Consultation outcome

DMG Media

Updated 30 October 2025

• DMG Media welcomes the opportunity to comment on SI No.2^{[footnote 1]}.  For over a century, our titles have held the powerful to account. We continue vigorously to champion the free press and editorial autonomy.  We are grateful to the Secretary of State for the considerable work which has gone into updating the legislation concerning foreign state investment in UK news sources.  It is vital that the correct balance is struck between preventing British newspapers from falling under the control of foreign powers, which would damage British democracy and the media freedom which underpins it, while at the same time ensuring that UK newspaper companies have access to sufficient investment to sustain publication in an ever more challenging digital marketplace.

• We believe 15% is an appropriate threshold for maximum holdings for sovereign wealth funds and other state-owned investors (“SOIs”).  However, we question the fairness of SI No.2’s preferential treatment of quoted UK newspaper groups, as opposed to their privately held competitors, when it comes to aggregating rights held by SOIs on behalf of different foreign states.  

• We have structured our response in accordance with DCMS’ three consultation questions.  

Question 1: We would welcome views on the operation of the cap on multiple SOIs from different foreign states, and on the scope of the exclusion of 5% holdings of shares or voting rights in quoted enterprises.

• The Foreign State Influence regime contains an exception permitting SOIs to hold up to 15% of the shares or voting rights in a UK newspaper owner^{[footnote 2]}.  If enacted in its current form, SI No.2 would introduce a requirement to aggregate shares or voting rights held by SOIs on behalf of different foreign states when applying this exception, unless a holding (i) does not exceed 5% of the total shares or voting rights in the newspaper owner and (ii) is in a quoted company^{[footnote 3]}. 

• SI No.2 would therefore afford preferential treatment to quoted companies, relative to privately-owned companies.  Taken together with the existing (expansive) interpretative rules on when shares or rights in a newspaper owner are deemed to be held “indirectly”^{[footnote 4]} (the “indirect holdings test”), SI No.2 could also curb the ability of UK newspaper groups to finance their operations. 

• Denying privately-owned companies the benefit of the proposed carve-out could restrict their ability to raise the capital that is required to produce high-quality journalism in a rapidly changing media landscape.  It would also risk distorting competition among publisher groups – it is notable, for example, that quoted groups such as News UK and Reach would have an advantage over privately-owned groups such as DMG Media, Guardian Media Group and Telegraph Media Group.  It would be inappropriate to discriminate in this way against private companies when, as is currently the case, more newspaper publisher groups are privately owned than are publicly quoted.

• DCMS’ SI No.2 consultation document gives no reason for the preferential treatment of quoted companies, other than that it is difficult for quoted companies to know the identities of new holders of shares or voting rights unless they reach reporting thresholds for share transactions.  But a stake below 5% (in the absence of other governance rights) cannot plausibly confer influence over a UK newspaper, whether it is part of a quoted group or not, and private companies should not be prevented from funding their operations in the same way as their quoted rivals.

• SI No.2 should therefore be amended such that SOI investments of up to 5% in private UK newspaper companies are not aggregated for these purposes – in line with the proposed carve-out for quoted companies.

Question 2: We would welcome views on the practical effect of the information requirement from both newspaper groups and from investors and financial and legal advisers and whether any additional requirements or safeguards need to be added.

• We do not believe that any additional requirements or safeguards need to be added.

Question 3: We would also welcome views on whether the new requirements create any unintended consequences for potential investors or for newspaper groups in reaching agreements with potential SOI investors, if possible with practical examples?

• We do not foresee any unintended consequences beyond the discriminatory effect that limiting the carve-out for SOI investments of up to 5% to quoted companies only will have on the ability of privately-owned newspaper groups to raise funding for investment and growth. No meaningful explanation or justification has been given for this discrimination, which we find surprising, given the Government’s strong emphasis on growth as a policy objective. Discriminating against private companies may also have a damaging effect on media plurality, which is best served by encouraging a broad range of media ownership models.

**DMG Media

September 2025**

Footnotes 

1. This response is made by DMG Media, publishers of the Daily Mail, Mail on Sunday, Metro and, through its sister company Harmsworth Media, the i Paper and New Scientist; and all their respective websites. ↩

2. S. 2B, Part 1A, Schedule 6B Enterprise Act 2002. ↩

3. S. 2(4), SI No.2. ↩

4. S. 9, Part 2, Schedule 6B Enterprise Act 2002 ↩