Broadcast compliance guide

Any UK-based provider of an on-demand programme service (ODPS) — including catch-up TV, online film services, and archive content libraries — must notify Ofcom before the service begins.

Complete the Ofcom Notification Form at ofcom.org.uk. You must also notify Ofcom when the service closes or undergoes significant changes.

Tiered by annual turnover. Under £10m: no fee. Fees scale up with turnover over £50m paying the highest rate. See Ofcom’s 2025/26 Fee Statement for current figures.

Statutory targets set annually by Ofcom. Ten-year targets: 80% subtitled · 10% audio-described · 5% signed. Higher targets apply to PSBs — 90% subtitling for ITV/Channel 4. In 2025, 83 channels must provide access services.

Under the On-demand Programme Services (Tier 1 Services) Regulations 2026, VoD services with more than 500,000 average monthly UK users must meet: 80% subtitled · 10% audio-described · 5% signed. Four years to full compliance, interim targets at year two.

Services below 500,000 UK users are not Tier 1, but Ofcom expects progressive improvement. Good-faith efforts toward subtitling are expected even outside mandatory targets.

An ODPS must not contain material which risks harm to individuals or, through their behaviour, to society — covering incitement to hatred, facilitation of illegal acts, and content unsuitable for minors.

Any programme analysing current events, political controversy, or public policy may attract stricter due impartiality obligations.

Product placement is prohibited in children’s programmes on ODPS. Age-appropriate access controls must be in place for all content accessible to minors.

Ofcom has designated the ASA as co-regulator for advertising within ODPS. Editorial content is Ofcom’s; advertising standards are the ASA’s.

ODPS providers must ensure that in each year, on average at least 30% of their catalogue is European works, and this content must be made prominent.

This obligation was transposed into UK law before Brexit and remains in force under the AVMS Regulations 2020. It applies to all UK-based ODPS providers.

The Audiovisual Media Services Directive (AVMSD) is the EU’s primary regulatory framework for all television broadcasters and on-demand video services. It sets minimum standards that all 27 member states must transpose into national law.

Any video-on-demand or linear TV service established in an EU member state, regardless of where viewers are located. Services established outside the EU that target EU audiences may also fall in scope under country-of-destination rules.

You are regulated by the member state in which you are established — typically where your head office is located and editorial decisions are made. You cannot shop for the lightest-touch jurisdiction — the AVMSD prevents regulatory arbitrage between member states.

Each member state has its own media regulator (e.g. Ofcom equivalent): Arcom in France, die Medienanstalten in Germany, AGCOM in Italy, CNMC in Spain. The European Regulators Group for Audiovisual Media Services (ERGA) coordinates between them.

All AVMS providers — both linear and on-demand — must notify the competent authority in their member state of establishment before the service begins.

Notification requirements vary by member state. In France, notify Arcom; in Germany, the relevant Landesmedienanstalt; in Ireland, the Broadcasting Authority of Ireland (BAI, now Coimisiún na Meán). Most require a written notification with service description, ownership structure, and editorial contact.

Vary significantly by country. Some member states charge annual fees based on turnover; others have flat registration fees. Germany and France have the most complex fee structures for larger services.

AVMSD Article 7 requires member states to ensure AVMS providers continuously and progressively make their services more accessible to persons with disabilities through subtitling, audio description, sign language, and accessible electronic programme guides.

The EAA (Directive 2019/882) came into force on 28 June 2025. It mandates that audiovisual media services and their dedicated apps are accessible to persons with disabilities across all EU member states.

Accessible user interfaces; subtitled content; audio description for key programming; sign language interpretation where required; accessible electronic programme guides; and accessible customer support channels.

All AVMS providers must ensure content that incites violence, hatred, or terrorism is prohibited. On-demand services must take appropriate measures to protect minors from content that may impair their physical, mental, or moral development.

Content harmful to minors must be restricted so minors will not normally see or hear it — through PIN codes, age verification, or watershed mechanisms. The most harmful content (graphic violence, pornography) must be subject to the strictest access controls.

Advertising, teleshopping, and sponsorship must be clearly identified. Advertising to children for foods high in fat, sugar, and salt is restricted or prohibited. Surreptitious advertising is banned.

Broadcast TV channels may not exceed 20% advertising per clock hour between 06:00–18:00 and 18:00–midnight. Spot advertising must be limited to these windows. VOD services are not subject to the same quantitative limits.

The DSA applies to all online intermediary services operating in the EU, including video platforms. Requirements scale by size: basic obligations for all providers; additional obligations for Very Large Online Platforms (VLOPs) with 45 million+ average monthly EU users.

All in-scope providers must: publish transparent terms of service; maintain a single point of contact for authorities; establish complaint and redress mechanisms; cooperate with trusted flaggers; publish annual transparency reports on content moderation.

Platforms with 45M+ EU users face additional requirements: annual systemic risk assessments; independent audits; data sharing with researchers; crisis response protocols; prohibition of targeted advertising to minors; prohibition of profiling based on sensitive data.

Up to 6% of global annual turnover for non-compliance. Repeated infringements can result in temporary access restrictions. The European Commission directly enforces against VLOPs.

All processing of EU residents’ personal data must have a lawful basis. For analytics, advertising, and recommendation engines, freely given, specific, informed, and unambiguous consent is typically required.

EU viewers have rights to: access their data; correct inaccuracies; request deletion; object to processing; data portability. Services must respond to subject access requests within one calendar month.

Non-essential cookies (analytics, advertising, personalisation) require prior opt-in consent. Pre-ticked boxes and consent bundled with terms of service are not valid. The ePrivacy Directive (Cookie Law) applies alongside GDPR.

Most member states require registration with the national Data Protection Authority if you process personal data systematically. Penalties up to €20 million or 4% of global annual turnover — whichever is higher.

All VOD services must ensure at least 30% of their content catalogue consists of European works and that these works are made prominent to users. This applies to every VOD provider established in an EU member state.

Member states may require VOD services targeting their audience — even if established elsewhere in the EU — to make financial contributions to the production of European works. France, Germany, Italy, and Spain have active levies.

Services established outside the EU but targeting a specific member state’s audience may be subject to that country’s financial contribution requirements. This is the mechanism most likely to catch non-EU streaming services.

France’s Centre National du Cinéma requires VOD services targeting French audiences to contribute a percentage of French revenues to local film and TV production. Foreign services with French subscribers are not exempt.