Consultation outcome

Press Freedom Project

Updated 30 October 2025

Executive Summary

We are pleased to present in this document our reply (PFP Reply) to the DCMS Consultation concerning The draft Enterprise Act 2002 (Mergers Involving Newspaper Enterprises and Foreign  Powers) (No.2) Regulations 2025 (SI 02), published on 16 July 2025. 

This PFP Reply consists of three Sections & an Annex: 

1. Specific Comments: on the three Questions set out in the DCMS Consultation 

2. Specific Policy Proposals: for inclusion in SI 02 (see Table in Annex) 

3. General Remarks: on the present ‘state-of-play’ concerning the legislative & regulatory situation  of UK media, in particular resulting from the various recent measures on foreign-state ownership of  newspaper enterprises 

We draw extensively on two sources: 

• the 22 July 2025 House of Lords Debate on Statutory Instrument N° 1 (HoL Debate) 

• the 25 November 2024 House of Lords Report of the Communications and Digital Committee on UK  Media, entitled The Future of News (HoL Report) 

Our principal recommendations are: 

• Given that the fundamental motivation of the present draft SI 02 and its preceding legislative  and regulatory dispositions is to curb ‘undue influence’ on UK media, we recommend strongly that  clear limits are set immediately by DCMS to eliminate ‘grey areas’ concerning the SOI definition  that could give rise to anomalous situations that undermine press freedom! 

• We strongly recommend that DCMS immediately spells out comprehensively how it intends to  ‘police’ undue influence, and above all what additional powers & resources it urgently requires for  itself & its agencies effectively to combat such serious democratic threats and reverse the results  of any illegal act already committed! 

• We strongly urge the DCMS to engage with us to explore which Press Freedom Trust governance model or hybrid combination can be recommended to UK media enterprises & journalists! 

We would be delighted to discuss all or any of the elements of our PFP Reply with the DCMS and/or  with any other party interested by our recommendations. 

1. Specific Comments

This first section of our PFP Reply to the DCMS Consultation on SI 02 provides our specific comments  on the three Questions set out in Consultation on The draft Enterprise Act 2002 (Mergers Involving  Newspaper Enterprises and Foreign Powers) (No.2) Regulations 2025, published on 16 July 2025. 

DCMS Question 1. We would welcome views on 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.

• We agree with the proposal to include in SI 02 the imposition of an aggregate limit of 15% on the  shares or voting rights which can be held in a UK newspaper owned by multiple SOIs acting on behalf  of different foreign states. 

• We also agree with the proposal to exclude, from SI 02’s 15% aggregate cap for multi-state SOI  holdings, holdings of shares or voting rights in quoted companies below 5%. 

• Our agreement is conditional upon greater clarity concerning various definitions in both this  Regulation & the underlying legislation, and in particular that of “sovereign wealth funds and other  state-owned investors (SOIs)”. As set out below in the third section (General Remarks) of our PFP  Reply, we recommend that the DCMS issues rapidly the necessary guidance on these definitions (‘for  the avoidance of doubt’ …). 

DCMS 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 agree with the proposal to require SOIs to notify DCMS within 14 days of an acquisition  completing where the SOI has acquired a holding of shares or voting rights in a UK newspaper which  is above 5%. 

• We consider that the requirement to notify will apply also on an obligatory basis to SOIs making  acquisitions which result in them having an indirect holding in a UK newspaper of more than 5% (the  term ‘indirect holding’ requires precise definition, since many investors use one or more SPVs for  fiscal & other purposes). 

• We encourage the DCMS, in the context of this ‘information requirement obligation’, to implement  Baroness Stowell’s “recommendation that the Secretary of State be required to notify Parliament on  a twice-yearly basis if she receives any such notifications, and about the actions that she has taken as  a result” (Hansard, HL Deb 22 July 2025 (Enterprise Act 2002 regulations debate), 16:00:00-16:15:00).  See also Section 2 below of this PFP Reply. 

• All obligations ex post rather than ex ante open the door in the commercial world to unscrupulous  actors exploiting their participation in the capital of a newspaper or other enterprise immediately to  force through major changes in management & strategy. In the case of a powerful SOI, its investment  in the target enterprise may even have been made conditional on such changes being immediately  executed, to which the controlling shareholder will have agreed ex ante. In those circumstances the  DCMS will be incapable of ‘unwinding’ such changes, even if notified ex post within the 14 day period  required by SI 02, and even if the CMA subsequently obliges the SOI to sell its participation. The  danger of such faits accomplis is real, given the confirmed habits of certain autocracies.

DCMS 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?

• Your proposed new information requirements should not deter those SOIs who respect Baroness  Twycross’ definition as set out in her opening speech on 22 July 2025: “this exception applies only to  a very narrow group of public bodies: sovereign wealth funds and public pension schemes or similar”  (Hansard, HL Deb 22 July 2025 (Enterprise Act 2002 regulations debate), 15:27:00-15:45:00). 

• Correspondingly, newspaper groups who seek investments from SOIs deterred by your proposed  new information requirements should be alerted by such hesitations – any concern about such  ‘transparency’ requirements may also put in doubt the SOIs’ willingness to be ‘passive investors’. 

2. Specific Policy Proposals

This second section of our PFP Reply to the DCMS Consultation on SI 02 provides our specific Policy  Proposals for inclusion in the Statutory Instrument entitled The draft Enterprise Act 2002 (Mergers  Involving Newspaper Enterprises and Foreign Powers) (No.2) Regulations 2025, published on 16 July  2025. 

We have selected our specific Policy Proposals among the numerous excellent requests &  suggestions made by Peers during the remarkable 22 July 2025 House of Lords Debate on Statutory  Instrument N° 1. Our selection is short, since we recognise the need to remain practical in order to  simplify appropriate drafting for inclusion in SI 02. 

(NB: these selected Policy Proposals are presented with relevant quotes (drawn from Hansard) in the  Table annexed to our PFP Reply, entitled Annex – PFP Reply – DCMS Consultation – SELECTED POLICY  PROPOSALS for inclusion in Statutory Instrument N° 2.) 

For the sake of completeness (and for the avoidance of doubt), we present as the first two items in  our Policy Proposals Table the ‘Aggregate Foreign State Ownership Cap’ (Item 01) and ‘Mandatory  Notification Requirements’ (Item 02) measures already included in the draft SI 02. 

We now summarise our three additional Policy Proposals, not yet included in the draft SI 02:  

Parliamentary Oversight & Transparency (Item 03) 

Policy Proposal: Secretary of State required to publish biannual (or more frequent) reports to  Parliament on all notifications, investigations, and enforcement actions under the foreign ownership  regime 

Policy Proponent(s): Baroness Stowell, Baroness Twycross (Minister) 

Parliamentary Quote Sources: Baroness Stowell – Hansard, HL Deb 22 July 2025 (Enterprise Act  2002 regulations debate), 16:00:00-16:15:00; Baroness Twycross – Hansard, HL Deb 22 July 2025  (Enterprise Act 2002 regulations debate), 17:30:00-17:45:00 

Policy Implementation: To Be Confirmed – we recommend inclusion in SI 02 

Rigorous Scrutiny of Major Transactions (Item 04) 

Policy Proposal: Strengthening of required Competition and Markets Authority (CMA) scrutiny of  proposed sales/acquisitions, with specific attention to editorial independence and beneficial  ownership, before completion of major deals.

Policy Proponent(s): Baroness Stowell, Lord Alton, Lord Lansley, amongst others 

Parliamentary Quote Sources: Baroness Stowell – Hansard, HL Deb 22 July 2025 (Enterprise Act  2002 regulations debate), 16:00:00-16:15:00; Multiple other speakers – Hansard, HL Deb 22 July  2025 (Enterprise Act 2002 regulations debate), various timestamps 

Policy Implementation: To Be Confirmed – we recommend inclusion in SI 02 

Broader Plurality and Tech Platform Regulation (Item 05)

Policy Proposal: Extension of public interest merger regime to cover online news aggregators and  major digital platforms, not just traditional print, by including these entities within the definition of  ‘newspaper’ 

Policy Proponent(s): Lord Lansley 

Parliamentary Quote Source: Lord Lansley quote: Hansard, HL Deb 22 July 2025 (Enterprise Act  2002 regulations debate), 17:00:00-17:15:00 

Policy Implementation: To Be Confirmed – we recommend inclusion in SI 02 

3. General Remarks

This third section of our PFP Reply to the DCMS Consultation on SI 02 provides our general remarks  on the present ‘state-of-play’ concerning the legislative & regulatory situation of UK media, in  particular resulting from the various recent measures on foreign-state ownership of newspaper  enterprises. 

The HoL Debate of 22 July 2025 & the HoL Report of 25 November 2024 are rich sources of policy  proposals covering a wide range of issues facing UK media today, based often on divergent  interpretations of the existing legislative & regulatory framework, and the definitions which underpin  it. 

We limit our general remarks today to three issues, all inter-related, and all subject to divergent  interpretations. 

a) State-Owned Investors (SOIs)

We observe pervasive confusion concerning the definition of this vital term. We are therefore  grateful to Baroness Twycross for her opening statement at the HoL Debate (Hansard, HL Deb 22 July  2025 (Enterprise Act 2002 regulations debate), 15:27:00-15:45:00), providing her interpretation of  the definition of SOI, and setting this definition within today’s legislative & regulatory context. 

We start by setting out our understanding of three terms, which while related, have distinct legal  meanings in UK legislation: 

• a ‘foreign power’ (as defined in the Enterprise Act 2002 and National Security Act 2023)  encompasses the broadest category, including foreign sovereigns, governments, their agencies and  authorities, and governing political parties 

• a ‘foreign government’ refers specifically to the executive authority of a foreign state, including its  constituent parts, departments, and agencies 

• a ‘foreign state’ designates any country or territory outside the United Kingdom, the Channel  Islands, the Isle of Man, and British Overseas Territories

Under the existing legislative & regulatory framework, none of these ‘entities’ as defined above can  buy or own a British newspaper enterprise. This specific interdiction is set out clearly in the following  texts: 

• Digital Markets, Competition and Consumers Act 2024, Schedule 7, Section 70A - which inserted  Chapter 3A into Part 3 of the Enterprise Act 2002, establishing the Foreign State Influence (FSI)  regime that prohibits foreign powers from controlling or influencing UK newspaper policy. 

• Enterprise Act 2002, Schedule 6B, paragraph 1 (as inserted by the DMCC Act 2024) - which defines  the conditions under which “a foreign power is able to control or influence the policy of a person”  including: 

• Condition 1: holding any shares in the person (directly or indirectly) 

• Condition 2: holding any voting rights in the person (directly or indirectly) 

• Condition 3: holding the right to appoint or remove officers 

• Condition 4: having the right or ability to direct, control or influence the person’s policy or  activities to any extent 

• Condition 5: indirect control through trusts or other entities 

• Enterprise Act 2002, Section 70A(3) (as inserted) - which defines a “foreign state newspaper merger  situation” that triggers mandatory Secretary of State intervention when “a foreign power is able to control or influence the policy of the person carrying on the newspaper enterprise, or is able to  control or influence that policy to a greater extent.” 

• Enterprise Act 2002, Section 70E (as inserted) - which defines “foreign power” comprehensively to  include sovereigns, governments, government agencies, political parties, and their officials in both  public and private capacities. 

This framework creates an absolute prohibition - any holding of shares, voting rights, or ability to  influence policy by foreign powers in UK newspapers triggers the mandatory intervention regime,  with the Secretary of State required to make orders “for the purposes of reversing or preventing the  creation of the foreign state newspaper merger situation”. 

The current regulations being debated create only limited exceptions for certain state-owned  investors under very strict conditions, but the underlying prohibition remains absolute for all other  foreign power entities. 

In her opening HoL Debate speech, Baroness Twycross refers both to this absolute ‘underlying  prohibition’ and to the limited exceptions for certain state-owned investors under very strict  conditions: 

The previous Government also made clear before the election that they would put in place  exceptions to encourage investment by sovereign wealth and other state-owned investors  and issue a consultation. To clarify—in response to the point from the noble Lord, Lord  Forsyth—this exception applies only to a very narrow group of public bodies: sovereign  wealth funds and public pension schemes or similar. It does not apply to states themselves or  other state bodies, so a foreign Government cannot buy and own a newspaper. 

Baroness Twycross has thus confirmed that her definition of a State-Owned Investor comprises only  “sovereign wealth funds and public pension schemes or similar”.

We conclude that, by her definition, an SOI is an entity ostensibly not directly controlled by the  foreign state concerned, and typically benefits from some form of governance purported to be  independent of the state, even if the relevant foreign government participates in this governance  and may constitute the determining decision-maker. Sovereign wealth funds and public pension  schemes formally correspond to this description. 

Baroness Twycross nevertheless widens her definition by including the term “or similar”. We strongly  recommend that DCMS issues urgently further guidance on this issue, specifically by providing a  comprehensive range of examples of entities both explicitly covered and explicitly excluded by her  definition. 

Many modern autocracies function through a complex web of corporate structures, where ruling  family members exercise decisive control. Some are indeed nominally classified as sovereign wealth  funds, where an individual ruling family member can be the ultimate decision-maker.  

Given that the fundamental motivation of the present draft SI 02 and its preceding legislative and  regulatory dispositions is to curb ‘undue influence’ on UK media, we recommend strongly that  clear limits are set immediately by DCMS to eliminate ‘grey areas’ concerning the SOI definition  that could give rise to anomalous situations that undermine press freedom! 

**b) Influence **

The term ‘influence’ is subject to multiple interpretations, particularly in the context of newspaper  enterprises, where editorial independence is considered a vital pillar of a thriving democracy.  

Numerous participants, among them distinguished former editors of Britain’s major publications,  compellingly expressed their views on this subject during the HoL Debate of 22 July. 

Baroness Twycross addressed this definition comprehensively in her opening speech, in relation to  the notion of a “passive investor”: 

Noble Lords have raised questions about whether an investor with up to 15% of shares or  voting rights can really be a passive investor. The regulations include a strict requirement that  the state-owned investor must hold the investment passively. They must have no right or  abilities to appoint or fire directors or other officers, and they must have no ability to direct,  control or influence a newspaper’s policy or activities. These are continuing requirements that  must be satisfied every day the shares are held. The exceptions should be seen as a privilege  and not a right. 

Several peers expressed profound doubt that, given commercial realities, limiting to 15% or even 5%  the percentage participation held by a powerful investor had any meaningful restrictive impact on its  ability to ‘influence’ editorial policy.  

Furthermore, several highlighted that the mere presence in the corporate context of a dominant  personality can have a demonstrable self-imposed chilling effect on the journalists concerned (“what  would Rupert think?”). 

In these circumstances, as our contribution to future discussions on definitions, we propose to  distinguish ‘influence’ from two other concepts: soft power & subtle threats, all equally pernicious:

• influence: defined as any non-trivial ability of powerful actors or their proxies to alter editorial  policy, management actions, or enterprise messaging outside direct ownership ‘control’. This  includes informal leverage on shareholders, privileged executive access, and the internalisation of  such influence among staff, leading to virtually undetectable self-censorship. 

• soft power: encompasses both direct and indirect techniques of inducement such as preferential  loans, lavish hospitality, lucrative external posts, and incentives for favourable coverage. The targets  are not limited to owners or journalists, but extend to all personnel capable of impacting editorial  output. 

• subtle threats: encompass veiled physical intimidation and/or blackmail, denial of information  access, strategic use of vexatious litigation (SLAPPs), and economic pressure through regulatory or  administrative harassment. 

In reality, these different ‘methods’ of applying influence are almost always ‘deliberately border-line’  by definition, because the perpetrator strategically understands the critical importance of avoiding  ‘over-stepping’ obvious legal boundaries. 

As many peers demonstrated during the HoL Debate, detecting & then dealing with such situations  will be an extraordinarily difficult task for DCMS, Ofcom & CMA, particularly as they can only proceed  on the basis of concrete evidence of such transgressions. 

We strongly recommend that DCMS immediately spells out comprehensively how it intends to  ‘police’ undue influence, and above all what additional powers & resources it urgently requires for  itself & its agencies effectively to combat such serious democratic threats and reverse the results  of any illegal act already committed! 

**c) Press Freedom Trusts (PFTs) **

We consider that the aim of our Press Freedom Project is to strengthen British democracy by  safeguarding the freedom of our UK press. 

For this purpose we have explored the different governance models that best preserve editorial  independence. 

We have identified so far three examples of governance models which are built on the basis of trusts  or equivalent mechanisms: 

• The Economist: Established in 1928, this model combines the concept of trustees with privileged  share classes held by individuals (many former and current journalists), not corporates. The trustees  appoint the editor and maintain constitutional restrictions preventing any individual or organisation  from gaining a majority shareholding. The company’s articles of association ensure that no single  shareholder may exercise more than 20% of voting rights, with trust shares specifically designed to  safeguard editorial independence from commercial, political and proprietorial influences. 

• The Guardian: The Scott Trust, backed by a £1.24 billion endowment fund, reinvests all profits in  journalism and appoints the editor. The journalists benefit from editorial independence through  constitutional protections that prevent interference in editorial decisions, though their direct  participation in ownership is limited to one journalist director on the Trust board. This structure  operates as a limited company designed to maintain perpetual independence while lacking the  formal editorial safeguards found in other European models.

• Le Monde: This pioneering model features ownership divided between an independent  endowment fund (75%) and a consortium of journalists & other staff members (25%). The journalist  consortium benefits from a golden share in the group, with participation in the selection of editors  and a range of specific contractual rights protecting editorial independence.  

Our PFTs can help protect journalists from undue influence, align their interests with those of benign  owners, and provide a robust institutional framework for protecting editorial integrity in case of  external pressure or ownership changes. 

We strongly urge the DCMS to engage with us to explore which Press Freedom Trust governance  model or hybrid combination can be recommended to UK media enterprises & journalists! 

Annex

From the HOUSE OF LORDS DEBATE 22 JULY 2025 concerning the Statutory Instrument “The Enterprise Act 2002 (Mergers Involving Newspaper Enterprises and Foreign Powers) Regulations 2025 “, made 23 July 2025 NB: these Policy Proposals (PP) are summarised & therefore indicative. PPs 01 & 02 are already included in the draft text of Statutory Instrument N° 2 (mentioned for completeness); PPs 03, 04 & 05 should also be included.

Policy ID	Policy Title	Policy Proposal	Policy Proponent(s)	Parliamentary Quotes: Text	Parliamentary Quote: Source	Policy Implementation
01	Aggregate Foreign State Ownership Cap	Cap total foreign state investment in each UK newspaper to 15% aggregate, closing the “multiple 15% loophole”	Baroness Twycross (Minister), Baroness Stowell	Baroness Twycross: “the changes proposed by the draft SI [N° 2] would close off any risk of multiple state-owned investors acting on behalf of different states, each being able to hold up to 15%. This change would be applied retrospectively from 13 March 2024 to ensure that there is no regulatory gap.” Baroness Stowell: “although I can accept a 15% aggregate cap for state owned investment, it will require rigorous government oversight of the boundaries that passive investors must not extend, and Parliament will need to be better equipped and more active in holding Ministers to account. In my view, it was frankly unacceptable for the Government to stay silent for 11 months on the matter of the secondary regulations and on what they were doing to safeguard the Telegraph’s future ownership during that time.”	Baroness Twycross quote: Hansard , HL Deb 22 July 2025 (Enterprise Act 2002 regulations debate), 15:27:00-15:45:00 Baroness Stowell quote: Hansard , HL Deb 22 July 2025 (Enterprise Act 2002 regulations debate), 16:00:00-16:15:00	Policy Proposal included in the Draft Statutory Instrument submitted for Consultation 16 July - 16 September 2025 – “to be laid by the end of October 2025” – The Enterprise Act 2002 (Mergers Involving Newspaper Enterprises and Foreign Powers) (No. 2) Regulations 2025: “(4)After sub-paragraph (2) insert— ‘(3) Subject to sub-paragraph (4), where state owned investors acting on behalf of foreign powers of different countries or territories hold shares or voting rights in a newspaper owner, directly or indirectly, their holdings of shares or voting rights are to be treated as if they were a single holding of shares or voting rights, unless they are holdings which …’”
02	Mandatory Notification Requirements	Mandatory declaration to Secretary of State for all foreign state-owned investments exceeding 5%, linked to approval regime and ongoing oversight	Baroness Twycross (Minister), Baroness Stowell	Baroness Twycross: “we have addressed concerns around the lack of a notification requirement on state-owned investors who plan to take significant shareholdings. This second draft SI proposes a new requirement for direct investments by state-owned investors of more than 5% to be notified to the Secretary of State as a condition of the exception. If the notification is not made, or made late, the investment would not comply with the exception and would be prohibited.” Baroness Stowell: “Noble Lords may have seen, and indeed have heard already from the Minister, that the supplementary regulations that are to follow these include a new notification requirement, meaning that any state-owned investor that acquires more than 5% must notify the Secretary of State within 14 days of that acquisition to be eligible for the exemption status. In my view, as a follow-on to that, the Secretary of State should be required to notify Parliament twice yearly about any or nil such notifications, together with information about action taken by her as a result. In future, we are going to need more information. Can the Minister ensure that this additional requirement of accountability to Parliament be added to the supplementary regulations the Government are now consulting on?”	Baroness Twycross quote: Hansard , HL Deb 22 July 2025 (Enterprise Act 2002 regulations debate), 15:27:00-15:45:00 Baroness Stowell quote: Hansard, HL Deb 22 July 2025 (Enterprise Act 2002 regulations debate), 16:00:00-16:15:00	Policy Proposal included in the Draft Statutory Instrument submitted for Consultation 16 July - 16 September 2025 – “to be laid by the end of October 2025” – The Enterprise Act 2002 (Mergers Involving Newspaper Enterprises and Foreign Powers) (No. 2) Regulations 2025 : (1C) This sub-paragraph applies where— (a) the state owned investor holds, directly, more than 5% but no more than 15% of the shares or voting rights in the newspaper owner, and (b) gives the Secretary of State a qualifying notification before the end of the period of 14 days beginning with the acquisition date. (1D) A qualifying notification is a notification that the state owned investor has acquired, or proposes to acquire shares or voting rights in the newspaper owner, with the result that the state owned investor holds, or will hold, directly, more than 5% of the shares or voting rights in the newspaper owner. (1E) The acquisition date is the date on which the state owned investor acquires shares or voting rights in the newspaper owner, with the result that the state owned investor holds, directly, more than 5% of the shares or voting rights in the newspaper owner.”.

Policy ID	Policy Title	Policy Proposal	Policy Proponent(s)	Parliamentary Quotes: Text	Parliamentary Quote: Source	Policy Implementation
03	Parliamentary Oversight & Transparency	Secretary of State required to publish biannual (or more frequent) reports to Parliament on all notifications, investigations, and enforcement actions under the foreign ownership regime	Baroness Stowell, Baroness Twycross (Minister)	Baroness Stowell: “I asked her [the Minister] a question about those new notification requirements in the draft regulations yet to be made, and whether the Government would consider my recommendation that the Secretary of State be required to notify Parliament on a twice-yearly basis if she receives any such notifications, and about the actions that she has taken as a result. Is she able to give me a response to that?” The Minister: “I have an answer for the noble Baroness. We think that it is a reasonable suggestion. We need to work out how we can do that. There was a suggestion, for example, that it might require primary legislation. Obviously, that feels a little bit heavy-handed in terms of where we would want to get to. If the noble Baroness is content, I will come back to that. We think that it is a good point and it is worth doing, but I am not able to commit until we have clearer legal advice on how we could achieve that.”	Baroness Stowell quote: Hansard , HL Deb 22 July 2025 (Enterprise Act 2002 regulations debate), 16:00:00-16:15:00 Baroness Twycross response: Hansard , HL Deb 22 July 2025 (Enterprise Act 2002 regulations debate), 17:30:00-17:45:00	To Be Confirmed
04	Rigorous Scrutiny of Major Transactions	Strengthening of required Competition and Markets Authority (CMA) scrutiny of proposed sales/acquisitions, with specific attention to editorial independence and beneficial ownership, before completion of major deals	Baroness Stowell, Lord Alton, Lord Lansley	Baroness Stowell: “It is not for Parliament to dictate how proprietors should discharge their responsibility, but in a media world that includes the presence of state-owned investors, clarity and some transparency about what proprietors are doing to protect their newspapers’ independence and editorial freedom becomes important. This is particularly so where proprietors are new to the newspaper industry or are private equity funds. Can the Minister tell us, therefore, what such demands the Government will make of the new Telegraph owners if and when that transaction is completed? Can she confirm that the Telegraph deal, once finalised, will be subject to detailed scrutiny by the CMA before it is completed?”	Baroness Stowell quote: Hansard , HL Deb 22 July 2025 (Enterprise Act 2002 regulations debate), 16:00:00-16:15:00 Multiple other speakers throughout: Hansard , HL Deb 22 July 2025 (Enterprise Act 2002 regulations debate), various timestamps	To Be Confirmed

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Confidential Annex – PFP Reply – DCMS Consultation – HoL 22July25 Debate – Selected Policy Proposals Table – 16Sep25 Final.xlsx

Annex – PFP Reply – DCMS Consultation – SELECTED POLICY PROPOSALS for inclusion in Statutory Instrument N° 2 – 16Sep25 Final
from the HOUSE OF LORDS DEBATE 22 JULY 2025 concerning the Statutory Instrument “The Enterprise Act 2002 (Mergers Involving Newspaper Enterprises and Foreign Powers) Regulations 2025 “, made 23 July 2025 NB: these Policy Proposals (PP) are summarised & therefore indicative. PPs 01 & 02 are already included in the draft text of Statutory Instrument N° 2 (mentioned for completeness); PPs 03, 04 & 05 should also be included.

Policy ID	Policy Title	Policy Proposal	Policy Proponent(s)	Parliamentary Quotes: Text	Parliamentary Quote: Source	Policy Implementation
05	Broader Plurality and Tech Platform Regulation	Extension of public interest merger regime to cover online news aggregators and major digital platforms, not just traditional print, by including these entities within the definition of ‘newspaper’	Lord Lansley	Lord Lansley: “However, I put it to the Government—I have discussed it with Ministers; I know that it is for further consideration in future—that because the definition of ‘newspaper’ includes ‘news-related material which is subject to editorial control’ and ‘editorial control’, among other criteria, includes that it should be first published by that publication, it excludes online news aggregators. I will give noble Lords a very simple example. I am sure that many of us use Google News or Apple News—I use the latter—which are news aggregators. I do not think that we should, for a minute, accept that they do not exercise control of our media. They have editorial teams to determine the most important stories that we should see each day. As many here will know, setting the agenda is an essential part of a political process. If we have news aggregators setting the agenda online for millions of people, for whom that source is one of the most trusted online sources, the control of that online news aggregator is an extremely important issue. News aggregators are currently excluded from our public interest media merger regime because they do not first publish the material that they put online and present to their millions of subscribers. I put it to the Government—I hope that they will take this on board—that the definition should be amended to identify that kind of online news aggregator and include it under the public interest media merger regime.”	Lord Lansley quote: Hansard , HL Deb 22 July 2025 (Enterprise Act 2002 regulations debate), 17:00:00-17:15:00	To Be Confirmed