VLV is concerned by the move to regulate the BBC according to the Broadcasting Code, because these changes will lead to a significant reduction in independent regulation of BBC content standards. The standards of the Broadcasting Code, as set out in Section 319 of the Communications Act, are far more limited than the existing Editorial Guidelines of the BBC which the BBC Trust has used to regulate the BBC and they will not apply to all content. Notably no online content will have independent scrutiny and Ofcom's regulation of the output of the World Service will be limited to one review a year.
While we understand the rationale of the proposal to devise a simpler approach to content regulation which applies equally across the broadcasting industry, we believe that public accountability regulation of the BBC should be distinct from regulation of other PSBs, because the public has different expectations of the BBC because they pay for it through the licence fee.
You can read the full submission here