The Children’s Media Foundation (CMF)

Policy Round-Up

CMF Director Greg Childs sent this presentation to the Screen Producers of Australia 20th November Screen Forever Conference. It outlines the key UK policy initiatives in the kids’ media sector.

You can watch the entire presentation here:

Our perspective at the Children’s Media Foundation is audience advocacy. But in pursuing that we believe in, and campaign for, a healthy, well-funded, well-regulated children’s media production sector to serve that audience. We are essentially a critical friend.

For example, CMF first proposed a fund to support children's content outside the BBC, back in 2011.

That fund is now becoming a reality and, along with some other policy initiatives, we are about to see some significant changes in the way children's and youth content is supported and, we hope, produced in the UK.

The context of that is essentially market failure, as identified by our regulator Ofcom’s studies over the last ten years.  Their recent children’s market review revealed a decrease in spending on children's content at the public service broadcasters, from £116m in 2006 to £70m in 2017 - and most of that £70m is now the BBC.

This of course goes hand in hand with the fragmentation of advertising revenues and increased regulation of advertising to children, which makes ad-funded children’s content extremely difficult for commercial channels. And that includes our commercial public service channels – which are ITV1, Channel 4 and Channel 5. Essentially – they complement the BBC by accepting some public service obligations in return for EPG prominence.  But since 2003 those obligations haven’t included children’s programmes.  So the hours of children's content on these channels have decreased significantly.

But after some years of campaigning by the producers’ association Pact, Animation UK and CMF, a number of policy initiatives have been the result.

Tax incentives for animation were followed up with tax breaks for children’s television, which result in a rebate of around 18% of a programme’s budget.  It should be said that in both cases there is evidence of broadcasters reducing their tariffs to cream off the tax incentive benefit. Nevertheless, this has helped keep producers afloat.

The in 2016 a government proposal was announced to create a new fund to finance production of public service content outside the BBC.  £60m of funding was found - using television licence fee revenues which had been under-spent on a broadband roll-out project entrusted to the BBC.

The fund was proposed as a three-year pilot and after much campaigning we managed to persuade the government to allocate almost all of it to children’s and youth content. Hence the name announced in October – The Young Audiences Content Fund.  The Fund will offer 50% of the funding for a project, against certain criteria which aim to address the market failure. So content for older children and young teens will be prioritised, as will content which helps them make sense of the world (timely – in the face of the fear of fake news) and content that holds up a mirror to their lives in the UK. The new Fund will be operational from April 2019. Producers will apply. The content will have to have the support of a platform which is “free at the point of use” - so that seems to point almost entirely towards the three public service commercial broadcasters - though not necessarily their mainstream channels.

We think this aspect should be freed up to make the Fund “future-proof” - reflecting VoD as the way kids discover content. It remains to be seen how that will play out.

Where the other 50% of the funding comes from will depend upon the extent to which broadcasters want to play ball. Or whether other forms of funding such as distribution or co-financing will fill the gap. But the dilemma there may well be that if the content must be locally relevant - can it also be internationally viable?

The Fund goes hand in hand with another policy initiative initiated by an amendment to the recent Digital Economy Act, restoring to Ofcom the power to regulate the commercial PSBs to commission or at least carry more children's content - the power the regulator lost in 2003.

This is inevitably complicated.  Ofcom has not been told it must regulate, simply that it “may.”  The campaigned-for amendment was watered down to gain government support. After being granted these additional powers Ofcom conducted the extensive market review I mentioned earlier, and it has now written to the three commercial Public Service Broadcasters asking them to address the shortfall in investment and programming for children. We will hear their responses in March 2019. There’s already some evidence of a shift away from their “we are a business” attitude, to some willingness to engage with the new Young Audience Fund and do more.

This softly softly approach is intended to get around the fact that Ofcom cannot create quotas for ITV’s CITV channel - it can only regulate the actual public service commercial channels, like ITV1. But that is the mainstream entertainment destination and carries very few children’s programmes, and the scenario is similar with Channel 4.  So Ofcom is trying to reach a position where the broadcasters will voluntarily take on their responsibilities and place the new content where children and young people will find it, rather than have it forced onto the mainstream channels. This includes their specialist digital channels and potentially online delivery.

The Fund is for new contentoutsidethe BBC, which incidentally is also now regulated by Ofcom.

Our next concern? What happens after the pilot? Where will the money be found to continue or even expand the Fund?  We’d be opposed to it coming to from the Licence Fee as that will simply reduce the BBC’s capacity to serve the children’s audience.

With further government policies on the horizon such as a Tech tax on the major internet platforms and talk of regulation if they won’t put their houses in order – I begin to wonder whether a digital levy might be a possible solution.

But that’s the next campaign…  For now we can say that for once policies seem to have actually lined up to create some form of “joined up government...”

Will it work? Ask me in 3 years’ time …

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