“Watch this space” media consultation. Pause and Revise before its results are used
The Issue
Report on Defects in Consultation Design and Requested Corrective Action
Date: 12 July 2026
Status: For submission / signature
Addressed to: Secretary of State for Culture, Media and Sport; Minister responsible for Creative Industries, Media and Arts; Department for Culture, Media and Sport
Purpose and Scope
This report sets out the case for DCMS to pause reliance on and analysis of the current ‘Watch this space’ consultation questionnaire, to correct identified defects in question design and accessibility, and to reopen or extend the consultation for a full response period following revision. It covers the questionnaire’s treatment of opposition options, routing transparency, leading or presuppositional wording, accessibility risk, privacy and AI-analysis matters, and the full set of corrective actions requested.
Executive Summary
The Department for Culture, Media and Sport’s ‘Watch this space’ consultation could influence how news is ranked online, the future of Freeview and digital terrestrial television, and the structure of public service media.
These are major decisions affecting freedom of expression, media plurality, viewer choice, digital exclusion, accessibility and emergency resilience.
However, the questionnaire does not consistently allow respondents to express their actual position. Some answer structures assume that a proposal should proceed rather than providing an equally clear way to reject it, select none of the available options, or retain the present system.
Some wording also risks confusing support for broad objectives — such as accurate information, accessible services or protections for vulnerable people — with consent to a particular form of government intervention.
The consultation is lengthy and technically complex. Important definitions and explanations are dispersed through extensive supporting documents rather than consistently provided in short, neutral language at the point each answer is requested. This may cause people to misunderstand questions, skip them, select ‘Not sure’ despite holding a clear view, or abandon the consultation.
The questionnaire’s routing, mandatory-answer rules and treatment of rankings, skipped answers and ‘Not sure’ responses are also insufficiently transparent. This creates a risk that the results will not accurately represent public opinion and that older people, disabled people, digitally excluded households and people without specialist knowledge will be disproportionately excluded or misrepresented.
We therefore ask DCMS to pause reliance on and analysis of the current questionnaire, correct the identified defects, improve its accessibility and transparency, allow existing respondents to amend or replace their answers, and reopen or extend the consultation for a full response period after revision.
A government consultation must record what citizens actually think — including whether they reject a proposed intervention altogether.
1. Overview
The ‘Watch this space’ consultation closes on 31 August 2026, but parts of the questionnaire do not allow citizens to record clear opposition to the proposals being discussed.
• Questions 5 and 6 ask how a ‘trustworthy news’ prominence regime should operate, but provide no direct option to reject government-backed preferential ranking.
• Questions 17 and 18 ask people to rank matters connected with a transition to internet-delivered television, without an explicit ‘I oppose the transition’, ‘retain DTT’ or ‘not applicable’ option.
• Question 28 asks respondents to rank three replacement models and a combination of them, but does not offer ‘retain the present system’ or ‘none of these’.
• Other questions risk confusing broad support for accurate information or easier access with consent to government-mandated algorithmic privilege.
Concern about misinformation is not consent for selected providers to be favoured in search results, recommendation feeds, homepages or platform interfaces.
The consultation is also long and technically complex. Definitions exist in the Green Paper, but they are dispersed and may not be available in clear, neutral language at the point each answer is requested.
Respondents may therefore skip important questions, choose ‘Not sure’ despite holding an opposing view, or abandon the survey. This risks non-response and accessibility bias, particularly affecting older people, disabled people, digitally excluded households and respondents without specialist knowledge.
Requested Action
We call on DCMS to:
• Pause reliance on and analysis of the current questionnaire.
• Add direct opposition, ‘none’ and ‘not applicable’ options.
• Rewrite leading or presuppositional questions.
• Publish the survey-routing and mandatory-answer rules.
• Explain technical terms, benefits, risks and alternatives at the point of answering.
• Preserve existing responses while allowing respondents to amend or replace them.
• Ensure rankings, skipped answers and ‘Not sure’ responses are not treated as support.
• Provide accessible versions suitable for assistive technology.
• Reopen or extend the consultation for a full response period after revision.
Signing the associated petition does not replace responding directly to the consultation. Respondents are also encouraged to submit their views to DCMS and contact their MP.
2. Why This Report Is Necessary
The consultation contains 30 numbered questions and 12 lettered follow-up questions. It concerns:
• Freedom of expression
• Media plurality
• Government influence over online content ranking
• The future of Freeview and digital terrestrial television
• Public service media
• User choice
• Digital exclusion
• Emergency resilience
• Disability access
• Privacy
• The use of artificial intelligence to analyse consultation responses
A consultation dealing with issues of this importance must allow people to express their actual views accurately. It must not:
• Require respondents to choose between different versions of a policy they oppose.
• Interpret concern about misinformation as support for government-backed content ranking.
• Exclude or disadvantage people through technical language, excessive length or inadequate explanation.
3. Questions That Do Not Provide a Clear Opposition Option
Question 5
Question 5 asks whether prominence for selected ‘trustworthy’ news providers should be:
• Ongoing and always active
• Active only during periods of heightened vulnerability
• ‘Not sure’
Both substantive options assume that a government-backed prominence system will be introduced. There is no option allowing a respondent to state that:
• Prominence measures should not be introduced.
• Platforms should not be required to alter rankings, recommendations or feeds.
• Selected providers should not receive government-backed preferential placement.
• Users should determine what lawful content they see without state-influenced prioritisation.
• Lawful news and opinion should compete without government-created algorithmic privilege.
‘Not sure’ cannot represent the position of someone who clearly opposes the proposal.
Question 6
Question 6 asks whether users should be able to switch prominence measures on or off. A ‘Yes’ answer assumes that the prominence regime should exist but be optional; a ‘No’ answer assumes that the regime should exist and should not be optional. Neither option allows respondents to state that no government-backed prominence regime should be created in the first place. Again, ‘Not sure’ is not a substitute for a direct opposition option.
Question 17
Question 17 asks which, if any, of four challenges relating to an IPTV transition are most important and directs respondents to rank them. Although the words ‘which, if any’ appear in the question, there is no explicit answer stating:
• I oppose an IPTV transition
• DTT should be retained
• No transition should be planned
• None of these
• Not applicable
• I reject the premise of the question
It is also not clear from the publicly available question list whether respondents can leave the entire ranking blank. If this question is shown to people who have already opposed an IPTV transition, asking them to rank transition considerations risks making their answers appear to accept the transition.
Question 18
Question 18 begins: ‘In the event of an IPTV transition…’ and then asks respondents to rank possible support measures. Although it says ‘which of the following, if any’, it does not provide an explicit:
• None
• Not applicable
• I oppose the transition
• Retain DTT
• No transition should take place
option. Support for affordable broadband, accessible equipment or assistance for older and disabled people must not be interpreted as support for switching off DTT. A respondent may believe that those protections would be essential if a transition occurred while still opposing the transition itself.
Question 28
Question 28 presents three illustrative replacement models and a fourth option combining those models, and asks respondents to rank their preferred model. It does not provide:
• Retain the existing system
• No reform
• None of these
• Another model
• Not applicable
• I reject the premise that one of these models should be adopted
A respondent who opposes all three models and their combination is therefore not given an answer that accurately records that position.
4. Conditional Survey Routing Must Be Published
The public version of the consultation lists the questions but does not show the conditional routing used in the live Qualtrics survey. It is therefore unclear from the published material whether:
• Questions 4a, 5 and 6 are shown after a respondent answers ‘No’ to Question 4.
• Questions 17 and 18 are shown after a respondent rejects an IPTV transition.
• Question 28 is shown after a respondent opposes reform of the existing public service media system.
• Ranking questions may be left wholly unanswered.
• Respondents must answer particular questions before continuing.
• Different respondents see different follow-up questions depending on earlier answers.
If these questions are shown only to people who have already supported the relevant proposal, DCMS should publish that routing clearly. If they are shown to people who have rejected the proposal, the questions must contain direct ‘I oppose this proposal’, ‘none’, ‘not applicable’ and ‘retain the present system’ options.
5. Free Text Does Not Correct Defective Answer Options
The consultation includes broad free-text questions, including Questions 20, 21 and 29. However, a later or generic free-text box is not an adequate substitute for a direct opposition option within the relevant question. Many respondents may not realise that they need to use a later comment box to contradict an assumption built into an earlier question. Others may:
• Skip the technical question.
• Leave the ranking blank.
• Choose ‘Not sure’.
• Abandon the consultation.
• Fail to locate a later comment box.
• Assume that their objection cannot be recorded.
Free-text responses may also be analysed separately from tick-box, ranking or numerical results. Respondents should not be required to repair defective question design themselves.
6. Skipped Answers Do Not Represent Consent or Neutrality
Leaving a question unanswered does not reliably record opposition. A blank answer could be classified as:
• Uncertainty
• Lack of knowledge
• Unwillingness to answer
• Survey abandonment
• Technical failure
• Accessibility difficulty
• Missing data
It must not be treated as:
• Support
• Neutrality
• Acceptance
• Lack of concern
• Evidence that the respondent had no objection
Similarly, ‘Not sure’ must not be treated as support or acquiescence where a clear opposition option was unavailable.
7. Questions That Are Leading or Presuppositional
Question 2
Question 2 describes challenges affecting the UK television-production ecosystem and asks what measures would be most effective for the Government to take. It does not first ask whether additional government intervention is necessary, proportionate, effective, desirable or supported by the respondent. A neutral sequence would first ask whether respondents support government intervention and then ask supporters which measures they prefer.
Question 4
Question 4 asks whether ‘trustworthy’ news should be more visible on social media. Many people may support the broad aspiration of accurate information being easy to find while opposing:
• Legislation compelling platforms to alter rankings
• Government-backed eligibility criteria
• Regulator-backed content preference
• Privileged algorithmic placement
• Insertion into recommendation feeds
• Approved-provider lists
• Reduced visibility for other lawful content
A ‘Yes’ answer to Question 4 must not be treated as consent to a statutory prominence regime because the question does not ask whether respondents support that particular mechanism.
Question 4a
Question 4a asks how respondents would like ‘trustworthy’ news to be made easier to access. This assumes that selected news should receive some form of preferential treatment, even though a respondent may have answered ‘No’ to Question 4. Unless this question is automatically hidden following a ‘No’ response, it should expressly allow respondents to state that government-backed prominence should not be introduced.
Question 15
Question 15 asks whether respondents have evidence that another switch-off timeframe would be preferable. It does not expressly invite:
• No switch-off date
• Indefinite retention of DTT
• Permanent retention of DTT
• Long-term hybrid provision
• No switch-off unless specified conditions are satisfied
• Rejection of switch-off altogether
‘Another timeframe’ is not equivalent to opposing the underlying transition.
Question 19
Question 19 does invite evidence about equipment and infrastructure impacts, including set-top boxes and connected televisions. The problem is that it frames the environmental assessment around two transition scenarios — transition in 2034, or DTT switch-off in 2044 — and does not present:
• Continued DTT
• Long-term hybrid provision
• No fixed switch-off
• Retention of DTT as a resilient public service
as equal environmental comparison scenarios. Without a continued-DTT baseline, the question does not permit a balanced comparison between transition and non-transition options.
Question 23
Question 23 defines prominence as giving selected content a privileged position, including placement at the top of search results or in recommendation feeds. It then asks whether public service media content should be ‘easier to find’. Those are not necessarily equivalent. A person may support:
• Normal availability
• Accurate search results
• Clear labelling
• Access through an ordinary menu
• Public service media being searchable
• Access through existing applications
without supporting:
• Priority ranking
• Insertion into recommendation feeds
• Homepage privilege
• Displacement of competing lawful content
• Government-backed algorithmic favouring
The question risks confusing ordinary accessibility with preferential algorithmic placement.
Question 23a
Question 23a asks only about the benefits of making public service media easier to find. It does not equally invite discussion of:
• Disadvantages
• Risks
• Reduced user choice
• Market distortion
• Effects on independent creators
• Effects on smaller publishers
• Effects on local media
• Effects on specialist publications
• Effects on new entrants
• Political or institutional bias
• Objections to privileged placement
A balanced consultation must invite disadvantages and objections as clearly as benefits.
Question 23c
Question 23c asks on which platforms public service media should be easier to find. It does not expressly offer:
• No platforms
• Prominence should not be mandated
• Availability without privileged placement
• Ordinary searchability only
• No government intervention
A respondent may type an opposing answer because this is a free-text question, but its wording still assumes that preferential visibility should exist somewhere.
8. Some Questions Do Allow Opposition
For completeness, not every question is defective in the same way. Questions 4, 9, 11, 12, 13, 14, 16, 23, 23b, 25, 26 and 27 provide some form of ‘No’, disagreement, ‘none’, rejection or alternative answer. For example:
• Question 13 permits disagreement with the case for adopting IPTV.
• Question 14 includes ‘Neither 2034 nor 2044’.
• Question 23 permits disagreement or strong disagreement.
• Question 23b includes ‘None of the above’.
• Question 25 includes ‘None of the above’.
• Questions 26 and 27 permit disagreement.
The objection is therefore not that every consultation question excludes opposition. The objection is that several central questions concerning implementation, ranking and replacement models fail to record rejection of the underlying proposal, while other questions may generate apparent support through ambiguous, leading or presuppositional wording.
9. Concern About Misinformation Is Not Consent to Prominence
Questions 3, 7, 8 and 10 ask about matters including encounters with untrustworthy information, concern about misinformation, effects on society and democracy, the ability to assess information, and the importance of judging accuracy. A respondent may be deeply concerned about misinformation and strongly support media literacy while also opposing:
• Government-backed content ranking
• Privileged algorithmic treatment for selected providers
• State-influenced recommendation systems
• Regulatory classification of approved news sources
• Government-created eligibility systems
• Reduced visibility for lawful alternative viewpoints
Answers showing concern about misinformation must not be interpreted as support for government-backed prominence. The final analysis must distinguish between:
• Concern about misinformation
• Support for education and media literacy
• Support for government intervention
• Support for mandated prominence
• Support for particular eligibility criteria
• Support for a particular enforcement system
These are separate issues. Support for accurate information is not consent to state-influenced content ranking.
10. Core Objection to Government-Backed Algorithmic Privilege
The central objection should be tested directly: government-backed or regulator-backed algorithmic privilege should not be given to selected providers at the expense of user choice, independent creators, smaller publishers, local media, ordinary users, new entrants or lawful alternative viewpoints.
Prominence may affect:
• Search-result rankings
• Recommendation feeds
• Homepages
• Platform interfaces
• Content menus
• Application placement
• Other algorithmically controlled areas
This is not simply about keeping public service media or selected news providers available. It may involve requiring platforms to push, rank, recommend, highlight, prioritise or place selected providers above other lawful sources. The consultation must distinguish clearly between:
• Availability
• Searchability
• Labelling
• Promotion
• Privileged placement
• Top-ranking placement
• Homepage preference
• Insertion into personalised recommendations
Public service media can remain available and searchable without necessarily being inserted into recommendation feeds or placed above other lawful content.
11. The Definition of a ‘Trustworthy News Provider’ Remains Unresolved
The Government has not yet determined the final criteria for identifying a ‘trustworthy news provider’. The Green Paper discusses possible criteria, including the recognised news publisher definition in the Online Safety Act, editorial standards, complaints arrangements, transparency requirements and additional responsibilities. However, fundamental questions remain unresolved:
• Who will decide which providers qualify?
• Will the decision be made by ministers, a regulator, an independent body, or platforms themselves?
• What statutory test will apply, and will there be an approved list?
• Will the evidence and decisions be published?
• Will rejected providers have a right of appeal, and will there be independent judicial or regulatory review?
• How will political, institutional and regulatory bias be prevented?
• How will local, independent and specialist publishers qualify and compete with established organisations?
• How will lawful dissenting viewpoints be protected, and how will new entrants enter the system?
• Could a future government alter the criteria for political purposes?
• What prevents a prominence regime becoming a system for controlling visibility?
It would be inaccurate to claim as an established fact that mainstream media organisations themselves will make the final decision. The accurate concern is that the Government has not settled who will decide, what criteria will apply, what appeal system will exist, or what safeguards will prevent political, regulatory or institutional bias. Respondents should not be asked to support prominence before a sufficiently detailed governance and appeal system has been presented.
12. These Concerns Have Already Been Raised in Parliament
During the House of Commons debate on the Green Paper on 24 June 2026, MPs raised questions about who would decide what constitutes trustworthy news, whether an approved list would be created, how dissenting publishers would be treated, whether publishers might be required to join a recognised regulator, and how free expression and media plurality would be protected.
The Secretary of State acknowledged that deciding who defines trustworthy news and how trustworthiness is determined is one of the most challenging parts of the consultation. This makes it especially important that the questionnaire does not generate apparent consent through questions that fail to offer clear opposition options.
13. Digital Terrestrial Television and IPTV
The Green Paper states that the Government considers a managed transition away from DTT to be inevitable and describes the policy choice as being between transition timelines. That wording risks suggesting that the underlying decision has already been made. Although Questions 13 and 14 permit disagreement, and Question 14 includes ‘Neither 2034 nor 2044’, later questions again proceed from the premise of a transition.
A consultation should take place while policy remains genuinely formative. It should not merely invite the public to comment on how or when to implement a decision already described as inevitable. Respondents must be able to state that no fixed switch-off date should be adopted unless the Government first demonstrates:
• Universal access and affordable broadband suitable for television
• Reliable rural and remote coverage
• Emergency resilience, including continued access during broadband and power failures
• Accessibility for disabled people and protection for older people and low-income households
• Support for people unable to operate internet-connected devices, and protection against digital exclusion
• Suitable and affordable equipment, and adequate technical support
• Consumer protection and privacy and data safeguards
• Environmental sustainability, with no forced purchase of smart televisions or streaming equipment
• No loss of service for households that depend on Freeview
The questionnaire should include an explicit answer stating: ‘No DTT switch-off should take place unless and until these conditions have been independently demonstrated.’ It should also allow respondents to support permanent or long-term retention of DTT as a resilient public service.
14. Complexity and Insufficient Explanation
The principal Green Paper is 94 pages long. An Easy Read version was added on 10 July 2026, after the consultation had opened. That Easy Read document is itself 81 pages long, and the GOV.UK page warns that it may not be suitable for users of assistive technology. The existence of an Easy Read document is welcome, but it does not establish that the live questionnaire provides short, neutral and understandable explanations at the point each answer is requested.
The Green Paper contains definitions of terms such as IPTV, DTT, prominence, public service media and discoverability, but those definitions are dispersed through a lengthy and technical document. Many respondents will not have specialist knowledge of media regulation, broadcasting technology, algorithmic ranking, recommendation systems, public service media structures, online-platform regulation, broadcast licences, or television-distribution infrastructure.
Without concise and neutral explanations at the point of answering, respondents may:
• Misunderstand what a question is asking, or answer without understanding the practical consequences.
• Confuse normal availability with privileged prominence.
• Fail to recognise that a question concerns government-backed algorithmic prioritisation.
• Overlook the implications of DTT switch-off.
• Bypass questions that appear too technical.
• Select ‘Not sure’ despite holding a clear opposing view, or leave rankings incomplete.
• Provide answers that do not reflect their actual position.
• Abandon the consultation before reaching important sections.
15. Risk of Non-Response and Accessibility Bias
The length, technical complexity and insufficient point-of-answer explanation create a serious risk of non-response and accessibility bias. People who are comfortable with specialist policy and technical language are more likely to complete the questionnaire fully. People who are less confident with that language may be more likely to skip difficult questions, choose ‘Not sure’, misunderstand answer options, fail to use free-text boxes, abandon the consultation, or never begin it.
This may disproportionately affect:
• Older people and disabled people
• People with cognitive or sensory impairments
• Digitally excluded and low-income households
• Rural users and people without reliable broadband
• People without specialist media knowledge
• People who depend most heavily on Freeview
These groups may also be among those most affected by the loss of DTT, dependence on broadband, equipment costs, unfamiliar television interfaces, accessibility barriers, emergency resilience problems, poor rural connectivity, and changes to the way news is ranked and displayed. The consultation cannot be considered representative if the people most affected are also among those least able to complete it.
16. What Each Section Should Explain
Each major questionnaire section should begin with a short and neutral explanation of:
• The current system
• What the Government proposes to change
• How the change may affect an ordinary viewer or internet user
• Possible benefits
• Possible disadvantages and risks
• Reasonable alternatives
• What remains undecided
• The option to oppose the proposal entirely
The Government’s claimed benefits should not be presented without equivalent explanation of risks, objections, alternatives, costs, unintended consequences, and potential effects on rights and competition.
17. The Live Questionnaire Should Make Its Operation Clear
DCMS should publish or confirm:
• The complete list of questions before respondents begin, and which questions are mandatory.
• The complete survey-routing logic, and whether ranking questions can be left blank.
• The estimated completion time and whether there is a progress indicator.
• Whether respondents can save and return, review answers, and amend answers before submission.
• Whether answers can be amended after submission.
• Whether supporting links return users to the same place.
• Whether a printable questionnaire and an accessible version suitable for assistive technology are available.
• Whether all versions allow opposition to be expressed in equivalent terms.
A consultation cannot reliably test public opinion where important questions are so technical, lengthy or insufficiently explained that many people may bypass them without understanding what is at stake.
18. Cabinet Office Consultation Principles
The Cabinet Office Consultation Principles state that consultations should:
• Be clear and concise, and use plain English.
• Avoid unnecessary acronyms.
• Be informative.
• Make it easy for people to contribute.
• Provide sufficient information for informed responses.
• Concern matters that remain genuinely undecided.
Questions that do not contain answers matching a respondent’s actual position damage both participation and data quality. Ranking possible IPTV protections does not demonstrate support for IPTV. Ranking three public service media models and a combination does not demonstrate support for replacing the existing system. Selecting a preferred form of prominence does not demonstrate support for prominence itself. Expressing concern about misinformation does not demonstrate support for government-backed ranking. The final report must not treat any of these answers as endorsement of the underlying premise.
19. Privacy, Disability Information and Artificial-Intelligence Analysis
Respondents should not feel required to disclose receipt of Personal Independence Payment, a medical diagnosis, a mental-health condition, detailed health history, or other identifying personal information merely to demonstrate that they understand or are capable of completing the consultation.
Health or disability information is relevant only where it provides evidence of equality impacts, such as difficulty operating internet-connected television services, dependence on accessible Freeview equipment, inability to afford broadband, cognitive or sensory barriers, problems with applications, passwords or streaming devices, increased dependence on carers or relatives, loss of familiar interfaces, access to emergency information, rural connectivity, or inability to resolve technical failures.
The consultation privacy notice states that:
• Demographic information is optional.
• Identifying data should not be entered into free-text boxes, and identifying information submitted in free text cannot later be removed.
• Personal data may be retained for five years.
• Data will be shared with a third-party provider and with the Department for Science, Innovation and Technology for analysis.
• Artificial intelligence will be used to identify themes, and human researchers will review AI outputs.
• Data may be transferred or stored outside the UK subject to stated safeguards.
These matters should be displayed prominently within the questionnaire before respondents enter free-text information, and should not be left solely in a separate privacy notice. DCMS should also explain what AI system will be used, what data will be entered into it, whether responses will be anonymised first, whether data will be used for model training, how AI-generated themes will be checked, what bias testing will be performed, how minority and dissenting views will be protected, how quality control will operate, and how respondents can challenge inaccurate categorisation.
20. Existing Responses Must Be Preserved but Not Misrepresented
Existing consultation responses should not simply be discarded. DCMS should:
• Preserve all existing responses.
• Record which version of the questionnaire each person completed.
• Allow previous respondents to amend or replace their answers.
• Identify questions affected by defective answer options.
• Avoid interpreting forced rankings, ‘Not sure’ or skipped questions as support or consent.
• Keep results from materially different questionnaire versions separate.
• Publish a transparent explanation of how affected data will be analysed.
People who already took part should not be disadvantaged because the questionnaire was later corrected.
21. Petition Signatures Are Supporting Evidence, Not Consultation Responses
This petition demonstrates collective concern about the fairness and reliability of the consultation process. However, petition signatures are not substitutes for individual consultation responses. DCMS should consider the petition, its stated demand, the verified number of signatures at the time of submission, and the supporting evidence about question design, alongside direct consultation submissions.
The private contact information of signatories should not be disclosed to DCMS without proper notice, consent and a lawful basis.
22. Our Full Demand
We call on the Department for Culture, Media and Sport to:
• Pause reliance on and analysis of the existing questionnaire until the identified defects have been addressed.
• Revise Questions 5, 6, 17, 18 and 28 so that each provides an explicit way to reject the underlying proposal.
• Add clear options including ‘I oppose this proposal’, ‘none of these’, ‘not applicable’, ‘retain the current system’, and ‘other, with an explanation’.
• Revise Questions 2, 4, 4a, 15, 19, 23, 23a and 23c so that they distinguish broad aspirations from the proposed government intervention and invite disadvantages and opposition as clearly as benefits and support.
• Confirm that a ‘Yes’ answer to Question 4 will not be treated as consent to government-mandated algorithmic prominence.
• Confirm that concern about misinformation or support for media literacy will not be treated as consent to prominence.
• Confirm that support for protective measures in Question 18 will not be treated as support for an IPTV transition.
• Confirm that forced rankings, ‘Not sure’, skipped questions and unanswered questions will not be treated as evidence of support, neutrality or lack of concern.
• Publish the complete Qualtrics routing and validation logic, including which questions are shown after a respondent rejects an earlier proposal and whether ranking questions are mandatory.
• Clearly distinguish availability, searchability, labelling, promotion, priority ranking, homepage privilege, and insertion into recommendation feeds.
• Publish a detailed governance model explaining who would decide which news providers qualify, what criteria and evidence would apply, what transparency requirements and appeal rights would exist, and how political, institutional and regulatory bias would be prevented.
• Provide safeguards for independent creators, smaller publishers, local media, specialist publications, new entrants, ordinary users, and lawful alternative and dissenting viewpoints.
• Add an express option to retain DTT indefinitely or until independently verified access, affordability, accessibility, environmental and resilience conditions have been met.
• Include continued DTT and long-term hybrid provision as environmental comparison scenarios in Question 19.
• Rewrite the questionnaire in plain English, with short and neutral explanations at the point of answering.
• Explain equally the possible benefits, risks, disadvantages and alternatives associated with each major proposal.
• Make the Easy Read version prominent before respondents begin.
• Provide an accessible alternative suitable for assistive technology and confirm that it allows opposition to be expressed in terms equivalent to the main questionnaire.
• Publish a complete list of all questions before respondents begin the survey.
• Confirm whether respondents can save and return, review answers, amend answers before submission, and amend or replace answers after submission.
• Publish survey completion rates, skipped-question rates and the points at which respondents abandon the questionnaire.
• Conduct an independent accessibility and comprehension review involving older people, disabled people, digitally excluded households, low-income households, rural users, and people without specialist media or technology knowledge.
• Make privacy and AI-analysis information prominent within the questionnaire.
• Explain the AI system, anonymisation process, quality controls, bias checks and protection of minority and dissenting responses.
• Preserve all responses already submitted but record clearly which version of the questionnaire each respondent completed.
• Allow previous respondents to amend or replace their answers after revision.
• Not combine results from materially different questionnaire versions without a transparent methodological explanation.
• Accept this petition and its verified signature total as collective supporting evidence, while recognising that signatures are not individual consultation responses.
• Reopen or extend the consultation for a full and reasonable response period after the revised questionnaire is published.
• Publish an independent methodological assessment explaining how the revised consultation complies with the Cabinet Office Consultation Principles.
• Confirm that no final policy decision will be taken until corrected responses have been received and properly analysed.
23. Call to Action
This consultation concerns freedom of expression, media plurality, public access to information, user choice, digital exclusion, emergency resilience and the future availability of free-to-air television. Citizens must be able to record not only which implementation option they prefer, but whether they reject the intervention altogether. The proposals must also be explained clearly enough for ordinary members of the public to understand what they are being asked to support or oppose.
Government consultation should test informed public opinion. It should not:
• Confine responses within assumptions built into the questions.
• Interpret concern about misinformation as consent to government intervention.
• Treat rankings as support for policies respondents reject.
• Treat skipped questions as neutrality.
• Disadvantage people through technical language and unnecessary complexity.
• Rely on inaccessible or incomplete participation as evidence of public approval.
Take All Three Actions
• Sign the petition.
• Respond directly to the consultation.
• Contact your constituency MP and ask them to intervene.
Signing the petition alone does not place an individual response into the official consultation evidence.
24. Official Consultation and Reference Links
Official consultation and documents: GOV.UK – Watch this space consultation
Find and contact your MP: members.parliament.uk – Find your MP
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The Issue
Report on Defects in Consultation Design and Requested Corrective Action
Date: 12 July 2026
Status: For submission / signature
Addressed to: Secretary of State for Culture, Media and Sport; Minister responsible for Creative Industries, Media and Arts; Department for Culture, Media and Sport
Purpose and Scope
This report sets out the case for DCMS to pause reliance on and analysis of the current ‘Watch this space’ consultation questionnaire, to correct identified defects in question design and accessibility, and to reopen or extend the consultation for a full response period following revision. It covers the questionnaire’s treatment of opposition options, routing transparency, leading or presuppositional wording, accessibility risk, privacy and AI-analysis matters, and the full set of corrective actions requested.
Executive Summary
The Department for Culture, Media and Sport’s ‘Watch this space’ consultation could influence how news is ranked online, the future of Freeview and digital terrestrial television, and the structure of public service media.
These are major decisions affecting freedom of expression, media plurality, viewer choice, digital exclusion, accessibility and emergency resilience.
However, the questionnaire does not consistently allow respondents to express their actual position. Some answer structures assume that a proposal should proceed rather than providing an equally clear way to reject it, select none of the available options, or retain the present system.
Some wording also risks confusing support for broad objectives — such as accurate information, accessible services or protections for vulnerable people — with consent to a particular form of government intervention.
The consultation is lengthy and technically complex. Important definitions and explanations are dispersed through extensive supporting documents rather than consistently provided in short, neutral language at the point each answer is requested. This may cause people to misunderstand questions, skip them, select ‘Not sure’ despite holding a clear view, or abandon the consultation.
The questionnaire’s routing, mandatory-answer rules and treatment of rankings, skipped answers and ‘Not sure’ responses are also insufficiently transparent. This creates a risk that the results will not accurately represent public opinion and that older people, disabled people, digitally excluded households and people without specialist knowledge will be disproportionately excluded or misrepresented.
We therefore ask DCMS to pause reliance on and analysis of the current questionnaire, correct the identified defects, improve its accessibility and transparency, allow existing respondents to amend or replace their answers, and reopen or extend the consultation for a full response period after revision.
A government consultation must record what citizens actually think — including whether they reject a proposed intervention altogether.
1. Overview
The ‘Watch this space’ consultation closes on 31 August 2026, but parts of the questionnaire do not allow citizens to record clear opposition to the proposals being discussed.
• Questions 5 and 6 ask how a ‘trustworthy news’ prominence regime should operate, but provide no direct option to reject government-backed preferential ranking.
• Questions 17 and 18 ask people to rank matters connected with a transition to internet-delivered television, without an explicit ‘I oppose the transition’, ‘retain DTT’ or ‘not applicable’ option.
• Question 28 asks respondents to rank three replacement models and a combination of them, but does not offer ‘retain the present system’ or ‘none of these’.
• Other questions risk confusing broad support for accurate information or easier access with consent to government-mandated algorithmic privilege.
Concern about misinformation is not consent for selected providers to be favoured in search results, recommendation feeds, homepages or platform interfaces.
The consultation is also long and technically complex. Definitions exist in the Green Paper, but they are dispersed and may not be available in clear, neutral language at the point each answer is requested.
Respondents may therefore skip important questions, choose ‘Not sure’ despite holding an opposing view, or abandon the survey. This risks non-response and accessibility bias, particularly affecting older people, disabled people, digitally excluded households and respondents without specialist knowledge.
Requested Action
We call on DCMS to:
• Pause reliance on and analysis of the current questionnaire.
• Add direct opposition, ‘none’ and ‘not applicable’ options.
• Rewrite leading or presuppositional questions.
• Publish the survey-routing and mandatory-answer rules.
• Explain technical terms, benefits, risks and alternatives at the point of answering.
• Preserve existing responses while allowing respondents to amend or replace them.
• Ensure rankings, skipped answers and ‘Not sure’ responses are not treated as support.
• Provide accessible versions suitable for assistive technology.
• Reopen or extend the consultation for a full response period after revision.
Signing the associated petition does not replace responding directly to the consultation. Respondents are also encouraged to submit their views to DCMS and contact their MP.
2. Why This Report Is Necessary
The consultation contains 30 numbered questions and 12 lettered follow-up questions. It concerns:
• Freedom of expression
• Media plurality
• Government influence over online content ranking
• The future of Freeview and digital terrestrial television
• Public service media
• User choice
• Digital exclusion
• Emergency resilience
• Disability access
• Privacy
• The use of artificial intelligence to analyse consultation responses
A consultation dealing with issues of this importance must allow people to express their actual views accurately. It must not:
• Require respondents to choose between different versions of a policy they oppose.
• Interpret concern about misinformation as support for government-backed content ranking.
• Exclude or disadvantage people through technical language, excessive length or inadequate explanation.
3. Questions That Do Not Provide a Clear Opposition Option
Question 5
Question 5 asks whether prominence for selected ‘trustworthy’ news providers should be:
• Ongoing and always active
• Active only during periods of heightened vulnerability
• ‘Not sure’
Both substantive options assume that a government-backed prominence system will be introduced. There is no option allowing a respondent to state that:
• Prominence measures should not be introduced.
• Platforms should not be required to alter rankings, recommendations or feeds.
• Selected providers should not receive government-backed preferential placement.
• Users should determine what lawful content they see without state-influenced prioritisation.
• Lawful news and opinion should compete without government-created algorithmic privilege.
‘Not sure’ cannot represent the position of someone who clearly opposes the proposal.
Question 6
Question 6 asks whether users should be able to switch prominence measures on or off. A ‘Yes’ answer assumes that the prominence regime should exist but be optional; a ‘No’ answer assumes that the regime should exist and should not be optional. Neither option allows respondents to state that no government-backed prominence regime should be created in the first place. Again, ‘Not sure’ is not a substitute for a direct opposition option.
Question 17
Question 17 asks which, if any, of four challenges relating to an IPTV transition are most important and directs respondents to rank them. Although the words ‘which, if any’ appear in the question, there is no explicit answer stating:
• I oppose an IPTV transition
• DTT should be retained
• No transition should be planned
• None of these
• Not applicable
• I reject the premise of the question
It is also not clear from the publicly available question list whether respondents can leave the entire ranking blank. If this question is shown to people who have already opposed an IPTV transition, asking them to rank transition considerations risks making their answers appear to accept the transition.
Question 18
Question 18 begins: ‘In the event of an IPTV transition…’ and then asks respondents to rank possible support measures. Although it says ‘which of the following, if any’, it does not provide an explicit:
• None
• Not applicable
• I oppose the transition
• Retain DTT
• No transition should take place
option. Support for affordable broadband, accessible equipment or assistance for older and disabled people must not be interpreted as support for switching off DTT. A respondent may believe that those protections would be essential if a transition occurred while still opposing the transition itself.
Question 28
Question 28 presents three illustrative replacement models and a fourth option combining those models, and asks respondents to rank their preferred model. It does not provide:
• Retain the existing system
• No reform
• None of these
• Another model
• Not applicable
• I reject the premise that one of these models should be adopted
A respondent who opposes all three models and their combination is therefore not given an answer that accurately records that position.
4. Conditional Survey Routing Must Be Published
The public version of the consultation lists the questions but does not show the conditional routing used in the live Qualtrics survey. It is therefore unclear from the published material whether:
• Questions 4a, 5 and 6 are shown after a respondent answers ‘No’ to Question 4.
• Questions 17 and 18 are shown after a respondent rejects an IPTV transition.
• Question 28 is shown after a respondent opposes reform of the existing public service media system.
• Ranking questions may be left wholly unanswered.
• Respondents must answer particular questions before continuing.
• Different respondents see different follow-up questions depending on earlier answers.
If these questions are shown only to people who have already supported the relevant proposal, DCMS should publish that routing clearly. If they are shown to people who have rejected the proposal, the questions must contain direct ‘I oppose this proposal’, ‘none’, ‘not applicable’ and ‘retain the present system’ options.
5. Free Text Does Not Correct Defective Answer Options
The consultation includes broad free-text questions, including Questions 20, 21 and 29. However, a later or generic free-text box is not an adequate substitute for a direct opposition option within the relevant question. Many respondents may not realise that they need to use a later comment box to contradict an assumption built into an earlier question. Others may:
• Skip the technical question.
• Leave the ranking blank.
• Choose ‘Not sure’.
• Abandon the consultation.
• Fail to locate a later comment box.
• Assume that their objection cannot be recorded.
Free-text responses may also be analysed separately from tick-box, ranking or numerical results. Respondents should not be required to repair defective question design themselves.
6. Skipped Answers Do Not Represent Consent or Neutrality
Leaving a question unanswered does not reliably record opposition. A blank answer could be classified as:
• Uncertainty
• Lack of knowledge
• Unwillingness to answer
• Survey abandonment
• Technical failure
• Accessibility difficulty
• Missing data
It must not be treated as:
• Support
• Neutrality
• Acceptance
• Lack of concern
• Evidence that the respondent had no objection
Similarly, ‘Not sure’ must not be treated as support or acquiescence where a clear opposition option was unavailable.
7. Questions That Are Leading or Presuppositional
Question 2
Question 2 describes challenges affecting the UK television-production ecosystem and asks what measures would be most effective for the Government to take. It does not first ask whether additional government intervention is necessary, proportionate, effective, desirable or supported by the respondent. A neutral sequence would first ask whether respondents support government intervention and then ask supporters which measures they prefer.
Question 4
Question 4 asks whether ‘trustworthy’ news should be more visible on social media. Many people may support the broad aspiration of accurate information being easy to find while opposing:
• Legislation compelling platforms to alter rankings
• Government-backed eligibility criteria
• Regulator-backed content preference
• Privileged algorithmic placement
• Insertion into recommendation feeds
• Approved-provider lists
• Reduced visibility for other lawful content
A ‘Yes’ answer to Question 4 must not be treated as consent to a statutory prominence regime because the question does not ask whether respondents support that particular mechanism.
Question 4a
Question 4a asks how respondents would like ‘trustworthy’ news to be made easier to access. This assumes that selected news should receive some form of preferential treatment, even though a respondent may have answered ‘No’ to Question 4. Unless this question is automatically hidden following a ‘No’ response, it should expressly allow respondents to state that government-backed prominence should not be introduced.
Question 15
Question 15 asks whether respondents have evidence that another switch-off timeframe would be preferable. It does not expressly invite:
• No switch-off date
• Indefinite retention of DTT
• Permanent retention of DTT
• Long-term hybrid provision
• No switch-off unless specified conditions are satisfied
• Rejection of switch-off altogether
‘Another timeframe’ is not equivalent to opposing the underlying transition.
Question 19
Question 19 does invite evidence about equipment and infrastructure impacts, including set-top boxes and connected televisions. The problem is that it frames the environmental assessment around two transition scenarios — transition in 2034, or DTT switch-off in 2044 — and does not present:
• Continued DTT
• Long-term hybrid provision
• No fixed switch-off
• Retention of DTT as a resilient public service
as equal environmental comparison scenarios. Without a continued-DTT baseline, the question does not permit a balanced comparison between transition and non-transition options.
Question 23
Question 23 defines prominence as giving selected content a privileged position, including placement at the top of search results or in recommendation feeds. It then asks whether public service media content should be ‘easier to find’. Those are not necessarily equivalent. A person may support:
• Normal availability
• Accurate search results
• Clear labelling
• Access through an ordinary menu
• Public service media being searchable
• Access through existing applications
without supporting:
• Priority ranking
• Insertion into recommendation feeds
• Homepage privilege
• Displacement of competing lawful content
• Government-backed algorithmic favouring
The question risks confusing ordinary accessibility with preferential algorithmic placement.
Question 23a
Question 23a asks only about the benefits of making public service media easier to find. It does not equally invite discussion of:
• Disadvantages
• Risks
• Reduced user choice
• Market distortion
• Effects on independent creators
• Effects on smaller publishers
• Effects on local media
• Effects on specialist publications
• Effects on new entrants
• Political or institutional bias
• Objections to privileged placement
A balanced consultation must invite disadvantages and objections as clearly as benefits.
Question 23c
Question 23c asks on which platforms public service media should be easier to find. It does not expressly offer:
• No platforms
• Prominence should not be mandated
• Availability without privileged placement
• Ordinary searchability only
• No government intervention
A respondent may type an opposing answer because this is a free-text question, but its wording still assumes that preferential visibility should exist somewhere.
8. Some Questions Do Allow Opposition
For completeness, not every question is defective in the same way. Questions 4, 9, 11, 12, 13, 14, 16, 23, 23b, 25, 26 and 27 provide some form of ‘No’, disagreement, ‘none’, rejection or alternative answer. For example:
• Question 13 permits disagreement with the case for adopting IPTV.
• Question 14 includes ‘Neither 2034 nor 2044’.
• Question 23 permits disagreement or strong disagreement.
• Question 23b includes ‘None of the above’.
• Question 25 includes ‘None of the above’.
• Questions 26 and 27 permit disagreement.
The objection is therefore not that every consultation question excludes opposition. The objection is that several central questions concerning implementation, ranking and replacement models fail to record rejection of the underlying proposal, while other questions may generate apparent support through ambiguous, leading or presuppositional wording.
9. Concern About Misinformation Is Not Consent to Prominence
Questions 3, 7, 8 and 10 ask about matters including encounters with untrustworthy information, concern about misinformation, effects on society and democracy, the ability to assess information, and the importance of judging accuracy. A respondent may be deeply concerned about misinformation and strongly support media literacy while also opposing:
• Government-backed content ranking
• Privileged algorithmic treatment for selected providers
• State-influenced recommendation systems
• Regulatory classification of approved news sources
• Government-created eligibility systems
• Reduced visibility for lawful alternative viewpoints
Answers showing concern about misinformation must not be interpreted as support for government-backed prominence. The final analysis must distinguish between:
• Concern about misinformation
• Support for education and media literacy
• Support for government intervention
• Support for mandated prominence
• Support for particular eligibility criteria
• Support for a particular enforcement system
These are separate issues. Support for accurate information is not consent to state-influenced content ranking.
10. Core Objection to Government-Backed Algorithmic Privilege
The central objection should be tested directly: government-backed or regulator-backed algorithmic privilege should not be given to selected providers at the expense of user choice, independent creators, smaller publishers, local media, ordinary users, new entrants or lawful alternative viewpoints.
Prominence may affect:
• Search-result rankings
• Recommendation feeds
• Homepages
• Platform interfaces
• Content menus
• Application placement
• Other algorithmically controlled areas
This is not simply about keeping public service media or selected news providers available. It may involve requiring platforms to push, rank, recommend, highlight, prioritise or place selected providers above other lawful sources. The consultation must distinguish clearly between:
• Availability
• Searchability
• Labelling
• Promotion
• Privileged placement
• Top-ranking placement
• Homepage preference
• Insertion into personalised recommendations
Public service media can remain available and searchable without necessarily being inserted into recommendation feeds or placed above other lawful content.
11. The Definition of a ‘Trustworthy News Provider’ Remains Unresolved
The Government has not yet determined the final criteria for identifying a ‘trustworthy news provider’. The Green Paper discusses possible criteria, including the recognised news publisher definition in the Online Safety Act, editorial standards, complaints arrangements, transparency requirements and additional responsibilities. However, fundamental questions remain unresolved:
• Who will decide which providers qualify?
• Will the decision be made by ministers, a regulator, an independent body, or platforms themselves?
• What statutory test will apply, and will there be an approved list?
• Will the evidence and decisions be published?
• Will rejected providers have a right of appeal, and will there be independent judicial or regulatory review?
• How will political, institutional and regulatory bias be prevented?
• How will local, independent and specialist publishers qualify and compete with established organisations?
• How will lawful dissenting viewpoints be protected, and how will new entrants enter the system?
• Could a future government alter the criteria for political purposes?
• What prevents a prominence regime becoming a system for controlling visibility?
It would be inaccurate to claim as an established fact that mainstream media organisations themselves will make the final decision. The accurate concern is that the Government has not settled who will decide, what criteria will apply, what appeal system will exist, or what safeguards will prevent political, regulatory or institutional bias. Respondents should not be asked to support prominence before a sufficiently detailed governance and appeal system has been presented.
12. These Concerns Have Already Been Raised in Parliament
During the House of Commons debate on the Green Paper on 24 June 2026, MPs raised questions about who would decide what constitutes trustworthy news, whether an approved list would be created, how dissenting publishers would be treated, whether publishers might be required to join a recognised regulator, and how free expression and media plurality would be protected.
The Secretary of State acknowledged that deciding who defines trustworthy news and how trustworthiness is determined is one of the most challenging parts of the consultation. This makes it especially important that the questionnaire does not generate apparent consent through questions that fail to offer clear opposition options.
13. Digital Terrestrial Television and IPTV
The Green Paper states that the Government considers a managed transition away from DTT to be inevitable and describes the policy choice as being between transition timelines. That wording risks suggesting that the underlying decision has already been made. Although Questions 13 and 14 permit disagreement, and Question 14 includes ‘Neither 2034 nor 2044’, later questions again proceed from the premise of a transition.
A consultation should take place while policy remains genuinely formative. It should not merely invite the public to comment on how or when to implement a decision already described as inevitable. Respondents must be able to state that no fixed switch-off date should be adopted unless the Government first demonstrates:
• Universal access and affordable broadband suitable for television
• Reliable rural and remote coverage
• Emergency resilience, including continued access during broadband and power failures
• Accessibility for disabled people and protection for older people and low-income households
• Support for people unable to operate internet-connected devices, and protection against digital exclusion
• Suitable and affordable equipment, and adequate technical support
• Consumer protection and privacy and data safeguards
• Environmental sustainability, with no forced purchase of smart televisions or streaming equipment
• No loss of service for households that depend on Freeview
The questionnaire should include an explicit answer stating: ‘No DTT switch-off should take place unless and until these conditions have been independently demonstrated.’ It should also allow respondents to support permanent or long-term retention of DTT as a resilient public service.
14. Complexity and Insufficient Explanation
The principal Green Paper is 94 pages long. An Easy Read version was added on 10 July 2026, after the consultation had opened. That Easy Read document is itself 81 pages long, and the GOV.UK page warns that it may not be suitable for users of assistive technology. The existence of an Easy Read document is welcome, but it does not establish that the live questionnaire provides short, neutral and understandable explanations at the point each answer is requested.
The Green Paper contains definitions of terms such as IPTV, DTT, prominence, public service media and discoverability, but those definitions are dispersed through a lengthy and technical document. Many respondents will not have specialist knowledge of media regulation, broadcasting technology, algorithmic ranking, recommendation systems, public service media structures, online-platform regulation, broadcast licences, or television-distribution infrastructure.
Without concise and neutral explanations at the point of answering, respondents may:
• Misunderstand what a question is asking, or answer without understanding the practical consequences.
• Confuse normal availability with privileged prominence.
• Fail to recognise that a question concerns government-backed algorithmic prioritisation.
• Overlook the implications of DTT switch-off.
• Bypass questions that appear too technical.
• Select ‘Not sure’ despite holding a clear opposing view, or leave rankings incomplete.
• Provide answers that do not reflect their actual position.
• Abandon the consultation before reaching important sections.
15. Risk of Non-Response and Accessibility Bias
The length, technical complexity and insufficient point-of-answer explanation create a serious risk of non-response and accessibility bias. People who are comfortable with specialist policy and technical language are more likely to complete the questionnaire fully. People who are less confident with that language may be more likely to skip difficult questions, choose ‘Not sure’, misunderstand answer options, fail to use free-text boxes, abandon the consultation, or never begin it.
This may disproportionately affect:
• Older people and disabled people
• People with cognitive or sensory impairments
• Digitally excluded and low-income households
• Rural users and people without reliable broadband
• People without specialist media knowledge
• People who depend most heavily on Freeview
These groups may also be among those most affected by the loss of DTT, dependence on broadband, equipment costs, unfamiliar television interfaces, accessibility barriers, emergency resilience problems, poor rural connectivity, and changes to the way news is ranked and displayed. The consultation cannot be considered representative if the people most affected are also among those least able to complete it.
16. What Each Section Should Explain
Each major questionnaire section should begin with a short and neutral explanation of:
• The current system
• What the Government proposes to change
• How the change may affect an ordinary viewer or internet user
• Possible benefits
• Possible disadvantages and risks
• Reasonable alternatives
• What remains undecided
• The option to oppose the proposal entirely
The Government’s claimed benefits should not be presented without equivalent explanation of risks, objections, alternatives, costs, unintended consequences, and potential effects on rights and competition.
17. The Live Questionnaire Should Make Its Operation Clear
DCMS should publish or confirm:
• The complete list of questions before respondents begin, and which questions are mandatory.
• The complete survey-routing logic, and whether ranking questions can be left blank.
• The estimated completion time and whether there is a progress indicator.
• Whether respondents can save and return, review answers, and amend answers before submission.
• Whether answers can be amended after submission.
• Whether supporting links return users to the same place.
• Whether a printable questionnaire and an accessible version suitable for assistive technology are available.
• Whether all versions allow opposition to be expressed in equivalent terms.
A consultation cannot reliably test public opinion where important questions are so technical, lengthy or insufficiently explained that many people may bypass them without understanding what is at stake.
18. Cabinet Office Consultation Principles
The Cabinet Office Consultation Principles state that consultations should:
• Be clear and concise, and use plain English.
• Avoid unnecessary acronyms.
• Be informative.
• Make it easy for people to contribute.
• Provide sufficient information for informed responses.
• Concern matters that remain genuinely undecided.
Questions that do not contain answers matching a respondent’s actual position damage both participation and data quality. Ranking possible IPTV protections does not demonstrate support for IPTV. Ranking three public service media models and a combination does not demonstrate support for replacing the existing system. Selecting a preferred form of prominence does not demonstrate support for prominence itself. Expressing concern about misinformation does not demonstrate support for government-backed ranking. The final report must not treat any of these answers as endorsement of the underlying premise.
19. Privacy, Disability Information and Artificial-Intelligence Analysis
Respondents should not feel required to disclose receipt of Personal Independence Payment, a medical diagnosis, a mental-health condition, detailed health history, or other identifying personal information merely to demonstrate that they understand or are capable of completing the consultation.
Health or disability information is relevant only where it provides evidence of equality impacts, such as difficulty operating internet-connected television services, dependence on accessible Freeview equipment, inability to afford broadband, cognitive or sensory barriers, problems with applications, passwords or streaming devices, increased dependence on carers or relatives, loss of familiar interfaces, access to emergency information, rural connectivity, or inability to resolve technical failures.
The consultation privacy notice states that:
• Demographic information is optional.
• Identifying data should not be entered into free-text boxes, and identifying information submitted in free text cannot later be removed.
• Personal data may be retained for five years.
• Data will be shared with a third-party provider and with the Department for Science, Innovation and Technology for analysis.
• Artificial intelligence will be used to identify themes, and human researchers will review AI outputs.
• Data may be transferred or stored outside the UK subject to stated safeguards.
These matters should be displayed prominently within the questionnaire before respondents enter free-text information, and should not be left solely in a separate privacy notice. DCMS should also explain what AI system will be used, what data will be entered into it, whether responses will be anonymised first, whether data will be used for model training, how AI-generated themes will be checked, what bias testing will be performed, how minority and dissenting views will be protected, how quality control will operate, and how respondents can challenge inaccurate categorisation.
20. Existing Responses Must Be Preserved but Not Misrepresented
Existing consultation responses should not simply be discarded. DCMS should:
• Preserve all existing responses.
• Record which version of the questionnaire each person completed.
• Allow previous respondents to amend or replace their answers.
• Identify questions affected by defective answer options.
• Avoid interpreting forced rankings, ‘Not sure’ or skipped questions as support or consent.
• Keep results from materially different questionnaire versions separate.
• Publish a transparent explanation of how affected data will be analysed.
People who already took part should not be disadvantaged because the questionnaire was later corrected.
21. Petition Signatures Are Supporting Evidence, Not Consultation Responses
This petition demonstrates collective concern about the fairness and reliability of the consultation process. However, petition signatures are not substitutes for individual consultation responses. DCMS should consider the petition, its stated demand, the verified number of signatures at the time of submission, and the supporting evidence about question design, alongside direct consultation submissions.
The private contact information of signatories should not be disclosed to DCMS without proper notice, consent and a lawful basis.
22. Our Full Demand
We call on the Department for Culture, Media and Sport to:
• Pause reliance on and analysis of the existing questionnaire until the identified defects have been addressed.
• Revise Questions 5, 6, 17, 18 and 28 so that each provides an explicit way to reject the underlying proposal.
• Add clear options including ‘I oppose this proposal’, ‘none of these’, ‘not applicable’, ‘retain the current system’, and ‘other, with an explanation’.
• Revise Questions 2, 4, 4a, 15, 19, 23, 23a and 23c so that they distinguish broad aspirations from the proposed government intervention and invite disadvantages and opposition as clearly as benefits and support.
• Confirm that a ‘Yes’ answer to Question 4 will not be treated as consent to government-mandated algorithmic prominence.
• Confirm that concern about misinformation or support for media literacy will not be treated as consent to prominence.
• Confirm that support for protective measures in Question 18 will not be treated as support for an IPTV transition.
• Confirm that forced rankings, ‘Not sure’, skipped questions and unanswered questions will not be treated as evidence of support, neutrality or lack of concern.
• Publish the complete Qualtrics routing and validation logic, including which questions are shown after a respondent rejects an earlier proposal and whether ranking questions are mandatory.
• Clearly distinguish availability, searchability, labelling, promotion, priority ranking, homepage privilege, and insertion into recommendation feeds.
• Publish a detailed governance model explaining who would decide which news providers qualify, what criteria and evidence would apply, what transparency requirements and appeal rights would exist, and how political, institutional and regulatory bias would be prevented.
• Provide safeguards for independent creators, smaller publishers, local media, specialist publications, new entrants, ordinary users, and lawful alternative and dissenting viewpoints.
• Add an express option to retain DTT indefinitely or until independently verified access, affordability, accessibility, environmental and resilience conditions have been met.
• Include continued DTT and long-term hybrid provision as environmental comparison scenarios in Question 19.
• Rewrite the questionnaire in plain English, with short and neutral explanations at the point of answering.
• Explain equally the possible benefits, risks, disadvantages and alternatives associated with each major proposal.
• Make the Easy Read version prominent before respondents begin.
• Provide an accessible alternative suitable for assistive technology and confirm that it allows opposition to be expressed in terms equivalent to the main questionnaire.
• Publish a complete list of all questions before respondents begin the survey.
• Confirm whether respondents can save and return, review answers, amend answers before submission, and amend or replace answers after submission.
• Publish survey completion rates, skipped-question rates and the points at which respondents abandon the questionnaire.
• Conduct an independent accessibility and comprehension review involving older people, disabled people, digitally excluded households, low-income households, rural users, and people without specialist media or technology knowledge.
• Make privacy and AI-analysis information prominent within the questionnaire.
• Explain the AI system, anonymisation process, quality controls, bias checks and protection of minority and dissenting responses.
• Preserve all responses already submitted but record clearly which version of the questionnaire each respondent completed.
• Allow previous respondents to amend or replace their answers after revision.
• Not combine results from materially different questionnaire versions without a transparent methodological explanation.
• Accept this petition and its verified signature total as collective supporting evidence, while recognising that signatures are not individual consultation responses.
• Reopen or extend the consultation for a full and reasonable response period after the revised questionnaire is published.
• Publish an independent methodological assessment explaining how the revised consultation complies with the Cabinet Office Consultation Principles.
• Confirm that no final policy decision will be taken until corrected responses have been received and properly analysed.
23. Call to Action
This consultation concerns freedom of expression, media plurality, public access to information, user choice, digital exclusion, emergency resilience and the future availability of free-to-air television. Citizens must be able to record not only which implementation option they prefer, but whether they reject the intervention altogether. The proposals must also be explained clearly enough for ordinary members of the public to understand what they are being asked to support or oppose.
Government consultation should test informed public opinion. It should not:
• Confine responses within assumptions built into the questions.
• Interpret concern about misinformation as consent to government intervention.
• Treat rankings as support for policies respondents reject.
• Treat skipped questions as neutrality.
• Disadvantage people through technical language and unnecessary complexity.
• Rely on inaccessible or incomplete participation as evidence of public approval.
Take All Three Actions
• Sign the petition.
• Respond directly to the consultation.
• Contact your constituency MP and ask them to intervene.
Signing the petition alone does not place an individual response into the official consultation evidence.
24. Official Consultation and Reference Links
Official consultation and documents: GOV.UK – Watch this space consultation
Find and contact your MP: members.parliament.uk – Find your MP
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Petition created on 10 July 2026