate. Make it resilient. Enable public service media to succeed within it.
Not:
Design the future market around preserving the structures of the existing one.
Moving to IP must not mean moving from one dependency to another
DTT has many limitations, but it provides a relatively common distribution environment.
IP changes that.
Television distribution can increasingly depend on operating systems, television manufacturers, streaming devices, application stores, identity platforms, proprietary interfaces and content-discovery systems.
As a result, the transition also shifts where market power can accumulate.
Spectrum and transmission infrastructure become less strategically significant. Device ecosystems, operating systems, search, recommendation and discovery become more significant.
For that reason, we believe open standards and interoperability should be treated as central components of the transition, not optional technical details to be considered later.
Government should encourage an environment in which:
services can operate across devices and platforms without unnecessary technical or commercial barriers;
consumers can retain compatible equipment for sensible periods;
common interfaces and standards are used where practical;
platforms and technology providers remain contestable;
services are portable between environments; and
broadcasters and new entrants do not become excessively dependent on a small number of proprietary providers.
A successful transition should increase competition, not merely exchange one form of infrastructure dependency for another.
Platform power is real. That does not make prominence the automatic answer
The Green Paper is right to focus on content discovery.
In the broadcast world, prominence was relatively easy to understand. Position within an electronic programme guide could materially affect whether audiences found a channel.
In an IP environment, discovery is much more complex.
Search results, recommendation algorithms, home-screen placement, personalised feeds, metadata, viewing history and editorial curation can all influence what somebody watches.
These systems undoubtedly confer significant power on platforms, and it is reasonable for policymakers to examine how that power is exercised.
Where we depart from some of the Green Paper’s reasoning is over the proposed response.
The paper argues that public service media content should be accessible and appropriately prominent across the platforms and devices audiences increasingly use to watch television.
We agree with the diagnosis that platforms exercise significant influence over discovery.
We are less convinced that institutional prominence is necessarily the right remedy.
There is an important difference between ensuring that a service cannot be unfairly excluded and requiring that it is positively advantaged.
The first protects competition. The second can distort it.
Content from the BBC, ITV, Channel 4, Channel 5 and other PSM providers should be capable of competing alongside commercial services, specialist publishers, independent producers and individual creators.
But no provider should receive preferential treatment purely because of its institutional status.
Otherwise, prominence risks becoming less about ensuring fair access and more about engineering a preferred audience outcome.
That should make policymakers cautious.
If audiences increasingly choose YouTube, Netflix, TikTok, a specialist publisher or something that has not yet been invented, the fact that those choices reduce the relative reach of traditional broadcasters is not, by itself, a reason to override them.
This is not an argument that public service media has no distinctive role. It is an argument that institutional status alone should not determine the outcome of search and recommendation systems. If particular content provides sufficient public value to justify special treatment, there is a legitimate debate to be had about that. But eligibility should follow objective characteristics of the content or service rather than simply the identity of the organisation producing it.
Public value should arise from demonstrable qualities and outcomes, not from the logo displayed before the content.
Transparency is different from regulating recommendation outcomes
There is another way of responding to concerns about platform influence.
Rather than attempting to prescribe what recommendation systems should recommend, policymakers could concentrate more heavily on transparency and accountability around how those systems operate.
Creators, publishers and service providers would benefit from:
clearer information about the principal factors affecting discoverability;
better analytics explaining how audiences find content;
meaningful notification when material platform changes affect reach;
stronger metadata, provenance and attribution;
effective review mechanisms where distribution is restricted; and
fair access to new platform functionality.
Transparency does not require platforms to publish source code, reveal every signal or make their systems easier to manipulate.
It means providing enough meaningful information for publishers and creators to understand the environment in which they operate, challenge material errors and make informed decisions.
That distinction is important: Transparency of recommendation systems is different from regulation of recommendation outcomes.
The former can help create a more accountable marketplace while leaving audiences and platforms substantial freedom over what they choose to surface. The latter risks regulators becoming progressively involved in determining which organisations should receive attention.
That is a considerably more interventionist proposition.
“Trustworthy news” requires particularly careful treatment
A related proposal is the possibility of giving greater prominence to “trustworthy” news.
The Government has not yet determined the criteria by which a trustworthy news provider would be identified and is consulting on how such a framework might operate.
We support the policy objective behind this.
Strong journalism, transparent editorial standards and access to reliable information are important components of a healthy media environment. Nor are we suggesting that all sources are equally rigorous or accountable.
There is useful common ground in the Green Paper’s focus on factors such as editorial controls, standards, complaints processes and transparency.
Our concern is that these process-based characteristics should remain at the centre of any future framework, rather than institutional status becoming a proxy for truthfulness.
Established broadcasters can have sophisticated editorial governance and still make mistakes, omit relevant context, exercise questionable editorial judgement or reach conclusions that later prove incorrect.
Conversely, specialist publishers and independent journalists can produce exceptionally rigorous work without belonging to the traditional broadcasting establishment.
We therefore think:
Trustworthiness should attach to process, not to an official determination of truth.
Relevant criteria might include:
editorial governance;
transparent ownership;
corrections policies;
complaints mechanisms;
provenance;
appropriate separation of reporting and opinion;
accountability; and
transparency around the use of AI-generated material.
These are characteristics that can be assessed comparatively objectively.
They do not guarantee that every output will be correct. No process can do that. But they provide a defensible basis for assessing whether a publisher behaves responsibly and can be held accountable.
Government deciding which organisations, viewpoints or individual pieces of journalism are officially “trustworthy” would be a much more problematic proposition.
Intervention also needs strong evidence
The Green Paper uses audience data to illustrate the changing competitive landscape, including BARB figures showing both the BBC and YouTube accounting for 19% of “total identified viewing” in the third quarter of 2025.
BARB is an established industry measurement system, and our concern is not with the legitimacy of audience measurement itself.
It is with the conclusions policymakers may draw from highly aggregated figures.
Presenting:
BBC - 19%
alongside:
YouTube - 19%
creates an intuitively powerful comparison.
But these are very different organisational categories.
The BBC is presented as a broadcaster, while YouTube is classified as a video-sharing platform. Each aggregates very different forms of content, creators, services and consumption behaviour beneath a single percentage.
A broadcaster and a platform are not necessarily equivalent units of competition.
The numbers may therefore be statistically valid within the methodology while still inviting conclusions about competitive equivalence that deserve closer examination.
That distinction becomes particularly important if such figures are subsequently used to justify intervention in search, recommendation or platform interfaces.
Before Government seeks to correct an alleged competitive imbalance, it should demonstrate that a genuine market failure exists using evidence in which the relevant services, audiences and forms of consumption are genuinely comparable.
Significant intervention deserves a correspondingly high evidential threshold.
Public service media should become more content-centric
The transition also provides an opportunity to rethink the meaning of public service media itself.
Historically, public service obligations have been closely connected to broadcast licences. In an IP-first environment, that relationship becomes increasingly artificial.
Public value does not inherently depend on whether something reaches an audience through DTT, IPTV, a broadcaster-owned application, a streaming service or a third-party video platform.
Here, there is significant common ground with the Green Paper.
Government proposes exploring a move away from regulating public service media principally through broadcast licences and considers institution-, service- and content-centric alternatives.
We strongly support that direction. Of the models explored, we believe a content-centric approach most closely reflects the future media environment. That does not diminish the role of existing PSM organisations.
The BBC, Channel 4 and other public service providers possess substantial production expertise, trusted brands, archives, journalism operations, commissioning capability and the scale to invest in ambitious UK content. They are likely to remain central to the delivery of public-service outcomes - but they need not be the only organisations capable of creating public value.
Independent producers, specialist organisations, digital-native publishers and individual creators may also produce content that advances clearly defined public-service objectives.
A more content-centric framework could recognise that contribution while allowing established PSM providers to continue playing a major role.
The critical safeguard is that the definition of qualifying public-service content must be objective, transparent and contestable. Otherwise, a content-centric system could simply reproduce institutional preferences through a different mechanism.
Universality needs a more precise definition
Universality remains an important principle, particularly as television moves away from DTT - but we think the terminology needs updating.
The Green Paper proposes that public service content should remain universally available and “free of charge”.
That wording masks several different concepts.
There is a distinction between:
universal availability;
free-at-the-point-of-consumption access;
the mechanism through which a service is funded; and
the connectivity and equipment required to receive it.
BBC television and iPlayer operate within the television licensing regime. Commercial PSM services are funded through advertising and wider commercial models. In an IPTV environment, households will also generally require broadband connectivity and compatible equipment.
A service may therefore be available without a subscription while still carrying material access costs for the household receiving it.
Those distinctions become considerably more significant once DTT is no longer available as an alternative.
Affordability is a real universality issue
For us, affordability is one of the most important practical questions surrounding the transition.
The Green Paper’s central forecasts suggest that around 880,000 households could still require suitable broadband to access IPTV in 2034.
Forecasts of this kind are necessarily sensitive to assumptions, but the scale illustrates why universality cannot be treated purely as a question of technical coverage.
Our preferred priorities are:
Affordable broadband suitable for television.
Targeted low-cost or subsidised broadband for low-income households.
Simple, inexpensive devices that make existing televisions IP-capable.
Accessibility built into devices and services.
Simple and intuitive user experiences.
Digital-skills support.
Subsidised replacement televisions where adaptation is not practical.
The principle is that Government should remove structural barriers before behavioural barriers.
A household that cannot afford broadband has a more fundamental problem than one that needs help navigating a menu. Accessibility and digital-skills support remain important, but neither can compensate for the absence of an affordable connection.
We would also strongly favour simple adapters over wholesale television replacement wherever practical. That would reduce the cost for households, simplify the transition and avoid rendering functional equipment obsolete unnecessarily.
The environmental calculation needs to consider the whole system
The environmental impact of an IP transition also deserves careful treatment.
Encouragingly, the consultation recognises that this question extends beyond the operational energy consumed when content is delivered. It asks respondents to consider infrastructure, consumer equipment, lifecycle impacts and technological change as part of the wider assessment.
We think that whole-system perspective is essential.
A simple comparison between the electricity required to deliver one hour of DTT and one hour of streaming risks overlooking the infrastructure required to support both models over time.
The more relevant policy comparison is closer to:
IPTV in 2034
versus:
IPTV plus another ten years of DTT infrastructure.
Broadcasters operate technology estates containing transmission infrastructure, specialist equipment, facilities, cooling, monitoring systems, redundancy and operational support. Extending DTT means continuing to operate and maintain much of that estate alongside the IP services that audiences are already adopting.
At the same time, the technology underpinning IP delivery will continue to evolve. Improvements in semiconductors, video codecs, networking, cloud infrastructure, CDNs, storage, consumer devices and software architecture all have the potential to change the efficiency profile of streaming over the coming decade.
We would therefore be cautious about extrapolating today’s IPTV energy consumption directly to 2034, just as we would be cautious about assuming that the cost and environmental impact of maintaining DTT will remain static.
The calculation should also include embodied carbon and electronic waste.
A transition to IP should not unnecessarily require millions of households to replace otherwise functional televisions. Wherever practical, simple and affordable adapters should be used to extend the useful life of existing equipment.
The environmental question is therefore not simply which delivery technology consumes less energy today.It is which transition pathway produces the best overall outcome across infrastructure, operations, consumer equipment and the full technology lifecycle.
Modernisation should not mean expanding yesterday’s regulation
Perhaps our broadest concern is what policymakers mean when they talk about “levelling the playing field”.
Technology-neutral regulation is a sensible objective - but there is a trap hidden inside the phrase.
A level playing field does not necessarily mean taking every obligation accumulated by traditional broadcasters over decades and imposing an equivalent version on every successful digital competitor. Sometimes the field is not uneven because a new entrant is insufficiently regulated. Sometimes an incumbent is carrying regulatory obligations designed for a market that no longer exists.
Those are very different problems.
Where traditional broadcasters face outdated or disproportionate requirements, the first question should therefore be:
Does this regulation still need to exist?
Only after answering that should policymakers ask whether equivalent obligations need to be applied elsewhere. Otherwise, “levelling the playing field” can become a one-way ratchet in which regulation continually expands but is rarely reconsidered. That risks freezing yesterday’s assumptions into tomorrow’s market.
A broadcaster exercising editorial control over a scheduled channel is not identical to a video-sharing platform hosting millions of creators. A connected-TV operating system is not the same as either of them - nor is an on-demand catalogue, a search service or a recommendation engine.
They exercise different forms of control, create different risks and have different relationships with audiences.Regulation should reflect those differences.
Technology neutrality should mean that comparable harms are treated comparably. It should not mean imposing identical obligations on fundamentally different services.
A modern framework therefore needs to distinguish carefully between:
editorial responsibility;
platform responsibility;
accessibility;
content discovery;
technical distribution; and
audience protection.
Proportionality matters too.
Obligations should follow demonstrable risk, responsibility and market power rather than simply the fact that a service has become popular.
The purpose of reform should be to create rules appropriate to the media market we are building, not to make new services resemble the businesses for which the existing rules were originally written.
A chance to build the next media market
There is much in Watch this Space that we welcome.
The Government has recognised that television is becoming IP-led, that the boundary between broadcasting and online media is disappearing and that a regulatory architecture developed for another technological era will need substantial reform.
Those are important conclusions - and the bigger question is what Government does with them.
There is a natural temptation when an established industry is disrupted to identify the institutions that mattered in the previous market and ask how regulation can preserve their position in the next one.
We think that would be a mistake. The historic influence of UK broadcasters is not, by itself, a public-interest outcome.
Trusted journalism matters. Universal access matters. UK-originated production matters. Accessibility matters. Plurality, cultural representation, children’s programming and coverage of events of national importance can all matter.
Those are outcomes that can be debated, defined and supported. Maintaining a particular organisation’s historic share of audience attention is something different. Regulation should not become a mechanism for trying to recreate historic patterns of audience attention.
Traditional broadcasters can and should play an important role in the next media era. They possess considerable creative, editorial and technical capability and remain responsible for some of the UK’s most important content.
But the strongest future for those organisations is one in which they continue to innovate successfully within a competitive market, not one in which the surrounding market is designed to reproduce the audience dynamics of the broadcast era.
The UK therefore has a much bigger opportunity than recreating the broadcasting environment of the past inside the technology platforms of the future.
It can create an IP-first ecosystem that is:
open;
interoperable;
competitive;
accessible;
resilient;
technology-neutral; and
capable of recognising public value irrespective of which institution creates it.
It can also regulate genuine harms without treating every successful challenge to an incumbent as evidence that something has gone wrong.
For us, that leaves one central question for the next phase of policy development.
It is not:
How do we preserve the position traditional broadcasters held in the broadcast era?
It is:
What outcomes genuinely matter in the next media era, and what is the least distortive way of achieving them?
That is a more difficult question.
But answering it is far more likely to produce a media market designed for where audiences are going, rather than one designed around where they used to be.
