Research and analysis

Stakeholder Forum Papers: Television - Carriage in future of TV distribution

Published 23 June 2026

Introduction

This paper explores how broadcasters in the UK can access the various IPTV platforms, recognising the complexity within the IPTV market and contrasts this with the simpler DTT platform. We consider the technical aspects and the broad commercial terms across various types of IPTV platform.  We then consider the potential impact on the viewer and how industry and government could work together to resolve any challenges and ensure that UK viewers can continue to easily view content, including the existing live broadcast channels. 

Context

IPTV brings with it many benefits for the viewer, including the availability of a significantly greater amount of UK content—which no longer must be tied to the linear schedule—alongside increased functionality, whether voice search, personalised recommendations, enhanced accessibility features and so on. It is clear that UK viewers still enjoy watching live television channels at scale, and that PSB channels continue to attract a very significant share of this live viewing. There is broad agreement, too, that traditional grid EPGs are valued by many as easy-to-use and familiar routes to live channels.

In the IPTV context the value of live channels and straightforward access to channels has not translated to a single uniform approach to the design of TV user interfaces or content services. Platforms are free to design their interfaces to differentiate themselves from others in the market, with different weighting placed by different players in the market on the presentation of live versus other types of content offer, and alternative routes to live linear (e.g. ‘now / next’ rails and continue watching features) offered alongside more traditional grid EPGs. Content services may choose to include live linear services within their apps or not.

There is consensus within the working group that, in any possible transition to IPTV, viewers should be able to continue to benefit from straightforward access to live linear IP channels, through a familiar EPG experience. This would replicate the successful approach to digital switchover, where industry collaboration and alignment with government ensured continuity of services. However, IPTV has a very different commercial model. DTT is relatively straightforward: broadcasters generate advertising revenues through unmediated direct access to viewers while TV manufacturers generate revenue from TV hardware sales and are unable to monetise the content displayed on the TV. In contrast, the IPTV commercial model is much more complex. 

The emergence of the TV operating system (TVOS) in IPTV has led to an economic model whereby broadcasters must negotiate with TVOS platform owners to determine whether and how their linear and on-demand services appear on the connected TV which can often mean sharing advertising inventory or revenue with the TVOS platform owner. Equally, platform operators must negotiate with broadcasters for supply of broadcaster content and the terms on which that content is supplied to the platform, and the form in which it is provided. TechUK note that for some, manufacturing TVs is no longer economically sustainable from a hardware only perspective, and therefore manufacturers have chosen to develop or license additional service propositions (for instance advertising) in order to remain in business. 

As the TV ecosystem has evolved considerably in the last twenty years, the public service media regulatory framework also needed to evolve to reflect the market. In May 2024, the Media Act received Royal Assent and became law. This is the biggest change to the public service media framework in two decades. Amongst a range of measures, the Act will regulate IPTV carriage agreements for the first time to secure prominence for PSB content on IPTV platforms.

The Act does this by introducing new requirements on designated PSB services (designated internet programme services or “DIPS”) and on designated IPTV platforms and devices (regulated television selection services or “RTSS”) that are provided in connection with smart TVs and streaming devices. Within these obligations, DIPS will be subject to  a must-offer obligation, whilst RTSSs will be subject to a must-carry obligation as well as an obligation to provide appropriate prominence to DIPS (and content within them) on their service. Under Section 362AF of the Media Act 2024 it sets out that a “regulated television selection service” must be designated by the Secretary of State via regulations (following advice from Ofcom), and must be used by a “significant number” of viewers. This is to ensure regulation is targeted and proportionate^{[footnote 1]}. DCMS officials/Ministers are currently considering Ofcom’s advice with a view to bringing forward the necessary secondary legislation in due course. Ofcom is responsible for designating the DIPS that will fall in scope of the new must offer/carry regime, except for BBC DIPS which are automatically designated.  Ofcom is also responsible for defining what appropriate prominence for DIPS means in practice.

Disputes between DIPS providers and RTSS providers as to the terms of carriage can be determined by Ofcom which must ensure that the terms of such agreements do not have an adverse effect on the delivery of the relevant PSB remit nor disproportionately restrict how the RTSS may make innovations in the way users select and access services. These obligations seek to ensure that BBC iPlayer and any other public service broadcaster internet programme services designated by Ofcom, (including public service content from within the internet programme service and not just the relevant application), are available, prominent, and easily accessible by audiences. The changes brought forward by the Media Act will be particularly important to consider when assessing policy challenges within a future transition of TV distribution. How these measures are implemented by Ofcom will also be instrumental in ensuring any future regime meets audience expectations on how they currently, and continue to, receive and access public service content in the years to come. 

It is also worth noting that currently only certain EPGs in the UK are regulated. These are EPGs that were being provided by a provider that held a Television Licensable Content Service (TLCS) or Digital Television Additional Service (DTAS) licence for it immediately before Brexit. These include EPGs provided by Sky, Everyone TV, Virgin Media and YouView TV at the time of Brexit. Newer EPGs provided by these providers and EPGs provided by other TV platforms are not currently regulated. Other EPGs can be regulated if the provider is designated by the Secretary of State. Given that many EPGs fall outside of regulation currently, this may impact the workability of a ‘must offer’ requirement. 

It is currently too early to determine how the policy changes will play out. Although ‘carriage’ of the linear PSB IP channels on a stand-alone basis does not fall under the prominence regime within the Media Act, Sky, Virgin, BT/EE and all the Freely partners (representing 15 consumer brands) have already reached agreement with all PSBs for carriage of their linear PSB channels within their IPTV platforms to ensure that viewers have a consistent experience of live TV channels, and one that replicates the familiar EPG. They have extended their familiar broadcast EPGs into IPTV ensuring that viewers can easily surface these channels.  

However some PSBs and some platform operators have found it challenging to agree terms - both for linear IP specifically, and in a few cases also for the terms of inclusion of content services more broadly. The DCMS understands the concerns that have been previously raised by techUK members around access to PSB IP Linear Services, and recognise the importance for PSBs and TV manufacturers being able to reach appropriate deals which work for UK audiences.

These challenges have arisen only in the ‘OTT-only’ space, which overall represents around 20 to 25% of the total market^{[footnote 2]}. As some providers of OTT-only platforms also offer Freely for some of their models or have agreed other terms for linear supply for their OTT-only models, it is not necessarily the entire segment that is impacted, so currently 20 to 25% represents the uppermost boundary.^{[footnote 3]}

The TV Sector Working Group recognises the importance of ‘carriage’ of the linear PSB services across all IPTV platforms, ensuring continued universal access for all UK audiences to this public service media content in a form in which they are accustomed. This group recognises that this current issue needs to be resolved.

Section 1: Carriage on the DTT platform

DTT has incrementally evolved over the two decades since its inception, but carriage is relatively simple. Access to the free-to-air (FTA) DTT platform is naturally constrained by the available (regulated) spectrum, a concept that no longer exists in IP where bandwidth is not regulated, nor a constraint. A pre-requisite to being on the DTT platform was thus securing access to sufficient regulated spectrum in which to operate.  DMOL (DTT Multiplex Operators Ltd) was created, at the behest of the government, to provide technical management and co-ordination of the DTT platform, including the electronic programme guide and channel numbering (LCN) and the DTG was created to deliver the technical specification and provide the testing and conformance regime. Originally DMOL was a separate company to Freeview and its duties included ensuring the DVB compliance of the DTT platform and managing the CSI (Central Service Information) system – i.e. the metadata system that fed the EPGs on digital TVs.

This meant that there was a singular centrally coordinated eco-system that delivered DTT to audiences in a similar consistent manner based on LCNs and similar EPGs. Broadcasters had to obtain and comply to the requisite Ofcom licences. Compliance with the DTG D-Book (by both broadcasters and devices) ensured interoperability and led to a largely common experience for audiences. 

Subsequently the MHEG-IC (MHEG interaction channel), and its successor HbbTV, allowed applications to be completely downloaded over the air which combined with internet-connected Freeview HD receivers allowed consumers to view channels delivered over IP, some of which fell outside the previously fully regulated TV channel paradigm. The commercial arrangements for delivering these services were separate from the regular Freeview TV service.

Carriage and distribution of linear PSB channels on DTT is relatively straightforward. In return for fulfilling their public service obligations, the PSBs are gifted capacity on DTT multiplexes for their designated PSB channels, with the three PSB multiplexes providing near universal coverage, broadcasting to c 98.5% of the UK population. The remaining three fully-commercial national multiplexes broadcast to c 90% of the UK population.^{[footnote 4]} Arqiva operates the broadcast infrastructure on which all multiplexes operate. 

The UK’s PSB system has a high degree of locality and regionality, serving viewers in different nations and regions with targeted programmes and advertising relevant to them. These are either regional versions of network output (BBC One/Two), regional services that form a UK network (ITV1/STV), or channels targeted primarily at individual nations (S4C, BBC Alba/BBC Scotland). Outside this PSB ecosystem there are local channels that operate under local licences.

Historically regionality has been delivered as an intrinsic part of distribution chains – DTT providing tailored multiplexes for different regions with appropriate EPGs and DSAT/DCAB having similar mechanisms to replicate, including by reference to billing information/postcode entry on setup.

The arrangements for carriage on DTT are very simple to outline: channels reach commercial terms with the multiplex operator (licensed by Ofcom), while the multiplex operator reaches commercial terms with Arqiva, the company that operates the broadcast infrastructure on which the multiplexes operate. Of the current six national multiplexes two are operated by the BBC, two by Arqiva, one by SDN (ITV) and one by ITV/C4.^{[footnote 5]} Everyone TV (ETV) provides some DTT-wide services to enable coordination between multiplex operators to the benefit of audiences. Two key areas are in relation to EPGs and LCNs. ETV manages the central service information (CSI) infrastructure which facilitates coordination between multiplexes that enables DTT-wide EPGs to be populated. ETV also centrally allocates LCNs to prevent LCN conflicts and consumer receiver equipment errors. In line with Ofcom’s EPG Code, LCNs are allocated according to a fair, reasonable and non-discriminatory method which has been publicly consulted on.^{[footnote 6]}

DTT allows channels to broadcast a single stream of information direct to millions of viewers, with little or no disintermediation by TV manufacturers (whose only role is to build TVs to Freeview and D-book standards and to display EPG information in the precise form it is broadcast by ETV, in line with Ofcom EPG prominence rules) or Arqiva (who simply operate the distribution infrastructure). Commercial PSBs have direct access to their audiences, monetise viewing directly and retain all revenue in full. Therefore, in DTT, neither the TV manufacturer nor the underlying TVOS platform owner have any responsibility for which channels are available and they do not monetise the content the TV screen displays. 

After 2010 TV platforms began to operate in a hybrid mode. “Traditional TV” via the EPG was thus only one element of the wider consumer offering. The wider TV user experience has been developed by the Smart TV operators to cater for the new viewing capabilities. These have been a mix of premium subscription services (e.g. DAZN) and free ad-funded services (e.g. FAST). The Media Act subsequently addresses the new hybrid world guaranteeing appropriate prominence to PSB internet programme services. with the remainder of the platform is still owned by the Smart TV manufacturers and they continue to develop new content services to audiences alongside their new business models.

Viewers nevertheless have a consistent linear broadcast EPG experience, with channels having the same LCN across all Freeview TVs—although we note that the EPG layout and remote controls can differ between each TV manufacturer, as they innovate new capabilities—and are served the correct regional broadcasts for their area. While the satellite and cable platforms (with a far greater number of channels) are built on different technology and have different channel numbers to DTT, their EPGs are built on similar principles of ease of use and accessibility for viewers, and with the five main PSB channels in positions one to five as required by Ofcom’s EPG code.

Section 2: IPTV

In this section we initially provide a general overview of carriage on IPTV platforms and then cover the different types of carriage agreements that broadcasters may have for access. Within this we include separate input from Sky, Everyone TV and Tech UK, as well as from the other members in the TV Sector Working Group. We then consider emerging challenges for broadcasters and platforms. 

General overview

With IPTV delivery the UK has moved away from one-to-many, unmediated distribution and towards a world in which there can be more personalised, 1 to 1 distribution over the internet, with each stream (both linear and on-demand) delivered as the viewer demands it—viewing is spread out over days,  weeks and devices. This has brought many benefits to the viewer including a greater range of content and functionality.

The distribution of linear IP channels can be straightforward in some circumstances - it is not inherently complex, although there are challenges in managing delivery at scale whilst maintaining a reliable quality and resilient service for audiences. Most obviously, broadcasters’ live channels and VOD content can be made  available over the open internet. Broadcasters can secure distribution capacity from Content Delivery Networks (CDNs) or may choose to build their own (e.g. BBC Internet Distribution Infrastructure “BIDI”), which deliver the channels into ISP core networks, from where the ISPs deliver the channels to their customers (governed by net neutrality principles). Most TV devices that connect to the open internet are therefore theoretically capable of receiving broadcasters’ channels and streaming services, as long as they support the necessary standards and media formats required to allow applications to run and AV content to be reproduced correctly and securely. In these circumstances, the broadcasters have direct access to their audiences, can monetise viewing directly and retain all revenue in full (as with DTT).

TV sets are not the only consideration when making technical choices. Broadcasters need to deliver their content and services to a range of IP devices (e.g. mobiles, tablets, smart speakers, PCs). All of these devices need to be considered in the round when making technical choices about content and service delivery (including but not limited to linear).

The development of free-to-air IPTV  has led to the rise of online TV platform operators which develop the User Interfaces (UIs) of TVs. These players (which include Amazon, Samsung, LG, Google etc) can shape the choices of viewers through the positioning of content and services. TechUK note that manufacturers will provide interfaces that meet the needs of their customers, which can include highly popular global services sitting directly alongside highly valued local content (which, if PSB content, would conform to the prominence provisions of the Communications Act and Media Act). Devices with DTT tuners still provide free broadcast access in the traditional way.

Unlike the open internet or DTT,  the TV platforms and IP content providers (whether broadcasters, FAST channels, SVOD services, video-sharing platforms, Spotify and so on) need to negotiate with each other to determine whether, how and on what commercial terms services appear on the TV platforms.

As distribution over IP can be at times more complex than DTT, so can the commercial models. Broadcasters that wish to obtain carriage on an IPTV platform need to reach a commercial agreement with each platform (either a closed pay-TV platform such as Sky or Virgin, or with the connected TV manufacturer/TVOS platform). While the PSBs will be afforded appropriate prominence on the designated RTSS, each would need to reach an agreement with the platforms on any requirement above the regulatory code that will be set out by Ofcom. Ofcom is expected to consult on its new prominence code in the autumn, and ultimately the code may or may not include features such as the application to be listed in the initial offerings, on the home screen or initial applications rail, promotional rail or presented to the user during the initial out-of-the-box set-up phase. Nevertheless, prominence on each platform is—over and above what regulation can secure—a commercial commodity to be bought and sold. Some IP platforms, such as Sky’s provide PSBs with significant levels of prominence already despite the fact that they are not required to. Broadcasters, including PSB channels are no longer guaranteed the direct and unmediated access to audiences delivered by DTT, potentially eroding one of the PSB benefits.  

In all approaches to delivering linear IP services, there is still an inherent degree of complexity in any commercial agreement between a ‘broadcaster’ and a ‘platform’. These need to be resolved but are outside the scope of this paper. For instance, are the services delivered to viewers by the broadcaster or by the platform? Who is responsible for acquiring the necessary CDN capacity? What technology will be used - for instance, are the streams to be delivered via unicast (a single stream delivered in full along the full length of the network to each individual viewer request) or multicast (a single stream pushed deeper into the network before only in-home delivery on a 1-1 basis)? 

In reality, relatively few platforms are as basic as this (and none are as basic as the older DTT-only experience), with a range of additional functionality often now coming as standard. This requires other topics to be subject to commercial agreement. For instance, is viewer sign-in required to view channels? If so, how is that managed (e.g. single sign-in when unboxing the device or individual app/channel sign-in at point of use) and by who (broadcaster, platform or both)? What tracking of audience behaviour is carried out, and by who? What metadata must be supplied (minimum necessary for functionality), would ideally be supplied (enhance functionality), and what purposes can the metadata be used for beyond this (if any)? Which TV functions need to be supported, for instance ‘pause and rewind’ or ‘watch from beginning’? For ad-supported channels, who sells the advertising and who retains the revenue? Does the approach to distribution support addressable linear advertising, underpinned by relevant data? The broadcasters gain access to the platform, may have access to data, but they lose the direct relationship with the viewer, potentially revenue and potentially prominence.

None of these complexities are inherently insurmountable but IP distribution is a different proposition to DTT, where the broadcast of a single stream was sufficient to allow reception in individual homes absent such agreements.

Similarly, the provision of traditional grid EPGs works differently in an IP world. As simple lists of channels, there is no inherent reason that an IP-delivered grid EPG need be more complex than or look radically different to broadcast EPGs. There may be a different viewer experience between an EPG which gives access to integrated IP channels to one where there is a deep-link in the EPG going to a VOD app. An EPG which is akin to the traditional Grid EPG which gives access to integrated channels and retains traditional ‘up/down’ functionality via the remote is likely to give a significantly better viewing experience. This in turn is likely to relate to the terms of the broader agreements in place between content providers and platforms for the inclusion of content services outlined above.

IP-delivered EPGs are not regulated, and potentially UK broadcasters’ channels and content could feature next to non-Ofcom licensed channels/content. The DCMS is aware that, as viewing over the internet increases, this gives rise to certain regulatory considerations, including the question as to whether to designate additional electronic programme guides (EPGs) for regulation to make sure there are adequate protections for audiences, appropriate accessibility requirements and rules around prominence for PSBs on regulated EPGs. The DCMS will continue to keep stakeholders informed as work on this progresses.

Broadcasters’ approaches to offering platforms access to their linear IP channels through a structured EPG

From a broadcaster perspective, it is vital that the way in which they supply their IP linear channels and VOD services via third parties does not undermine their ability to meet PSB remits, for instance because the terms of such supply don’t deliver an appropriate and accessible experience for audiences, or value for money or require some kind of sharing of revenue or levy fees for access. This means meeting key principles including:

• ensuring that the presentation and experience of accessing their content meets viewers’ expectations, including maintaining a consistent viewer experience across platforms. As with broadcast, this does not mean they must be identical, but they must fit within the existing guardrails that enable that familiarity 
• ensuring a resilient and high-quality service
• ensuring that the presentation of PSB services meets PSB prominence requirements as set out in the Communications Act, Ofcom EPG code, the Media Act and the BBC Charter and Agreement and related Ofcom requirements
• ensuring that broadcasters are able to secure fair value for their content, including ensuring that commercial broadcasters are able to appropriately monetise viewing to their channels and VOD content, including through linear addressable advertising 
• ensuring that editorial control is not compromised
• delivering innovation that benefits audiences (e.g. accessibility services, live restart)
• delivering appropriate levels of data about who is viewing and what they are viewing, to facilitate both the ad products expected by advertisers (on commercial channels) and the personalised TV experience expected by audiences, alongside insight to guide commissioning decisions^{[footnote 7]}

Broadcasters note that some of these TV manufacturers/TVOS platforms are global, and while decisions as to which content they carry may vary by country the user interface and many of the features (such as voice control) they offer may be decided at a global level. If platforms are able to dictate the terms of ‘carriage’ the TV platform could also impact the commercial model for linear distribution. For instance by seeking revenue shares from content providers on their platform, demanding (and/or withholding) data, or seeking to integrate such data into wider online businesses without any recognition of value (or payment). 

Platforms are also often in direct competition for advertising revenue with the content providers on their platforms. If the commercial deal means that broadcasters must provide data on their audiences to platforms (or allowing platforms to use AI or in-device tools such as Automatic Content Recognition (ACR) to monitor viewing behaviour outside of contracts) these platforms can use that data to strengthen their own ad propositions which they can then deploy in direct competition with the broadcasters. 

For those unfamiliar with ACR, the technology takes frequent digital “snapshots” (every few hundred milliseconds) of the TV screen and creates unique fingerprints, which it matches against a central database to determine exactly what the household is watching. It continually identifies what is being displayed on the screen—whether it’s from live broadcast, streaming apps, or external devices like HDMI inputs. The system records not just the name of the programme or ad, but also how long it was watched, whether the viewer interacted with it, switched channels, or used another app or device. The data is used to build a detailed viewing profile, enabling the manufacturer to deliver personalised content recommendations and highly targeted advertising on the TV and possibly other devices linked to the household or accounts. Information collected by ACR may be shared with advertisers, streaming partners, and data brokers for audience measurement and ad-targeting across the TV ecosystem. 

TechUK note that ACR is a completely legitimate innovative technology developed and used by manufacturers to improve and enhance the users viewing experience (other members note it also delivers revenue to the manufacturer/platform). TechUK note that audiences are currently confused by the myriad and complexity of disparate content applications. ACR is used to help audiences discover content that is relevant to their needs, whether that is from local broadcasters, SVOD or FAST channels. A good implementation of ACR should fully explain the data collection process to the consumer in the platform’s terms and conditions and provide consumers with clear instructions on how to opt out if they so desire. ACR can be disabled or enabled by consumers independently of any other feature, although they may then lose many of the smart TV features.

Broadcasters today offer three broad options to IPTV platforms for access to their linear IP channels:

i. Individual agreements with platforms that provide viewers a unified, familiar linear experience (such as on the pay-TV platforms of Sky and Virgin) ii. Commercial agreement through Everyone TV for Freely iii. Deep-links from a third-party UI directly into the linear channels or VOD content hosted on the broadcaster’s player. This is normally the approach on non-Freely connected TVs (notably not Sky Glass however)

Clearly no arrangement is perfect - each of these approaches comes with pluses and minuses for all parties, but taken together should provide sufficient market flexibility for all stakeholders. The remainder of this section will consider each model in turn and then highlight some challenges for broadcasters.

i. Carriage through individual platform licences

These agreements tend to be part of a broader agreement covering all aspects of that broadcasters’ integration with the platform including the distribution as offered by Virgin and Sky. These larger pay-TV platforms work with the broadcasters to develop tailored and mutually beneficial arrangements and provide a unified IP linear experience familiar to viewers. They potentially allow the platform operator more control and customisation, so as to implement platform-specific innovations that benefit viewers and/or drive increased revenues. Although they may require more effort and investment from broadcasters on a technical level they do guarantee that broadcasters are compensated for any commercial impact from that, and that viewers can access content in innovative, simple and easy ways i.e. linear IP content launching directly from the EPG. However, they may also impede broadcasters from implementing their own innovations that benefit viewers, noting that broadcasters were the first to offer text services, red button activity and so on

While these types of agreements are currently just with Sky, Virgin Media and BT/EE, we understand that some broadcasters are willing to explore similar agreements with other major TV platforms.

The following paragraphs have been supplied by Sky, with regards to its satellite and IP platforms

Sky ensures the content on all our platforms (Sky Glass, Sky Stream, Sky Q, Sky+) meets our customer expectations, with a wide range of providers as integrated into the platform as possible. Ease of use for customers on all of our platforms is therefore an extremely important component in all our partnerships. We seek to reduce the amount of friction viewers face, and therefore time it takes, to find the content they are looking for. 

There are two key aspects that enable ease of discovery for audiences:

• Seamless access to linear (without leaving the Sky environment): This principle is core to both our satellite platforms and IP platforms as it enables fast access to live TV, a consistent experience and easy navigation. It is vital that platforms like Sky are able to offer a consistent, frictionless, customer centric linear experience. The benefits of linear TV via broadcast must be maintained (e.g. access without registration, seamless up and down selection between channels, instant load times) as they are central to this experience.
  • Sky’s IPTV products, Sky Glass and Sky Stream are built to ensure that easy access to live viewing, particularly of PSB services, remains core to the experience. As such, they provide a prominent ‘Grid EPG’ which functions in the same manner as both Sky’s satellite platforms and via DTT. 
• VOD delivered in the native Sky environment: Enabling a consistent experience without the additional friction of logging in to different services and additional load times, so as to keep the user experience as frictionless as possible. This is especially important for older and more vulnerable customers who value the simpler service that Sky services provide.

Sky has a range of commercial arrangements in place, ensuring all Sky customers are able to access their favourite services on Sky platforms in the way that best suits them:

• Traditional pay carriage deals: These are arrangements with commercial broadcasters (such as UKTV, Hearst and Disney), where linear pay TV channels and associated Video-on-Demand channels are made available as part of Sky’s TV packs. 
• Bundle deals with Streaming Video on Demand providers (SVODs): Some SVOD providers are included in the price of Sky TV packs. For example, Netflix and Discovery+ are included within a number of Sky TV packs.
• Regulated access via satellite on Sky+ and Sky Q for PSBs, free-to-air channels and services that aren’t retailed by Sky: access to Sky’s satellite platform is regulated.  It is required to offer an EPG listing on FRND terms to broadcasters meeting a set of minimum criteria set out in Sky’s Listing Methodology. Furthermore, as Sky+/Sky Q platforms are primarily dependent on satellite delivery for linear channels, they benefit from the regulatory backstop of regulated access to the commercial Public Service channels under Must Offer rules in the Communications Act 2003. ‘Must offer’ in relation to the BBC’s channels is delivered by a broader set of obligations in the Charter and Framework Agreement, backed by Ofcom’s Distribution Requirements. This regulation helps ensure guaranteed access to PSB content for viewers.
• Commercial arrangements with PSBs: As the current ‘Must Offer’ regulation only applies to the availability of linear channels via satellite and Sky’s services now also incorporate IP-delivery (e.g. VOD on Sky+/Sky Q/Sky Go, linear channels via IP on Sky Glass/Stream/Go and PSB apps on Sky Q/Glass/Stream), Sky also has broader commercial relationships with the PSBs. These deals are bespoke to each PSB but focus on delivering mutually beneficial partnerships that make Sky a great platform to showcase PSB brands and content, putting the customer at the heart.  
  • Although Sky Glass and Sky Stream EPGs are not regulated by Ofcom, and therefore not subject to the requirements of the EPG code, Sky has made a conscious choice to give the PSBs the same level of prominence that they would have on  regulated platforms – e.g. on satellite (and on DTT) – i.e. BBC 1 at slot 1, ITV at slot 3 etc. This is then combined with public service content receiving prominence on Sky Glass and Sky Stream’s various content rails throughout our UI.
• Standalone Apps: There are a number of apps available on Sky Q/Glass/Stream on a standalone basis (for example Amazon Prime Video, Apple TV+ and YouTube). These commercial arrangements reflect the nature of the relationship.

The commercial arrangements and value exchange between Sky and the relevant partner varies depending on the type of content arrangement.

A number of our partners above deliver apps. There is inherent incremental friction in this experience (e.g. time taken to log-in, load times of apps), therefore as a platform we work closely with app providers to mimic the native experience as closely as possible. For example, partners integrate their metadata so that apps can be included in search and automated rails, they provide viewing data to enable customers to see app content in our ‘continue watching’ rail and we constantly work with app partners to reduce friction and enhance aggregation features.  

The ability for all Sky platforms to carry integrated linear streams is essential to ensuring our service meets our audience expectations but also contributes to the government’s objective of not leaving audiences behind in the transition to IP, whilst also maintaining PSB content at the heart of the viewing experience, no matter how viewing habits evolve over time. As we look forward to the future of TV distribution, ensuring that viewers have continued, and frictionless, access to linear PSB content over IP will be vital in making sure no viewer is left behind when a transition comes.

ii. Carriage through commercial agreement with Everyone TV via Freely 

The following paragraphs have been supplied by Everyone TV

Subject to commercial agreements, onboarding onto Freely^{[footnote 8]} for OEMs and onboarding onto the Freely service for Content Providers (CPs) is designed to be both robust and repeatable. It has been tested in this: to date across ~15 separate CPs have been onboarded and 15 OEMs and TVOSs.^{[footnote 9]}

Freely is built on the latest Hybrid Broadcast/ Broadband (HbbTV) international standards that are incorporated into many new TV models (since 2024). This ‘write once & deploy many times’ approach means that content providers’ streams and apps can be developed and tested once and then deployed across multiple OEMs and TV OSs with little if any additional effort. This ensures a consistent quality for all audiences irrespective of the device they are using (akin to the DTT model).

For Content Providers:

• For linear channel distribution, two core items are required: IP streams, and related schedule/ data formatted according to our Freely specifications
• The streams employ the international DVB-DASH standard, which is a commonly used standard. For other optional features our specification requirements are designed to provide CPs with flexibility of implementation:
  • CPs can bring their own analytics plug-ins and media selectors (the latter being used to switch between CDNs for service resilience if desired)
  • Dynamic Ad Insertion (DAI) and fallback streams are also supported and will be tested by Everyone TV (ETV) if provided by the CP.
• If a CP has VOD content ETV asks for an HbbTV app to be provided that can support playback of the CP’s catalogue. ETV works with them to ensure that their app works in the Freely environment (e.g. links and video playback function correctly). The advantage of using the open HbbTV standard is apps are built once and deployed across multiple TVOSs/OEMs, which is especially advantageous for smaller content providers.
• Streams and apps can be created by the CP, or the CP can approach a streaming / app development partner to do this for them. Both models are currently in use. The costs are borne by the CP.
• ETV provides assistance with both stream and app testing, and goes through a formal onboarding process to ensure that reliability and quality gates are met before new channels and apps go live. [REDACTED]

For OEMs/TVOSs:

• Support for Freely requires the OEM or TVOS provider to implement the Freely specifications, including the relevant DVB stream and HbbTV application standards. 
• ETV works closely with OEM and TVOS partners to assist with their initial implementation, including the provision of technical assistance, and of test applications and materials. [REDACTED]
• As the implementation approaches completion, the ETV testing teams work with OEM and TVOS providers to work through conformance testing, which involves running comprehensive tests against the Freely applications and stream playback, but also extended testing of key content partner applications. 
• ETV also offer OEM and TVOS partners the opportunity to co-locate in the ETV test lab in order to facilitate technical issue resolution.
• In order to assure ongoing conformance with the Freely specifications and a good viewer experience, each new Freely release is tested on a wide range of representative devices and TVOSs, with any defects logged and raised back to OEM and OS partners if required.

The IP TV platform [REDACTED] Freely provides the TV device market with a ready-made standard and a common user experience, comparable to the Freeview experience, should manufacturers wish to adopt it.

The commercial model in the case of Content Providers (CPs) on Freely,^{[footnote 10]} an IP service deployed on Smart TVs and, later in 2025, connected devices that deliver linear and VOD content principally from FTA providers including all PSBs is described below.

The reasons CPs give for partnering with the Freely service are multiple but the main, recurring ones are: reduced cost to deploy across multiple platforms that usually have bespoke technical requirements; and still being able to monetise apps and linear content streams as they care to.

Whilst the Freely EPG is not currently regulated by Ofcom, maintaining the same quality standards as Freeview and Freesat remains aligned to ETV’s mission. Hence to ensure and maintain viewer access to high-quality TV programming, any linear channels that contract directly with, and appears in, the Freely EPG must be appropriately licensed, e.g. hold an Ofcom Licence. To ensure fair and open treatment our Logical Channel Numbering (LCN) Policy is publicly available.^{[footnote 11]}

Content providers contract directly with Everyone TV to be on the Freely service; contact with the OS is usually not required.

iii) Carriage via Connected TVs (non-Freely)

The most common approach for content providers to get onto a Smart TV or streaming device (e.g. Roku Streaming Stick) requires an application to be written that runs on the end device. Content can then be accessed via deep-links from that third-party UI directly into the linear channels or VOD content hosted on the CP’s player. Some techUK members may argue that this is not as good as a user experience than the previous two options. The content provider must conform to the TVOS’ chosen technical standards, which vary by each platform. The content provider and device manufacturer would need to reach a commercial agreement, which may or may not include some aspect of revenue sharing such as a share of advertising revenue/inventory. The TVOS economic model increasingly includes raising revenue (revenue sharing) from those third-party content providers on its platform, due to the decreasing margins on old hardware-only business models, although the majority of revenues still remain with the content provider.

The following paragraphs have been supplied by TechUK

TechUK only has full knowledge of its members own devices and platforms, which do not cover the whole range available. This section is therefore primarily confined to major Smart TV manufacturers, USB Stick devices and providers of third-party operating systems that are implemented within Smart TVs.

Application Environments

The IP content world is currently dominated by the “application” environment paradigm. The most common approach for broadcasters to get onto a Smart TV and USB Stick end device (e.g. Roku Streaming Stick) requires an application to be written that runs on the end device (i.e. authored to the Application Programming Interface (API) of that device). The application will manage the entire content offering, including managing the metadata and presenting the consumer with the catalogue of content on offer within the application. The application will also manage the streaming of the chosen content to the user. 

The content provider will generally author the application and submit it to the device owner for their approval and incorporation into the platform’s applications store. This will usually be subject to a standard commercial agreement provided by the device manufacturer, which may or may not include some aspect of revenue sharing and a necessary technical quality assurance verification process. Additional commercial agreement would be necessary if the content provider wanted additional features such as the application to be listed in the initial offerings, on the home screen or initial applications rail, or presented to the user during the initial out of the box set up phase.

If the content provider wishes to expose its content on the Smart TV outside of the confines of its own application, it will also need to make its metadata available to the wider Smart TV platform. This will require a technical integration exercise and a further commercial agreement is usually needed. Without metadata, the Smart TV platform has no knowledge of the content hosted within the application.

Linear Services in addition to Catch-Up

The above caters for applications that include both live linear and VOD (catch up) type service. Originally applications predominantly focused on only offering xVOD content however many content offerings now offer both catch up and live linear services within their applications. 

If the content provider were only to be offering live linear streams then an alternative approach is to integrate these services within a larger providers application or, if available, within the FAST channel offering provided by the device manufacturer. An example of the former would be the National League integrating its live football streaming services within the DAZN application.  An example of a FAST channel is Red Bull TV which is available on many major Smart TV FAST channel services and USB Sticks. For content providers wishing to offer a channel within the FAST channel offering provided by the device manufacturer such carriage would be subject to the commercial terms of the FAST platform.^{[footnote 12]}

The remainder of  (iii) has also had input from other companies within the TV sector working group.

HbbTV applications

Although the SDKs^{[footnote 13]} of the end devices differ between the TVOS platform owners, there is sometimes commonality between Smart TV platforms, and so the same code can be used.  However, some TVOS use a completely different non-HTML technology meaning there is no code reuse in these platforms. The exception to this is if the standardised HbbTV API is used (as profiled in the D-Book and required by free platforms such as Freeview Play and Freely), in which case the application should run seamlessly on all HbbTV compatible devices without modification.

An extension of the HbbTV core application principle is the HbbTV OpApp (Operator Application) approach. The OEM or TVOS reaches agreement with the OpApp to carry it on its platform. In essence the HbbTV OpApp can be considered to be a “virtual set top box” integrated within a Smart TV.^{[footnote 14]} As such it replaces many aspects of the devices own native UI, and therefore the OpApp has much greater control of the user environment and service offerings presented to the viewer.^{[footnote 15]} Operator Apps also have the capability to allow app-to-app communication, which for example is how Freely is able to launch apps such as the iPlayer or ITVX. This benefits the viewer because it makes journeys between content providers much more seamless and intuitive  and means the viewer does not have to go back to the TV home screen. The two most well-known examples of services built on the OpApp are HD+ subscription platform in Germany and Freely in the UK. 

All of the above, to greater or lesser extents, can be considered to be a collection of individual, vertically closed, fragmented, walled garden environments TV platforms. The user experience is defined autonomously by the owners of each application, platform, operating system and device or a combination of any of these depending on commercial discussions. The UK has multiple routes in the IP world for content providers to reach audiences in a simple manner. Hence there is less consistency of user experience than in DTT.

Potential option iv: A standards-based solution for the future

Some techUK members have not reached agreement with the PSBs for carriage of the PSB linear IP services through the three options above. These members note that deep-linking requires multiple steps to switch between linear channels—which users must also do when switching between FAST platforms and/or all the apps on the smart TV—which may be challenging and cumbersome for users, especially for elderly or vulnerable people. They note that having more individual platform licences would further fragment the market. Some of techUK’s members note that they have not been able to reach successful commercial agreements with Freely.

TechUK would therefore like the UK to adopt a further potential option based on an open horizontal standards-based ecosystem. TechUK believes PSB linear channels should be required to be made available over IP based on open standards to ensure universal access. TechUK believes this will enable the user-friendly access paradigm associated with the DTT network to endure with as little audience confusion as possible, while also reduce barriers to entry to the UK market for smaller manufacturers and new entrants. 

TechUK strongly suggests that DVB-I could be the preferred solution for the UK in the long term. If this is not adopted by the UK techUK believe this may result in more expensive devices and services to UK audiences. Germany, Italy and Ireland have well advanced DVB-I trials and their direction of travel is becoming ever more concrete.^{[footnote 16]} Although still labelled as “trials” TechUK note they are effectively pre-launch exercises to iron out wrinkles and determine when, not if, such services will be launched. Italy and Germany both have demanding commercial and regulatory requirements on their PSB service offerings over IP and solutions have been developed to meet all such requirements. There are no suggestions that DVB-I will not meet these needs and commercial launches may soon be announced if stakeholders can agree the whole framework.^{[footnote 17]}

New Zealand is probably the most advanced country to develop its DVB-I service proposition with 2027 having been set as the date when it becomes mandatory for devices wishing to be blessed by the New Zealand accreditation scheme. More recently other countries such as France and Spain have also announced trials. TechUK believes a common harmonised solution across the UK and the Republic of Ireland would be beneficial. China is also an adopter of DVB-I, and for the first time ever a DVB standard (i.e. DVB-I) has been fully translated, word for word, into the Chinese language in order to accelerate implementation. 

However, there is no agreement within the TV Sector Working Group as to whether DVB-I would be the correct standard to be used within the UK.  No country has yet deployed DVB-I, with some trials ongoing and some countries announcing trials. These trials have all worked on the assumption that the DVB-I service lists will effectively allow OEMs to discover channels and then present and play them back within their own Guides and Players. In effect this means that UK broadcaster content could be next to non-Ofcom licensed channels which do not need to adhere to the Ofcom Broadcasting Code.^{[footnote 18]}

ETV noted that it considered the use of DVB-I ahead of developing the Tech solution for Freely. Whilst the Op App approach ETV adopted is slightly more complex than a simple Broadcast Associated HbbTV app, ETV believe it remains the only way to deliver a truly aggregated user experience for Live TV that is consistent across TV OEMs and Content Partner channels.

From a technical perspective, DVB-I represents an approach to implementing some parts of a TV distribution chain. It is primarily a Service List Management specification.^{[footnote 19]} CLM looks at a device’s capabilities and location and returns the correct channel list for the region, and the appropriate IP/DTT channel mix for the platform and connectivity type. DVB-I itself does not yet, but could include the specific features required in the UK to handle its complex DTT regionality needs, and DVB previously declined to adopt them when they were offered. 

DVB-I is not a single defined solution, but a flexible standard that then requires additional implementation parameters to be set for it to comprise a solution. The parameters for a DVB-I solution are what determine how standardised it is. The specific regional and local nature of the UK would need to be reflected and supported in the DVB-I standard. Thus, if DVB-I still requires bespoke work for each national implementation (e.g. for regionality), then it’s simply a new bespoke solution rather than a universal one.

TechUK is not advocating that DVB-I should be mandatory in IP TV devices, but that it should be mandatory for PSB linear channels to be available over IP based on open standards, to be delivered on the same principles as broadcast streams. Some broadcasters within the TV Sector Working Group noted that should content providers be mandated to use DVB-I then DVB-I will only be one of a number of TV operating technologies used in the market, and implementation therefore increases their costs with no associated benefit.

However, even if there were no technical barriers to implementation, the broadcasters and manufacturers would still need to agree commercial requirements for the carriage of the PSB linear channels (such as metadata complexity, targeted linear advertising, quality of delivery, DRM, audience data and so on), the ad-funded PSB’s non-PSB linear channels, and all their VOD content. Having a standards-based option does nothing inherently to resolve these broad commercial issues (see the text boxes overleaf for further details).

Emerging challenges for broadcasters and platforms in agreeing terms for inclusion

It is against this backdrop that PSBs and some platform operators have found it challenging to agree terms - both for linear IP specifically, and also for the terms of inclusion of content services more broadly. In considering whether and how such challenges might be addressed, it is important to first understand the prevalence of such issues. 

Looking at BARB and 3Reasons data, it can be seen that around a third of UK homes have either Freeview or Freesat on their primary TV set. The remaining two thirds use a platform that requires either broadcasters or ETV to agree terms for the carriage or inclusion of PSB linear IP services. These platforms include Sky (satellite and IP), Virgin Media, BT/EETV, Freely (e.g. Amazon Fire TVs, Roku TVs, Hisense, Vestel and others) and ‘OTT-only’ (which will include Samsung and LG TVs not connected to an aerial). 

Whilst this paper discusses (see the following text box)  the current challenges that PSBs and some techUK members have faced in trying to reach terms for the supply of linear channels, it is important to be clear that these challenges have arisen only in the ‘OTT-only’ space, which overall represents around 20-25% of the total market. As some providers of OTT-only platforms also offer Freely for some of their models or have agreed other terms for linear supply for their OTT-only models, it is not necessarily the entire segment that is impacted, so 20 to 25% represents the uppermost boundary.^{[footnote 20]}

Whilst individual negotiations will vary, the fact that the majority of platforms have commercial deals in place for the supply of linear IP channels suggests the remaining challenges arise from genuine but specific commercial differences between the negotiating parties rather than being suggestive of a structural barrier to PSBs and platforms agreeing terms for IP distribution per se.

Current commercial issue of PSB linear IP channels

This group recognises that there is a current unresolved commercial issue between some TV manufacturers and some of the public service broadcasters regarding distribution and carriage terms of the linear IP PSB channels. The DCMS also understands the concerns that have been previously raised by techUK members around access to PSB IP Linear Services, and recognise the importance for PSBs and TV manufacturers being able to reach appropriate deals which work for audiences. As will be the case under the new prominence regime, the aim of the DCMS is to allow parties to explore mutually beneficial arrangements independent from government. 

These disputes are less about audience access to PSB content than about commercial issues related to the manner of supply to platforms. While current commercial issues sit outside the scope of the Stakeholder Forum, some aspects are relevant in this paper. We have therefore set out the top-level views of the relevant TV platforms and PSBs. We are not making any recommendation.

In DTT the TV manufacturer has no control over which channels are broadcast. Compliance to the DTG D-Book (by both broadcasters and devices) ensures interoperability and that all manufacturers have access to the same broadcaster metadata as each other. Manufacturers do not monetise the DTT broadcast content the TV screen displays, while broadcasters have direct and unmediated access to their audiences. Because of the lack of a back channel there is no data available to the broadcaster nor manufacturer as to the real-time TV viewing by each household.

With TV delivered via IP the commercial model has changed. Broadcasters have to make commercial arrangements with the TV manufacturer/TVOS platform (Television Selection Service, or TSS) for carriage. The Media Act 2024 ensures that the PSB players must be carried and given appropriate prominence on each connected device that is within scope of the new regulatory regime (RTSS). While the Media Act requires the RTSS to give appropriate prominence to PSB channels if carried within the PSB services (DIPs) it does not explicitly mandate the linear public service channels over IP, which may therefore be subject to commercial negotiation between each TV platform and each PSB, subject to Ofcom’s implementation of the Act.

As of today, bi-lateral commercial agreements for disaggregated carriage of PSB’ linear channels between some PSBs and some of techUK’s members (including Samsung and LG) have not been reached. Access to those linear streams is still fully available via PSB apps. Detailed below are the high-level views of the broadcasters and the manufacturers. 

Public Service Broadcasters’ views

PSBs recognise that universal access for our audience to our IP-delivered PSB channels and streaming services is crucial - universality has always been a key feature of PSB. That’s why our streaming services and IP channels are already available to our audiences across a wide range of platforms and devices.

But in recent months there has been a suggestion that PSBs are somehow withholding the IP variants of their linear channels, with the implication that audiences can’t easily access them. This is simply not the case - this is not an argument about universal provision to our audiences, but a disagreement about the way in which that takes place and the commercial terms of specific types of provision via online TV platforms. 

Often disagreements stem from the expectation of global providers that national PSBs specifically should simply conform to global standards and terms, and a lack of willingness to entertain alternatives. These expectations are not placed on other content providers e.g. global SVODs like Netflix or Disney who use their own proprietary technology. For PSBs to agree to disaggregated supply of IP linear channels on the terms set by many global TV platforms would substantially undermine the ability of the PSBs to fulfil their public service remits and would damage the commercial model that funds UK content at scale. For instance, it could result in PSBs having no insight into who is watching or what they are watching, with commercial PSBs being required to use the ad sales functions of the platform (with a revenue share) rather than selling ads directly. Perversely, such disaggregated supply would enable the online platform to monetise the data about their channel and viewers to sell advertising in competition to the PSBs.

To protect PSB outcomes for audiences in the long term, government should support PSBs to make decisions about how they distribute their content and services in the interests of their UK audiences. The current dispute between a small minority of manufacturers and the PSBs is fundamentally a disagreement about commercial models for delivery of content and services. Given there is no technical barrier, there is no reason for government to intervene. On the technical side, we welcome opportunities to update IP linear solutions to make them more standardised to deliver greater benefits to UK audiences and the industry. 

Sky’s view: 

For Sky to be able to continue to provide a linear TV service that functions in the manner that audiences know and expect, it is crucial that Sky can access and provide PSB linear streams natively. This allows audiences to access PSB linear content either directly from within the Sky platform or by scrolling up and down the Sky EPG, choosing programmes and channels directly. It notably avoids the friction of having to go in and out of a series of individual apps, all with different functionality and characteristics and with a requirement to log in to each separately. If Sky’s ability to provide native linear streams is impeded, the ability to provide other IPTV innovations that consumers value – such as ‘watch from start’ - could also be impacted.

Some of TechUK’s members’ views

Whereas DTT broadcast channels are relatively straightforward for device manufacturers to access, IP-delivered streams are easier for PSBs to deny access to. This creates a scenario where television manufacturers now effectively have to negotiate to gain access to PSB linear content delivered over IP. 

These techUK’s members position is that in an all-IP environment, access routes based solely on BVOD applications such as iPlayer, or via operator applications with terms set collectively by PSBs, have failed – and will continue to fail – to sustainably deliver the universality, simplicity, and inclusivity required of PSB services. To meet these objectives government must:

• Set a non-negotiable directive that all televisions sold in the UK provide audiences with universal access to linear PSB services via logical channel numbers (LCNs) and an Electronic Programme Guide (EPG).

• Essentially this means that the traditional user-friendly approach to presenting linear services to audiences can be preserved in the future IP world, with no clumsy user-unfriendly solutions based on deep-linking and trying to stitch together a myriad of proprietary player applications etc.

• Mandate open and non-proprietary standards for delivery of PSB IP linear streams and metadata, enabling interoperability across all devices.

• Essentially this means agreeing on the necessary equivalent standards to DVB-SI in DTT, to enable #1 to happen

• Ensure unobstructed and unmediated access to PSB IP linear streams and broadcaster metadata so that PSB channels can be integrated into familiar EPG structures, preserving simple and anonymous navigation for audiences.
  • Essentially this guarantees that audiences will be able to receive linear services in their familiar user friendly paradigms identically as they did for DTT
• Replicate the successful approach of digital switchover, where industry collaboration ensured continuity of service, by directing industry, under Ofcom oversight, to agree the necessary technical standards, compliance frameworks, and service obligations.
  • This is necessary as without it there will only be continued proprietary  standards and solutions competing for audience attention, perpetuating fragmentation and confusion for UK audiences,

All of the above are critical dependencies and pre-requisites to be secured before a decision on any IP transition path can be made. These will make a significant contribution to the preservation and prolongation of a universal, inclusive, simple television delivery system, acceptable to all audiences. These issues can no longer be deferred.

TechUK believe that government must ensure that devices can have guaranteed access to PSB IP linear streams and that device manufacturers have unobstructed access to metadata about the broadcaster content available via linear services and VOD apps. Guaranteed access to metadata would enable device manufacturers to create content guides and recommendations that are more appropriate to viewers’ preferences. If manufacturers are denied access to this metadata we may well see greater fragmentation and a more complex navigation path for consumers.

The viewer should sit at the heart of any IPTV future.  Viewers still enjoy watching live TV channels and will still be doing so for many years to come. It is therefore important that it is easy and intuitive for them to continue to be able to easily access live channels, and in a manner to which they are accustomed. Public service broadcasting sits at the heart of the UK TV sector and should continue to do so if content delivery transitions to a fully-IP future.

Audiences have become accustomed to “broadcast quality services” as their TV baseline viewing experience and they expect such standards to prevail as products and services evolve as technology advances. Their expectations include not only video and audio quality aspects but also production values and ease of use, features and familiarity. Anonymous content navigation is a part of this product mix. Audiences expect this to be seamless and easy to use. Innovations, such as voice search and navigation, have improved the experience for many, but the underlying core paradigm of the ease of use of the traditional familiar EPG, with its familiar channel numbers, and the ability to launch content directly from the EPG without friction remains at the core of many users experience. Adopting a similar EPG principle across IPTV platforms  would be very helpful for many audiences to transition over. 

However, there are some challenges that need to be recognised:

• The legal and regulatory framework must continue to evolve
• Industry should continue to work together to develop the technical infrastructure 
• Regional and local broadcasting and minority UK languages need to be protected

The legal and regulatory framework must continue to evolve

Unlike in DTT, which offers broadcasters unmediated and direct access to audiences, the commercial model of IPTV has given rise to the TVOS platform/manufacturer having a direct relationship with the viewer. In contrast to UK-specific platforms, such as Sky and Virgin Media, the global operators of TV platforms may sometimes have less interest in the particular characteristics and priorities of the UK TV market and PSB. While these platforms recognise consumers want both local and global content, they may often apply global terms to the aggregation and distribution of some content providers, while also seeking to monetise local broadcaster prominence and visibility and secure a percentage of any revenue generated via their platforms. 

Accordingly, this new world also creates serious potential risks to the visibility and easy availability of UK content providers on some platforms, and threatens investment in all original UK content, including by PSBs. Commercial broadcasters in the UK have to make significant revenues in order to be able to afford to invest in original UK content and broader public service media output such as national, nations and regions news which does not necessarily work commercially. Broadcasters investment in UK content is key to a diverse and healthy TV sector.

At the same time, competition for advertising revenue is more intense than it has ever been and costs of original programming have been accelerating ahead of inflation - a big challenge in itself. The result is that commercial broadcasters are making returns that are only just meeting their cost of capital. There is no scope therefore to pay platforms for prominence or to share advertising revenues—if commercial PSBs had to do that there would be a direct and immediate impact on levels of original UK content investment and on the viability and sustainability of PSB— in both cases to the significant detriment of UK viewers.  It was for these reasons that the Media Act was enacted to give PSBs prominence on online TV platforms and to ensure equitable resolution of disputes. 

The DCMS is aware that, as viewing over the internet increases, this gives rise to certain regulatory considerations, including the question as to whether to designate additional electronic programmes (EPGs) for regulation to make sure there are adequate protections for audiences, appropriate accessibility requirements and rules around prominence for PSBs on regulated EPGs. The DCMS will continue to keep stakeholders informed as work on this progresses.

In addition to the above, smaller and non-UK wide channels have more limited leverage in negotiations. Despite protracted dialogue across multiple platforms and manufacturers, STV has been unable to secure prominence as a PSB on some platforms through a lack of effective leverage. S4C has faced similar barriers, with limited ability to negotiate in the absence of regulatory support. The Media Act should enable STV and S4C to have the appropriate level of prominence and to reflect the regional prominence afforded in the DTT landscape.

Over time, as online TV consumption increases further on an ever-proliferating range of platforms and services, a new policy approach from government may be needed if the current framework proves ineffective.

Whilst the Media Act 2024 will look to introduce more guardrails to ensure PSBs and Television Selection Services have regulated access to each other’s respective services, it is important that ensuring viewers’ ease of access to content is at the heart of any future regulatory framework for IPTV distribution, so as to meet consumer expectations.

While the Media Act is a welcome step, it does not yet guarantee prominence across all discovery routes, which will be crucial as technologies and audience behaviours continue to evolve. The PSBs believe that prominence must be extended to all AV devices, user interfaces operating systems and algorithms. Local content providers must be easily discoverable via EPGs, app rails, voice search, and remote controls. The PSBs believe that if prominence is not considered in the round, then government’s longstanding commitment to ensuring the ongoing investment in and availability of public service content for UK audiences will also be at risk. This is particularly pressing in an increasingly challenging environment for public service broadcasting.

The Local TV Network note that Local TV is unique in being the only public service radio or TV licensee not to have its future IP carriage/prominence secured through the Media Act 2024. The local TV sector will want to see other solutions that will enable audiences to continue to receive local content. Future IP arrangements should also provide an opportunity to increase relevant local audience coverage, where appropriate.

Industry should continue to work together to develop the technical infrastructure 

The sheer range of operating systems and devices means that onboarding and supporting smaller broadcasters can be complex and costly. This could mean broadcasters may not be able to put their service on all platforms, reducing choice for viewers compared to today. The reverse is true for the smaller manufacturers and new market entrants trying to gain access to multiple broadcasters’ services in order to compete with their larger competitors.

In the IP world, the range of operating systems and device types means that the process of onboarding and supporting broadcasters’ services on connected TVs can be complex and costly for both broadcaster and manufacturer, which poses challenges for all broadcasters and manufacturers especially those with more limited resources, many of which are yet to launch IP channels. These complexities include:

• Building different versions of apps/services to the multiple different technical standards operated by the range of global platforms in accordance with their individual requirements (some more onerous than others) and extensive testing across multiple devices before onboarding. 
• Supporting the multitude of platforms with a variety of differing integration and platform rules which vary over time.
• Providing metadata to meet the differing requirements of each platform, as there is no universal set of metadata requirements, which again involves complexity and cost.
• Time and resource in having to reach bespoke agreements with each broadcaster, OEM or TVOS.

We note that such complication and cost can be multiplied if linear playout is required to take place outside of content provider apps, where content providers need to operate to a further diversity of player software (controlled by the manufacturer) and relevant implementations of standards (such as streaming formats like MPEG-DASH) and variations of different DRMs alongside multiple metadata feeds to ensure now/next and other live content discovery areas have the latest information of what’s on.

This all means that broadcasters must prioritise the major platforms, and thus some existing linear channels may not all be available on every platform via IP. Ideally this should be minimised. 

Due to the complexity of IPTV (with many different commercial models within the market, and the myriad uses of metadata differentiating each platform and driving revenue to it) it is not as simple as to set technical standards that all platforms must adopt. However, industry should continue to work together to develop the technical infrastructure for IPTV to flourish within the UK. The concept of whether to introduce an equivalent of the “Digital Tick” Certification Mark which was developed with industry, to indicate when a platform has met relevant requirements could be considered.

Regional and local broadcasting and minority UK languages need to be protected

The UK’s PSB system has a high degree of regionality, serving viewers in different nations and regions with targeted programmes relevant to them. These are either regional versions of network output (BBC One/Two), regional services that form a UK network (ITV1/STV) or channels targeted primarily at individual nations (S4C, BBC Alba/BBC Scotland). Additionally, there are 34 local digital television services, intended for reception only within a particular area or locality, which hold specific obligations under their licences, including requirements for local news and programming.

Historically regionality has been delivered as an intrinsic part of distribution chains – DTT providing tailored multiplexes for different regions with appropriate EPGs and DSAT/DCAB having similar mechanisms to replicate, including by reference to billing information/postcode entry on setup.

Many large platforms, such as YouView, Freeview Play, Freely^{[footnote 21]}, VMO2 as well as Sky IPTV devices such as Sky Glass and Sky Stream show that regionalisation is possible. However, not all IPTV platforms include regionality as part of the user experience, which means PSB services targeted at regions/nations may not be prominent^{[footnote 22]} or in some cases not appear at all. In addition some of these platforms/device manufacturers are much less likely to pre-install nations/regions PSB services than UK networks, even where geography is known – e.g. via postcode at setup.^{[footnote 23]} As a result, users must take additional steps to install regional PSB apps from the app store and they will be unlikely to receive appropriate prominence.

It is not an optimal experience for the viewer to be served the incorrect regional broadcast. In addition, in Scotland the viewer may have access to both ITVX and the STV Player (although they may have had to install the STV Player app themselves), and if the TV platform cannot regionalise the promotional rail then a viewer won’t be able to access an ITV1 programme on ITVX and may not easily be able to surface the STV Player. This is not a good user experience.

With the general trend to online platforms developing functionality to offer increasing personalisation, including targeted ads, there should be no technical impediment to TVOS platforms implementing a requirement for regionality, e.g. through mapping of IP address and/or postcode entry. It is understood that compliance with GDPR requirements should be possible by demonstrating that delivering PSB regional prominence under legal/regulatory requirements constitutes a lawful basis. As noted earlier in this paper, DSAT/DCAB have always been able to offer regionalisation by reference to billing information/postcode entry on setup. 

We note that postcodes are not a completely stable entity, with frequent updates to the postcode database such as creating new postcodes and discontinuing others to reflect new developments, address reorganisations, or demolition of properties. Having said this, Sky, VMO2, BT/EE and Freely already handle this, while most TV manufacturers require a postcode to set up the TV, and it is not necessary to have the full postcode to determine whether an address is in, say, Wales or England. 

Manufacturers would also be looking for a solution that could be replicated across all of Europe which again adds another layer of complexity due to national variations in EU postcode structures. However, this may make TVs less user-friendly for audiences because alternatives to local postcode-based systems would mean viewers may have to, say, select from a long list of regions, or use an entirely new Europe-wide system. Similar issues would apply to IP address mapping.

techUK note that regionality is an issue that impacts all countries across Europe, with regionalisation requirements overlapping with prominence requirements. Manufacturers require economies of scale at the European level and divergent national requirements may result in fragmentation and increased device costs for consumers. Smart TV manufacturers serving the European market have become exasperated by the fragmented transpositions of the 2018 AVMS directive, and its successor the 2024 EMFA, particularly in Germany, Italy and France.^{[footnote 24]} From a manufacturing perspective the UK’s specific regionalisation needs require a bespoke solution,  add on another layer of fragmentation for manufacturers which typically have a single factory producing Smart TVs for all Europe. From a manufacturing perspective the UK’s specific regionalisation needs require a bespoke solution,  add on another layer of fragmentation for manufacturers which typically have a single factory producing Smart TVs for all Europe.

TechUK argue that the uncertain and still developing fragmented approach to prominence and regionalisation across Europe has made it impossible for global manufacturers to pre-empt and predict what each ultimate individual national requirement will be. Manufacturers fully appreciate the benefits of regionalisation for audiences, and those that have developed interim solutions risk having to re-work these to meet the needs of the final requirements. Development and implementation can only therefore start once the final regulated requirements in the Media Act have been agreed and unambiguously defined. 

STV and S4C both believe it would be worth considering a common standard for global TVOS platforms to adopt to achieve accurate regionalisation, although recognise that geolocation derived from an IP address is not always reliable, and so it is helpful to also have a postcode. DVB-I is one such standard that might in future support regionalisation on IP networks allowing delivery of region-specific services based on users’ geolocation. We recommend that further industry work is done on developing regionalisation on IPTV platforms.

Lack of attribution and/or promotional activity on platforms/devices further hinders STV and S4C. Featured promotional slots and content rails are often only UK-wide and seldom include content from nations/regions PSBs. For example, in the case of Channel 3 licences, this results in national promotion for ITVX. Consequently, there is incorrect attribution in STV regions and poor user experience since Channel 3 network programmes are only available on STV Player in relevant areas. However, this is due to implementation choices made by platforms rather than due to technical barriers. For example, Freely’s PSB promotional slots for Channel 3 licensees in Scotland promote STV not ITV with all promotions deep-linking to STV Player.

There are additional challenges for minority language broadcasters. Under the Media Act, the public service remit for television will, for the first time, include providing audiovisual content “in a recognised regional or minority language” of the UK. Whilst this is welcomed, it also presents particular challenges for a minority language broadcaster such as S4C, as search (text and voice) becomes an increasingly important pathway for audiences to find content on platforms. Smart TV manufacturers generally have to buy in natural language processing (NLP) technology from third parties and so are completely dependent on the capabilities of such external software. It is only relatively recently that the major EU languages have been covered and there is a very long tail of minority languages yet to be addressed. Various projects are understood to be in place with approximate target dates of 2030 being suggested before the long tail of minority languages might be commonly supported. It has also yet to be determined how much language support could be directly integrated natively within a device and how much would be online and cloud based and the relative performance capabilities of such solutions. With advancements in language recognition technology, it is hoped that platforms can be encouraged or, once technology allows, required to accommodate minority languages in platform text and voice search, and algorithmic logic which drives discovery and prominence.

1. TechUK believes Ofcom’s preference to designate only the top 14 platforms as RTSSs may disadvantage other TVOS platforms. ↩

2. OTT-only households have no access to TV via satellite, cable or DTT. Over 75% of homes currently have IPTV (Barb Establishment Survey, Q2 2025). Estimates based on Barb ES and 3 Reasons Platform Model Spring 2025. ↩

3. Viewers may also be able to access linear IP channels directly in apps, via casting and through connected devices such as streaming sticks, laptops or games consoles. ↩

4. In addition there is a quasi-national multiplex for local TV and a separate Northern Ireland multiplex. ↩

5. Comux Ltd operates the local multiplex which covers 58% of the UK and Multiplex Broadcasting Services operates the multiplex in Northern Ireland. ↩

6. Ofcom Code of practice on electronic programme guides. ↩

7. TechUK notes that broadcasters have full information on their viewers consumption habits within broadcasters’ own apps. They note access to wider platform data cannot automatically be provided without an appropriate agreement with the platform provider. Broadcasters would note that they would need to reach a commercial agreement with the platform to obtain viewing data to their own content if it were done outside the broadcaster’s own app. ↩

8. Freely is an IP linear and VOD service that sits on Smart TVs and connected devices focused on FTA content. ↩

9. techUK notes that many of the comments and issues identified by its members come from such TVOSs and it cannot be assumed that Freely has unwavering support for its paradigm from all these TVOSs. ↩

10. Freely Website ↩

11. Freely Logical Channel Numbering (LCN) Policy, January 2024 ↩

12. A full description of the FAST channel landscape is provided in the  DTG’s FAST Forward – Your Essential FAST TV Industry Handbook. ↩

13. SDK stands for Software Development Kit, a collection of software-building tools, like libraries, debuggers, and compilers, that enable developers to create applications for a specific platform or operating system. ↩

14. A full description is available on the HbbTV Website here. ↩

15. The user can still choose to use the TVOS or uninstall the OpApp. ↩

16. For up-to-date information on DVB-I deployments please see : https://dvb-i.tv/deployments/ ↩

17. In Germany the participating groups are now looking at how to take a successful trial forwards, and plan to address significant aspects including : Monetisation, User Experience, Marketing, Regulatory concerns, Service List Governance, Prominence, Data sovereignty, Identity management, OEM adoption, Content partner ecosystem etc. ↩

18. One of the key learnings of the trials is that anything other than a simple unencrypted channel being launched also requires an HbbTV app to start up after each channel change in order to support capabilities such as DRM, CDN selection, Identity (and consent) and Dynamic Ad Insertion. Solutions to these kinds of shortcomings are expected, but have not cut through into production deployments so far. ↩

19. In this respect it is similar to ETV’s Chanel List Management (CLM) specification, which has been built into all recent Freeview Play TVs and now carries out the same function for Freely. ↩

20. Viewers may also be able to access linear IP channels directly in apps, via casting and through connected devices such as streaming sticks, laptops or games consoles. ↩

21. Hybrid Freely user: the CLM uses the DTT signal to decide which DTT antenna to use, and which regional variants of IP services to use. If DTT can’t be used, the user is asked for a postcode. For IP-only: a user enters their postcode and CLM decides which IP regional variant to serve for each channel. In both cases regional variants are available for the main PSBs to the same level of variation as their DTT equivalents. ↩

22. S4C’s and STV’s expectation is that the Media Act will enable regionalised prominence in Wales/STV regions respectively on connected TVs. ↩

23. For example, S4C Clic has to be downloaded by users from the app store on Amazon Fire, LG and Samsung devices. ↩

24. DigitalEurope, the EU equivalent of techUK, has published numerous policy papers on such matters, calling for harmonisation rather than fragmentation, here. ↩