Reforms to boost confidence in the BBC’s impartiality and complaints system set out in Mid-Term Review

Government recommends reforms to boost public trust in the BBC following a review at the mid-point of its 11 year Charter

  • Review recommends greater independent scrutiny of complaints handling, improving transparency for commercial media organisations, and extending Ofcom oversight over more BBC online services 
  • BBC urged to better reflect diverse views and opinions in decision-making and improve engagement with underserved audience groups, among other key recommendations 

The government has recommended major reforms to help boost audience confidence in the BBC’s  impartiality and complaints system, following the first Mid-Term Review published by the government today.

Launched at the halfway point of the BBC’s 11 year Royal Charter, the Mid-Term Review evaluates the effectiveness of the governance and regulatory arrangements introduced by the Charter in 2017, with recommendations to ensure the best outcome for audiences. 

Audiences will be given greater certainty that their complaints about BBC TV, radio and on demand content - including concerns about bias - are dealt with fairly, through greater scrutiny of its complaints process, which is to be made more independent from programme makers. A new legally binding responsibility on the BBC Board will require it to actively oversee the BBC’s complaints process to assure audiences that their concerns are being fairly considered. 

In recognition that audiences are increasingly getting their news and watching content online, Ofcom oversight will be extended to parts of the BBC’s online public services, including the BBC News website, to enable Ofcom to hold the BBC to account in a more robust way. And Ofcom will be given a new legally binding responsibility to review more of the BBC’s complaints decisions, meaning audiences can have greater confidence that their complaints have been handled fairly.

The Mid-Term Review stresses the need for the BBC to clearly demonstrate how it will meet its obligations on distinctiveness over the remainder of this Charter period, and for the BBC to meaningfully engage with its competitors, such as radio stations and local newspapers, when it is considering a change to its services.

The government consulted the BBC and Ofcom closely on the recommendations and expects them to be implemented in a timely manner. The government has also identified some key issues as a result of the Mid-Term Review that need to be further considered at the next Charter Review before 2027. 

In particular, we will continue to place a strong emphasis on impartiality and complaints, including reviewing the effectiveness of the BBC’s new social media guidelines and whether the BBC First model - formally introduced by the Charter in 2017 - process remains the right model for complaints, as well as how distinctive BBC output and services are from those of commercial providers. The Government has highlighted these priorities for the next Charter in correspondence with the BBC. 

Culture Secretary Lucy Frazer said:

"The Government wants to see a strong, independent BBC that can thrive in the years to come as a major contributor to the nation’s successful creative industries. 

"In a rapidly changing media landscape the BBC needs to adapt or risk losing the trust of the audiences it relies on. Following constructive conservations with the BBC and Ofcom, we have recommended reforms that I believe will improve accountability while boosting public confidence in the BBC’s ability to be impartial and respond to concerns raised by licence fee payers.

"These changes will better set up the BBC to ask difficult questions of itself, and make sure Ofcom can continue to hold the broadcaster to account. We all rely on the BBC being the best it can be and this review will help ensure that is what the British public gets."

Complaints and impartiality 

The Mid-Term Review has concluded that the BBC’s complaints process introduced at the last Charter Review in 2017, known as BBC First - where audience complaints are normally addressed by the BBC before they can be escalated to Ofcom - allows licence fee payers to hold the BBC directly accountable. 

However, impartiality continues to be an ongoing issue for audiences, with concerns about the broadcaster’s objectivity making up the majority of complaints about the BBC’s editorial content. The review highlights a lack of public confidence in the way the BBC currently handles complaints.

Following challenging and constructive conversations with the government, the BBC will introduce reforms to enhance the independent scrutiny of its complaints handling and further improve the experience of viewers who make a complaint. 

The BBC Board previously had a responsibility to oversee only the establishment of a complaints handling process. We are now giving the entire Board the responsibility to oversee how that process is working in practice. Furthermore, the non-executive board directors and external advisors on the BBC’s Editorial Guidelines and Standards Committee will be given greater powers to scrutinise and challenge how BBC senior management responds to complaints. 

The job role which has responsibility for complaints handling now reports directly to the Director General rather than the Director responsible for editorial policy, separating pre-broadcast editorial policy and post-broadcast complaints resolution.

Currently Ofcom regulates the BBC’s TV, radio and on demand output, but not other elements of its online content. The government has committed to extending Ofcom regulation to other elements of the BBC’s online public service material in order to give audiences confidence that the BBC is being held to greater account across its digital services. The government expects this to apply to BBC branded content on third party websites, applications and other online interfaces over which the BBC has editorial control - including the BBC News website and the BBC’s YouTube channel.

The review recommends the BBC materially improves the experience of audiences when lodging a complaint by giving clearer explanations of the process and the roles of the BBC and Ofcom, to ensure licence fee payers are not put off from sharing their views. The review also recommends Ofcom improves the transparency of its decision making when considering whether to open a formal investigation into content that the BBC has found has breached its own editorial standards. This will help audiences to better understand whether Ofcom is taking further regulatory action and why.

At Charter Review, the government is committing to examining whether BBC First remains the right complaints model to enable the BBC to deliver against its responsibility to serve all audiences.

To help the BBC go further to tackle perceptions of bias, the review also recommends that the BBC publishes more information about the work it is doing to strengthen the impartiality of its editorial content, including to illustrate the impact it’s having.

The BBC’s impact on the wider market 

Looking at the BBC’s impact on the UK media landscape, the review sets out that the BBC must clearly demonstrate how it effectively balances delivering for licence fee payers and supporting the UK’s wider creative industries when making decisions about how its services and output are distinctive. This is increasingly important given broader structural trends in some of the markets in which the BBC operates, such as online local news, and will be an important question for the Charter Review.

Meaningful engagement with competitors should be strengthened and the BBC must be more transparent when it seeks to make changes to its services. This higher standard of engagement and transparency should support other businesses operating in the same markets as the BBC, including commercial radio stations and local news publishers. The government has recommended that Ofcom publish an annual high-level view on the BBC’s position in the local news sector, as it does for other sectors, to provide further clarity.

The government has also recommended that the BBC develop a public strategy outlining how it will partner with others, and provide competitors with greater clarity on how it will make decisions on partnerships. 

While the government supports the BBC’s ambitious plans to grow its commercial revenue, and has found that the governance and regulation of its commercial activities works effectively, the impact of  any changes, such as the introduction of a BBC Commercial Board in 2022, needs to be closely monitored.


As a national broadcaster, the BBC has a duty in its Charter to accurately reflect, represent and serve diverse communities across the UK, both on and off the screen. 

While the BBC has said it is committed to improving representation, the review recommends it considers how diversity of thought and opinion could be better reflected in its decision-making. Some audience groups, for example, disabled viewers and people from lower socioeconomic backgrounds, feel underrepresented by the BBC. We recommend that the BBC works to ensure engagement with these groups is sufficient to best understand their specific needs and concerns.

Department for Culture, Media and Sport
The Rt Hon Lucy Frazer KC MP