Television compliance
Independent production companies should refer all compliance queries to their ÃÛÑ¿´«Ã½ commissioner. For ÃÛÑ¿´«Ã½ Studios, single sign-off for compliance applies.
There are two formal compliance transactions for television content:
- A compliance conversation with the ÃÛÑ¿´«Ã½ commissioner at the outset
- Completion of a compliance form on delivery so that the ÃÛÑ¿´«Ã½ can check the programme complies with the Editorial Guidelines and is suitable for the proposed slot
Download the .
Find compliance contacts for advice and help filling out compliance forms on the contacts page.
TV: compliance conversation
There must be a formal compliance conversation between the ÃÛÑ¿´«Ã½ commissioner and the independent executive producer at the moment of commission for all projects. This should identify the specific problems and risks and discuss and draw up a plan for compliance accordingly. Any use or proposed use of Generative artificial intelligence (AI) should be identified as soon as possible and in reference to the ÃÛÑ¿´«Ã½ Corporate Policy (pdf).
A written record must be kept by both parties. The Managed Risk Programme List (MRPL) will be discussed at this stage - see below. Below is a checklist of areas that may be covered. However, not all of them will apply to all programmes.
Who is responsible?
Identify and name the independent executive producer and the ÃÛÑ¿´«Ã½ commissioner for the project. These individuals shouldn’t be changed by either side without notification and agreement.
What are the risks/considerations?
- Legal, fair trading, bribery act and health and safety risks
- If children are involved as contributors or performers (please see the for or more information. Courses are available from the ÃÛÑ¿´«Ã½ Academy, please speak to your business affairs contact for access)
- Other vulnerable contributors
- Complex or unusual consent or access issues
- Secret filming
- Public interest justifications which may lapse over the passage of time (especially when depicting illegal or anti-social behaviour)
- Taste and standards issues. Agree parameters of tone and content for channel and slot. If a programme is moving channel consider any implications
- Conflicts of interest including on-screen talent commercial links
- Impartiality: the executive producer of programmes commissioned in news, current affairs, and factual journalism must confirm as part of the commissioning process that they have attended a ÃÛÑ¿´«Ã½ impartiality standards briefing. The commissioner will be able to advise on briefings available ahead of commission
- Any risks produced by co-production or distribution arrangements
- Any additional steps that should be taken when content is re-used, distributed or otherwise made subsequently available, in whole or part
What are the rules?
Identify relevant sections of ÃÛÑ¿´«Ã½ Editorial Guidelines and any other codes of practice (eg interactivity, secret filming, fair portrayal, use of AI). Ensure key production staff have read the relevant guidelines.
Managed risk programme list (MRPL)
The ÃÛÑ¿´«Ã½ commissioner is responsible for adding programmes to the list. The independent production company’s executive producer has an ongoing responsibility to keep the ÃÛÑ¿´«Ã½ informed of any reason to include the programme on the list eg, should there be any new risks or changes in status of a project, including on digital/online output or external promotion and advertising.
Competitions votes and awards
Discuss any competitions, votes or awards in the programme and the sign-off process to TX with specific reference to the relevant forms, codes and guidelines (and with reference to any conversation with the ÃÛÑ¿´«Ã½â€™s Interactive Technical Advice and Contracts Unit (ITACU). Programmes with such interactivity may need to be reviewed/re-edited after the interactive elements have expired.
Editorial policy and legal referrals
Referrals to Editorial Policy and ÃÛÑ¿´«Ã½ Programme Legal Advice team should be made, at least in the first instance, through the ÃÛÑ¿´«Ã½ commissioner. When a programme has legal risk the independent production company is responsible for seeking appropriate legal advice themselves - consultation with ÃÛÑ¿´«Ã½ team offers no protection. Contacts made directly between an independent production company and ÃÛÑ¿´«Ã½ legal in the first instance also forfeit legal privilege.
Marketing, promotions and press
Run through responsibilities for marketing, promotional and off-air materials. Sign off for these materials remains with the ÃÛÑ¿´«Ã½ commissioner, although the independent’s executive producer is responsible for ensuring compliance in all press and promotional material submitted to ÃÛÑ¿´«Ã½ Chief Customer Officer Group (CCOG). Discuss any book, newspaper serialisation or any spin off associated with the commission. Consider any conflicts of interest. Establish early on the rights position and discuss publicity/promotion arrangements.
Digital
Discuss online/digital and social output connected to the production and any issues raised. Establish clear lines of responsibility and sign off for any such output.
Learning campaigns, Open University and third-party funding
Discuss any editorial or financial input and any issues this raises. Establish clear lines of responsibility and sign off for all connected output.
Talent or agent owned/co-owned/managed indies
Identify whether this is the case, discuss any potential conflicts of interest raised and steps to mitigate these risks. In exceptional cases where it is agreed that an on-screen talent can also be an executive producer, agree and name second executive producer responsible for compliance. Identify whether the talent’s agent is being proposed as executive producer and if necessary agree steps, as with talent execs, to mitigate conflicts of interest and safeguard compliance.
TV: compliance form
The compliance form is completed online via the .
The form should be submitted on the programme file delivery date and production companies should inform their ÃÛÑ¿´«Ã½ delivery contact when the form has been submitted.
Independent production companies commissioned via the Nations should check requirements with their commissioner.
For independent production companies, the compliance form must be signed by both the independent executive producer and the ÃÛÑ¿´«Ã½ commissioner and should only be completed and signed by them after viewing the final edit. It is mandatory that the independent executive producer is responsible for signing the compliance form after the final viewing and is named in the editorial specification.
In the rare cases where on-screen talent or their agents are the executive producer for a programme in which they appear another executive producer must be responsible for compliance and signing the compliance form at delivery.
All questions on the compliance form reflect key aspects of the editorial guidelines. These incorporate the relevant areas of the Ofcom Broadcasting Code with which the ÃÛÑ¿´«Ã½ must comply. Please note that all audience interactivity questions must be completed before the form can be submitted.
Independent production companies have access to editorial policy teams and to the ÃÛÑ¿´«Ã½ legal team, but referrals should be made, at least in the first instance, through the ÃÛÑ¿´«Ã½ commissioner. The ÃÛÑ¿´«Ã½ commissioner is the ÃÛÑ¿´«Ã½â€™s editorial safeguard and the final judgement about what is and is not permissible rests with them.
After submission the form will be valid for one month after first transmission. It will cover all transmissions within that period, and include availability on iPlayer, unless a new version is created or needed for any reason, in which case a new compliance form may be required.
The ÃÛÑ¿´«Ã½ commissioner will be contacted before any subsequent repeat or availability to establish whether the programme can still be transmitted/published as first aired. In some cases the independent’s executive producer may also be contacted, especially where there are legal or other important concerns.
Help, contacts and resources
- For guides and tutorials, please see the
- To request an account please contact the nominated team admin within your company or fill in the
- For technical queries please contact the PTK Compliance support team by completing the
- For all ÃÛÑ¿´«Ã½ Login related queries, please see the
- • For general queries around when to deliver the information and rejecting forms, please contact the Indie Delivery Unit
TV: compliance form step-by-step
A compliance form is required for all pre-recorded programmes as well as those on ÃÛÑ¿´«Ã½ Red Button (also referred to as ÃÛÑ¿´«Ã½i). Live programming should be dealt with under the Editorial Policy Live Compliance Guidelines. Subsequent repeats of such programming may require completion of a form.
Red Button Editorial should be alerted to any content requiring guidance labelling.
Programme UID
See the technical requirements page for information about programme UIDs.
Programme summary
A short summary (not a full synopsis) indicating the programme genre and any significant story/content.
Red Flag complaint (via the ÃÛÑ¿´«Ã½ formal complaint’s process)
Usually filled in after transmission against that particular transmission if a formal complaint has been made which has led to a revocation from iPlayer or may affect the compliance status if repeated or made subsequently available.
If the programme is subject to a formal Red Flag complaint, the ÃÛÑ¿´«Ã½ complaints case reference (CAS) number will be added. Once the complaint has been resolved a further updated compliance form may be completed to record the finding.
Compliance events
You must answer all 49 questions on the ‘compliance events’ tab, adding accompanying notes where necessary. Any extra detail you can supply, including timecodes, will aid understanding of the compliance issues noted, and help save time and effort on the part of those reviewing them.
Issues are listed below with the relevant section in the ÃÛÑ¿´«Ã½ Editorial Guidelines and with links to any other guidance or supporting information.
See the Editorial Policy website for further information.
Further information and advice from ÃÛÑ¿´«Ã½ Editorial Policy and associated teams can be sought from ÃÛÑ¿´«Ã½ commissioning.
Some issues require referrals up the editorial chain, including mandatory referrals. In the Nations and in English regions the relevant Director or Controller must be informed of any issue that is a ‘mandatory referral’ to Director, Editorial Policy and Standards.
1. Legal issues
Any decision to proceed with content despite legal advice must be referred to the most senior divisional editorial figure and to the Director, Editorial Policy and Standards.
Editorial Guidelines:
YES: where there are continuing issues. In the referrals section, indicate the subject/s of the legal issue/s (eg contempt, privacy etc) with dates but do not detail the advice given.
NO: if you have sought legal advice but there are no outstanding issues.
Editorial Guidelines:
2 – 5. Strong language/gestures
The use of any strong language, whether written or spoken, or offensive gestures, must be editorially justified and signposted if appropriate to ensure it meets audience expectations wherever it appears. Attention should be given to spoken and written language and gestures, even if not in English, and/or captioned, as well as music lyrics (even if background).
Refer to:
Editorial Guidelines: Section 5 Harm and Offence: language (Guidelines 5.4.27 - 32)
Editorial Guidelines: Section 5 Harm and Offence: abusive or derogatory treatment (Guidelines 5.4.43)
There are some views and language which may cause serious offence, but a failure to reflect them could have implications for the ÃÛÑ¿´«Ã½â€™s impartiality
Editorial Guidelines: Section 5 Harm and Offence: mandatory referral (Guidelines 2.3.6)
2. Strong, most offensive
YES: if there is language that shouldn’t be transmitted pre-watershed on TV (before 9pm) or falls into the ‘most offensive’ category. Detail in notes the precise words used with time-coded references.
Strong language/gestures are allowed only in consultation with the ÃÛÑ¿´«Ã½ commissioner.
Indicate if strong language/gestures occur near the start of the programme or in episode recaps or pre-title (and so would be transmitted close to the 2100 television watershed).
Use of any of the most offensive words or phrases eg fuck, motherfucker, ‘Jesus fucking Christ' and cunt require the advance approval of the relevant head of channel and/or the chief content officer. Where approval is given, please note in the referrals section before submitting the form. (See appendix 2 of the for more details.)
Refer to:
Editorial Guidelines: Section 5 Harm and Offence: mandatory referral 5.3.4
The strongest language should not be included in content online, or in social media content, likely to appeal to a significant proportion of children (Guideline 5.4.30).
3. Any other which may offend
YES: if there is any other offensive language (eg bloody, shit, arse, bollocks, bugger, wank etc) or gestures.
If intended for pre-watershed transmission, detail in notes the precise words used with time-code references.
Language which is offensive but is not the strongest language should not be included in content online, or social media content, likely to appeal to a significant proportion of children, unless it is justified by the context. Even then, frequent use must be avoided (Guideline 5.4.32).
See also Question 17-18 Portrayal.
4. Strongest racist language
Use of racist and discriminatory language must be editorially justified and signposted where appropriate to ensure it meets audience expectations, wherever it appears. Its use, even with editorial justification and in line with the expectations of most of the audience, may still cause offence to some.
There must be exceptional editorial reasons to use the strongest racist and discriminatory terms.
The Divisional Director or their named delegate should be made aware of and agree the use of the strongest racist language, as listed in Ofcom’s ‘strong’ column, in any upcoming programmes or output on TV, Radio and Online/Digital
Editorial Guidelines: Section 5 Harm and Offence: mandatory referral 5.3.5
Where approval is given, please note in the referral section before submitting the form.
A list of racist language in the UK is available from Ofcom in their research report from September 2021.
Further guidance:
5. Any other discriminatory language or content that may offend
There are a range of discriminatory words and gestures which would be offensive to particular groups of viewers as well as more widely. Detail in notes on the compliance form the precise issue and the context with time-code references.
See also Question 17-18 Portrayal.
6 - 7. Sex
6. Sexual content
YES: if there is any kind of sexual activity depicted. Give enough detail in notes for scheduling judgements to be made in relation to slot/channel.
Some disturbing scenes eg of sexual violence (including rape) should also be flagged in the Violence section (Q10) and should be used only after consultation with the ÃÛÑ¿´«Ã½ commissioner.
Editorial Guidelines: Section 5 Harm and Offence: sex (Guidelines 5.4.46 - 48)
7. Sexual innuendo/reference
YES: for comedy and comic situations, and broad sexual discussion, language, material or themes, especially if the main topic or focus of the content, or occurring across several contributions. Detail whether verbal or visual.
It may not be necessary to give precise details if the comic innuendo is relatively mild, depending on the scheduled slot/channel and/ or intended or likely audience
8. Nudity
YES: if nudity is featured, especially lower body, whether in a sexual or non-sexual context. Nudity should not normally be shown before the watershed or in online content likely to appeal to a significant proportion of children. Where it is used it must be justified by the context which should be noted.
Editorial Guidelines: Section 5 Harm and Offence: nudity (Guideline 5.4.45)
9 – 12. Violence
All scenes containing violence must be noted. Pay particular attention to those featuring weapons, which are particularly graphic or prolonged (see Q19 Disturbing images), or aimed at those considered particularly vulnerable (including women and children, see Q11 and Q12). A soundtrack can enhance the sense of menace or terror and should be considered.
Provide time-coded references if possible but it is essential to indicate whether scenes occur near the start of the programme or in episode recaps or pre-title (and so would be transmitted close to the 2100 television watershed).
This section has relevance not just to factual and drama content, but may also apply to other genres like entertainment (eg even slapstick or spoof violence may be especially offensive should real life violence be in the news eg mass shooting/beheading etc). See Q10.
Editorial Guidelines: Section 5 Harm and Offence: violence (Guidelines 5.4.37 - 42)
Please note that this should include significant violence to, or mistreatment of, animals as well as people.
Refer to:
Editorial Guidelines: Section 5 Harm and Offence: mandatory referral 5.3.6
Editorial Guidelines: Section 5 Harm and Offence: violence against animals and animal welfare (Guideline 5.4.42)
Editorial Guidelines: Section 8 Crime and Anti-social Behaviour: mandatory referral (8.2.15)
9. Real life
When real life violence, or its aftermath, is shown, producers need to strike a balance between the demands of accuracy, and the risk of causing unjustified distress or offence.
Editorial Guidelines: Section 5 Harm and Offence: mandatory referral 5.3.1
Editorial Guidelines: Section 7 Privacy: reporting death, suffering and distress (Guideline 7.4.52 - 56)
See also Q29 Suffering and distress.
10. Fictional
This section may also apply to scripted genres like entertainment (eg even comic or spoof violence may be become offensive in the light of a real life news event, for example terror acts such as bombings or other mass casualty attacks). It does not apply purely to fictitious events/characters.
Refer to:
Editorial Guidelines: : television scheduling and the watershed (Guideline 5.4.11)
11. Involving children
YES: for scenes involving children, whether in scripted or unscripted content, where they appear to be or are present during verbal or physical violence. Content should adhere to the ÃÛÑ¿´«Ã½â€™s Safeguarding policy.
Refer to:
Editorial Guidelines: Section 9 Children and Young People as Contributors - Guidelines (Guidelines 8.4.16 - 19)
Further guidance:
12. Sexual violence
Any scenes eg of sexual assault/violence (including rape). These should be used only after consultation with the ÃÛÑ¿´«Ã½ commissioner. A link to a ÃÛÑ¿´«Ã½ Action Line should be considered, especially for unscripted content, and if put in place, should be noted on the form.
13 – 16. Imitative behaviour
Careful judgments are required about content which might lead to dangerous imitation.
The possibility of audiences, especially children, imitating dangerous, life-threatening, anti-social or criminal behaviour may have already been referred to in a previous section, if so, tick YES, but do not repeat detail in notes.
13. Drug/solvent abuse/gambling
Editorial Guidelines: Section 5 Harm and Offence: alcohol, smoking, vaping, solvent abuse, drugs and gambling (Guideline 5.4.52 - 56)
Period and/or contemporary social drinking and smoking/vaping, especially in background scenes, or where present as ordinary character behaviour should not cause concern and need not be timecoded (See Q16).
Gambling must not be condoned, encouraged, or glamourised in content likely to be widely seen, heard or used by children and young people, unless there is editorial justification (Guideline 5.4.55).
14. Suicide, eating disorders, self-harm, hanging
Editorial Guidelines: Section 5 Harm and Offence: suicide, attempted suicide, self-harm and eating disorders (Guideline 5.4.57 - 60)
Material which normalises, encourages or romanticises these behaviours should be avoided. Signposting and content warnings should be considered, as well as provision of support via a ÃÛÑ¿´«Ã½ Action Line link / announcement. Editorial policy should usually be consulted (Guideline 5.4.58)
Editorial Guidelines: Section 5 Harm and Offence: mandatory referral 5.3.7
15. Other potentially dangerous behaviour
This could include dangers around the house such as a child getting into a fridge or the use of domestic objects (knives, scissors etc) in harmful acts (Guideline 5.4.62).
Editorial Guidelines: Section 5 Harm and Offence: imitative behaviour (Guideline 5.4.61 - 63)
16. Use of alcohol/smoking
YES: if the activity is particularly prominent eg a contributor smoking/vaping or the context is significant and/or substantial (eg binge drinking, extended scenes). Consider also whether content is aimed particularly at children.
NO: if the content is for a general audience where the activity is not prominent and is justified by context eg scenes set in pubs or restaurants/period settings.
17 – 18. Portrayal
Careless or offensive or stereotypical assumptions must be avoided and people should only be described in terms of their disability, age, sexual orientation, gender identity, race etc when editorially justified. (See also Q3 Language.) This can be a complex area where advice should be taken.
Refer to:
Editorial Guidelines: Section 5 Harm and Offence: portrayal (Guideline 5.4.50 - 51)
Editorial Guidelines: Section 5 Harm and Offence: religion (Guideline 5.4.66 - 68)
17. Disabilities, religious, minorities, vulnerable contributors
YES: if there are significant and potentially controversial references.
NO: the fact that any presence is unremarkable and would only need noting for issues which might give rise to offence.
The welfare of children and young people is of paramount concern. This means their interest and safety must take priority over any editorial requirement.
Audiences may be offended if they believe contributors are vulnerable and their welfare has not been protected. Appropriate information should be given where it would assist in avoiding or minimising offence (Guideline 5.4.49 and 9.4.19).
Material may require an additional assessment of the contribution of vulnerable people (including children), or those in a vulnerable state, when taking into account the nature of their contribution and the passage of time since originally broadcast or made available.
Refer to:
Editorial Guidelines: Section 7 Privacy: children, young people and vulnerable contributors (Guideline 7.4.8)
Editorial Guidelines: Section 8 Crime and Anti-social Behaviour: children and young people/as witnesses or victims (Guideline 8.4.31 - 32 and 8.4.37)
Editorial Guidelines: Section 9 Children and Young People as Contributors: impact of a contribution (Guideline 9.4.29 - 33)
Further guidance:
18. Cultural sensitivities
YES: if there are scenes or subject-matter which may be generally acceptable to UK domestic audiences but which could be an issue to specific ethnic or religious groups, and particularly if transmitted outside the UK ie a scene associating a person perceived to be a Muslim with tobacco or alcohol.
YES: also if there are scenes which may be culturally acceptable in other countries (eg ritual slaughter or other scenes with animals (eg bloodletting/butchering) but which might raise concerns for the UK audience.
Refer to:
Editorial Guidelines: : violence against animals and animal welfare (Guideline 5.4.42)
19 – 21. Disturbing content
19. Disturbing images/sounds
For scenes which are inherently distressing or disturbing to sections of the audience or which could be relatively innocuous but take on impact at a particular time or within a particular context ie. after a train or air crash, or a major natural disaster.
A soundtrack can enhance the sense of menace or terror and should be considered. Repeating factual material involving emotional trauma and death may cause particular distress.
A link to a ÃÛÑ¿´«Ã½ Action Line may be considered
Given the wide-ranging nature of this section, it is particularly important to provide full details in notes.
20. Disasters, accidents, kidnappings, terror
YES: for any news coverage or reporting of recent or past events (especially on significant anniversaries)
YES: where there are fictional instances with deliberate echoes of real-life events, or where those instances have gained such overtones.
Any significant UK or global landmarks or locations should be noted.
Editorial Guidelines: Section 5 Harm and Offence: tragic events (Guideline 5.4.9)
21. Exorcism, occult, paranormal, horror
Editorial guidelines : Section 5 Harm and Offence: hypnotism, exorcism, the occult and the paranormal (Guideline 5.4.69 - 71)
Editorial Guidelines: Section 5 Harm and Offence: mandatory referral 5.3.8
22 – 24. Impartiality and diversity of opinion
ÃÛÑ¿´«Ã½ is committed to achieving due impartiality in all its output. Impartiality is fundamental to its purpose and enshrined in the Charter. Impartiality is key to a relationship of trust with audiences.
Due impartiality usually involves more than a simple matter of ‘balance’ between opposing viewpoints and does not prevent objective judgements being made, based on evidence. It does not require detachment from fundamental democratic principles, including freedom of expression, the right to vote, the rule of law and freedom from discrimination (Guideline 2.1).
Editorial Guidelines:
Editorial Guidelines: Section 2 Impartiality: diversity of opinion/consensus/contentious views (Guideline 2.4.1 - 4 and 2.4.26 and 2.4.16)
22. Personal view/authored
Content which may be regarded as giving a personal view about controversial subjects, particularly those that are matters of public policy, or political or industrial controversy.
Such personal view content must be clearly signposted to audiences in advance.
Editorial Guidelines: Section 2 Impartiality: mandatory referral 2.3.1
If YES: please indicate the name of author in the notes (if not clear from the programme or content title), the subject matter and whether this is intended as part of a series or is a one-off. Balancing across the schedule / platform may be needed to ensure a full range of views is presented.
Editorial Guidelines: Section 2 Impartiality: personal view content (Guideline 2.4.34 - 36)
23. Controversial subjects/issues
If YES: indicate in notes the subject matter and whether there is due impartiality or whether it is part of a series which will carry a full range of views.
Multiple genres may touch on major subjects/issues of public or political controversy. It is particularly important to flag issues in content which may be less likely to deal with controversial matters.
For a definition of ‘controversial’, see:
Editorial Guidelines: Section 2 Impartiality: controversial subjects (Guideline 2.4.5 - 10)
Editorial Guidelines: Section 2 Impartiality: mandatory referral 2.3.1
24. Does it require additional programming?
If YES: provide details of any additional programming which has been commissioned/scheduled to represent alternative points of view.
Refer to:
Editorial Guidelines: Section 2 Impartiality: impartiality in series and over time (Guideline 2.4.28 - 30)
Editorial Guidelines: Section 2 Impartiality: drama, entertainment and culture (Guideline 2.4.3.33)
25 – 27. Accuracy and Statistics
Editorial Guidelines: Section 3 Accuracy/Section 11 Statistics, Data, Polls and Surveys
ÃÛÑ¿´«Ã½ content must not knowingly and materially mislead audiences.
Refer to:
Editorial Guidelines: Section 3 Accuracy: Production Techniques (Guideline 3.4.25 - 26)
Editorial Guidelines: Section 3 Accuracy: Use of AI (Guideline 3.4.27 - 29)
Further guidance:
Editorial Guidelines: Section 3 Accuracy: mandatory referral 3.3.4
Editorial Guidelines: Section 3 Accuracy: Factually Based Drama (Guideline 3.4.31)
Editorial Guidelines: Section 3 Accuracy: Archive Material (Guideline 3.4.32)
For questions of accuracy and acceptable/misleading production techniques, including for natural history content, see:
Further guidance:
For statistics and other data driven content see:
Editorial Guidelines: Section 11 Statistics, Data, Polls and Surveys
Further guidance:
For opinion polls, surveys, focus groups, online voting and other forms of ‘straw’ polls, also see Q36 Politics.
25. Reconstructions
YES: give notes to indicate what the reconstruction is and any issues which may arise with subsequent use such as if it mirrors or comes to mirror recent real word events. This includes both factual and drama-documentary genres.
Editorial Guidelines: Section 3 Accuracy: Reconstructions (Guideline 3.4.30)
Editorial Guidelines: Section 7 Privacy: mandatory referral 7.3.26
Editorial Guidelines: Section 8 Crime and Anti-social Behaviour: reconstructions (Guideline 8.4.11)
26. Anonymity issues
YES: if either a source or contributor has been promised anonymity. Please note the level of anonymity agreed ie picture, voice, non-identifiable to the general public/non-identifiable to close friends and family.
Editorial Guidelines: Section 18 The Law: legal rights to anonymity (Guideline 18.4.2)
Editorial Guidelines: Section 3 Accuracy: mandatory referral 3.3.1
Further guidance:
Refer to:
Editorial Guidelines: Section 3 Accuracy: avoiding misleading audiences: sources (Guideline 3.4.16 - 23)
Editorial Guidelines: : contributors and consent: anonymity (Guideline 6.4.31 - 36)
Editorial Guidelines: Section 8 Crime and Anti-social Behaviour: children and young people (Guideline 8.4.31 - 32)
Editorial Guidelines: Section 8 Crime and Anti-social Behaviour: mandatory referrals 8.3.7 and 8.3.9
Editorial Guidelines: Section 8 Crime and Anti-social Behaviour: disguising identities (Guideline 8.4.36)
27. Fairness and Accuracy in drama
When a drama portrays real people or events it is inevitable that some dramatic elements may be fictional. However, the portrayal should be based on a substantial and well-sourced body of evidence whenever practicable and should not unduly distort the known facts, including chronology.
It is important to explain the drama's factual basis (or use of dramatic licence) with clear signposting. Portrayal of living people will often be particularly sensitive. Particular care should be taken to achieve due accuracy. There may also be issues with people who are no longer alive but have living relatives. Note names and issues which may arise with reuse ie. relatives to be informed (bearing in mind privacy and data protection issues).
Refer to:
Editorial Guidelines: Section 3 Accuracy (Guideline 3.4.31)
Editorial Guidelines:
Editorial Guidelines: Section 7 Privacy: mandatory referral 7.3.26
28 – 30. Privacy
We must balance the public interest in freedom of expression with the legitimate expectation of privacy by individuals.
Editorial Guidelines: Section 7 Privacy
28. Secret Recordings/webcam/CCTV – including body worn and drone cameras
Editorial Guidelines: Section 7 Privacy: secret recording (Guideline 7.4.11 – 29)
All proposals to record secretly must be referred to Editorial Policy prior to approval by the ÃÛÑ¿´«Ã½ commissioner. These should also be notified to the relevant figure in each Division responsible for record keeping, even if the request is turned down.
For all mandatory referrals, you MUST provide dates and specify if approval has been given for both recording and transmission.
Forms available from the .
Note use of live streaming (webcam/CCTV footage).
Refer to:
Editorial Guidelines: Section 7 Privacy: mandatory referrals 7.3.12 – 7.3.13
Further guidance:
Note that in some circumstances open filming with small, body worn digital cameras (such as ‘GoPros’) may be construed as secret recording.
Refer to:
Editorial Guidelines: Section 7 Privacy: body-worn cameras (Guideline 7.4.32)
Further guidance:
Editorial Guidelines: Section 7 Privacy: mandatory referral 7.3.5
Editorial Guidelines: Section 7 Privacy: tag-along raids (Guideline 7.4.51)
Any proposal to gather material using a drone where it might infringe privacy must be referred to a senior editorial figure or, for independent production companies, the commissioning editor
Editorial Guidelines: Section 7 Privacy: drones (Guideline 7.4.33)
Refer to:
Editorial Guidelines: Section 7 Privacy: mandatory referral 7.3.19
Further guidance:
Any proposal to use a tracking device where it would infringe the privacy of an individual must be referred to Director Editorial Policy and Standards
Editorial Guidelines: Section 7 Privacy: mandatory referral 7.3.7
Editorial Guidelines: Section 7 Privacy: tracking devices (Guideline 7.4.35)
Where approval is given, please note in the referral section before submitting the form.
See also:
Editorial guidelines: Section 7 Privacy: secret recording – comedy, entertainment or satire (Guideline 7.4.25 - 28)
29. Footage of suffering and distress
This applies to both contemporaneous and archive footage. If YES please detail the nature of the material.
Refer to:
Editorial Guidelines: Section 7 Privacy: mandatory referral 7.3.26
Editorial Guidelines: Section 7 Privacy: reporting death, suffering and distress (Guideline 7.4.52 - 56)
Editorial Guidelines: Section 7 Privacy: reporting death, suffering and distress – revisiting past events (Guideline 7.4.57)
Editorial Guidelines: Section 13 Use of ÃÛÑ¿´«Ã½ Content: fairness, consent and privacy issues (Guideline 13.4.12 - 19)
30. Door-stepping
If YES, overall details of the referrals, with dates, must be given in the referrals section.
Editorial Guidelines: Section 7 Privacy: doorstepping (Guideline 7.4.46 - 7.4.50)
Editorial Guidelines: Section 7 Privacy: mandatory referrals 7.3.23
31 – 32. Reporting crime and anti-social behaviour
Material likely to encourage or incite crime, or lead to disorder, must not be included in ÃÛÑ¿´«Ã½ output. Any proposal to publish or broadcast content which risks inciting crime or disorder must be referred to Director Editorial Policy and Standards.
Editorial Guidelines: Section 8 Crime and Anti-social Behaviour: mandatory referral 8.3.1
Editorial Guidelines: Section 8 Crime and Anti-social Behaviour
Repeating content depicting illegal or anti-social behaviour, particularly more than a year after first shown can throw up additional editorial issues.
Any public interest justification may diminish with the passage of time and may require discussions between a senior editorial figure in the DBC unit (responsible for complying repeats), production, commissioning and Editorial Policy. Additional blurring or editing may be required.
Refer to:
Editorial Guidelines: Introduction: editorial values (Guideline 1.2)
Editorial Guidelines:
Further guidance:
31. Interviews with criminals
If YES: detail name and the nature of crime (bearing in mind privacy, legal and data protection issues). Attention should be brought to any restrictions on re-use (as above).
Refer to:
Editorial Guidelines: Section 8 Crime and Anti-social Behaviour: reporting crime (Guideline 8.4.1 - 6)
Editorial Guidelines: Section 8 Crime and Anti-social Behaviour: dealing with criminals and perpetrators of anti-social behaviour (Guideline 8.4.14 - 18)
Editorial Guidelines: Section 8 Crime and Anti-social Behaviour: mandatory referrals 8.3.1 - 8.2.14
32. Demonstration of illegal activity
This applies to both demonstration and witnessing of illegal activity.
Refer to:
Editorial Guidelines: Section 8 Crime and Anti-social Behaviour: reporting crime (Guideline 8.4.4 - 6)
Editorial Guidelines: Section 8 Crime and Anti-social Behaviour: mandatory referrals (Guideline 8.3.1 - 2)
Editorial Guidelines: Section 12 War, terror and Extreme Violence - mandatory referrals (Guideline 12.3.1 - 8)
Material that contains hate speech should not be included in our output unless it is justified by the context. Broadcasting hate speech can constitute a criminal offence if it is intended, or likely to stir up, hatred relating to race, religious belief or lack of religious belief, disability, sexual orientation or transgender identity.
Editorial Guidelines: Section 8 Crime and Anti-social Behaviour: hate speech (Guideline 8.4.3)
See also Q4 and Q5 Language
33 – 35. Independence from commercial interests
Editorial Guidelines: Section 15 Independence from Commercial and External Interests
33. Commercial, sponsor or brand references
The ÃÛÑ¿´«Ã½ must not commission, produce or co-produce output for its UK Public Services which contains product placement (Guideline 15.2.6).
Any proposal to carry output on UK Public Services which requires signalling for product placement must be approved by the Director-General
Editorial Guidelines: Section 15 Independence from Commercial Interests: mandatory referral 15.3.5
Brands, products, organisations, services, trade marks, activities, views or opinions must not be promoted on the UK Public Service or the World Service (Guideline 15.2.7).
Refer to:
Editorial Guidelines: Section 15 Independence from Commercial Interests: product prominence (Guideline 15.4.1)
Editorial guidelines: Section 15 Independence from Commercial Interests: public service references to ÃÛÑ¿´«Ã½ commercial services and products and other material related to editorial content (Guideline 15.4.25)
34. Brands, services, products and trade marks
List any featured or visually or verbally prominent. Precise timecoding may no be necessary bearing in mind the nature of the programme and/or context.
35. Conflicts of interest: Presenters/guests/production team
YES: for any issues - or perceived issues - which may arise concerning guests, presenters, producers and production. Give as much information as you can. Particular attention should be paid to business interests.
Refer to:
Editorial Guidelines: Section 4 Conflicts of Interest
Potential conflicts of interest can also arise where an independent production company is owned/co-owned by an on-air presenter or performer or their agent, or where they are part of the senior management.
It is essential that content must not be used as a vehicle for to promote the external commercial or other interests of talent or their agents.
In exceptional circumstances, where there is clear editorial justification and where the programme or content and its subject cannot be commissioned unless it is produced with the associated agent or talent-owned independent, the proposal should be referred to the Director, Editorial Policy and Standards.
Editorial Guidelines: Section 4: Conflicts of Interest: mandatory referral 4.3.3
Further guidance: Conflicts of Interest
36 – 38. Politics and public policy
The principles relating to the ÃÛÑ¿´«Ã½â€™s political impartiality and independence from political influence are central to its coverage of politics and public policy.
See also Q22 and Q23 Impartiality.
36. Opinion polls/surveys (also see Q38)
Both for commissioning and reporting polls or surveys. If YES: please note the subject of the poll or survey and whether it was commissioned by the ÃÛÑ¿´«Ã½.
Any proposal to commission an opinion poll (or use other methods, such as data analysis) with the intention of sampling party political support or voting intentions must be referred in advance to Chief Adviser Politics for approval in advance.
Editorial Guidelines: Section 10 Politics and Public Policy: mandatory referral 10.3.7
Any proposal to commission an opinion poll or ÃÛÑ¿´«Ã½ any sort of survey, vote or focus group on matters of public policy, political or industrial controversy, or on ‘controversial subjects’ in any other area, must be referred to Chief Adviser Politics in advance.
Editorial Guidelines: Section 10 Politics and Public Policy: mandatory referral 10.3.8
Where approval is given, please give notes in the Referral section before submitting the form.
Editorial Guidelines: Section 10 Politics and Public Policy: opinion polls and surveys (Guideline 10.4.16 - 20)
Further guidance:
Refer to Editorial Guidelines: Section 11 Statistics, Data, Polls and Surveys
See also Q23-24 Accuracy.
37. Interview/appearance of party leaders (also see Q38)
If YES: detail the name and party of leader.
Editorial Guidelines: Section 10 Politics and Public Policy: political interviews and contributions (Guideline 10.4.3 - 6)
Editorial Guidelines: Section 10 Politics and Public Policy: mandatory referrals 10.3.1 and 10.3.2
Chief Adviser Politics must be consulted in advance of any proposal to invite a politician to take part in any content not normally considered to be ‘political’ in the proper sense. Any offer from a politician to take part in such content must also be referred before accepted or declined.
Editorial Guidelines: Section 2 Impartiality: mandatory referral 2.3.2
38. If yes to 36 or 37, referred to Chief Political Adviser?
Where approval is given, please give notes in the Referral section before submitting the form.
39 – 42. Other issues, repeats and subsequent use
Consider any additional issues which might arise after content is first made available, in the light of immediate or extended availability on iPlayer, planned or subsequent repeat or use, or re-licensing for ÃÛÑ¿´«Ã½ platforms or other ÃÛÑ¿´«Ã½ services offering on-demand or streaming.
These are likely to range across the whole range of core editorial and compliance issues – accuracy, fairness, privacy, interactivity - as well as involving legal considerations, concerns about contributors and portrayal, questions of impartiality and harm and offence issues (including language).
See Q17 Vulnerable contributors, Q18 Cultural sensitivities, Q23 Controversial subjects, Q26 Anonymity issues, Q29 Suffering and distress and Q32 Illegal activity.
39. Public figures - as contributors
Contributors and potential contributors must be treated with respect. Content makers must not unduly intimidate, humiliate, or behave aggressively towards contributors, either to obtain their consent or during their participation in output (Guideline 6.4.27).
40. Public figures - reference to
YES: if any royal figure, well-known person or prominent figure (especially with strong connection to or association with the ÃÛÑ¿´«Ã½ in the public mind) whether in politics, the broader public sphere, entertainment, or sport, and/or with a high profile as a celebrity or on social media etc either takes part in the content or is referred to. In particular, any person involved in significant news stories during production or leading up, or expected to lead up to, broadcast or publication.
Full detail should be provided if possible but if this would be overly burdensome (ie if there are multiple references and / or delivery is close to transmission or publication), then simply tick YES. Please note that this section may be particularly valuable if unexpected events occur eg sudden death or illness, criminal or other charges, press coverage, stories or other speculation between delivery and availability that would make significant news.
NO: Historical figures/fictional characters
41. Sensitive content issues
Covers a range of potential problems, primarily in the event of a repeat, extended availability and/or subsequent re-use. For example, references to currently seriously ill or recently dead people, coverage of time-sensitive subjects or issues, interviews with children etc.
Religious sensitivity around holy days should also be considered.
Editorial Guidelines: Section 14 Religious Content
42. Any restriction for subsequent use?
Including any contributor sensitivities or legal reasons which would affect the partial or whole re-use/repeat of the content. If YES: give full details.
Consider any additional steps that should be taken when content is re-used, distributed or otherwise made available, in whole or part, in ways that may not have been contemplated at the time of production.
Editorial Guidelines: Section 13 Use of Content after publication or broadcast: mandatory referral 13.2.2
For accuracy issues see: Editorial Guidelines: Section 13 Use of Content after publication or broadcast: accuracy issues (Guideline 13.4.10 - 11)
For fairness consent and privacy issues see:
Editorial Guidelines: Section 13 Use of Content after publication or broadcast: fairness consent and privacy issues (Guideline 13.4.12 - 17)
Editorial Guidelines: Section 7 Privacy: Revisiting Past Events (Guideline 7.4.57)
For help with questions where the public interest justification in depicting illegal or anti-social behaviour may have diminished over time, see Crime (Q 29-30) above.
Editorial Guidelines: Section 13 Use of Content after publication or broadcast: content depicting illegal or anti-social activity (Guideline 13.4.19)
Refer to:
Editorial Guidelines: Section 6 Fairness: safety and duty of care (Guideline 6.4.22 - 26)
Editorial Guidelines: : anonymity (Guideline 6.4.31 - 36)
Editorial Guidelines: Section 7 Privacy: reporting suffering and distress - past events (Guideline 7.4.57)
Editorial Guidelines: Section 8 Crime and Anti-social Behaviour: impact on victims (Guideline 8.4.7 - 10)
Editorial Guidelines: Section 8 Crime and Anti-social Behaviour: disguising identities (Guideline 8.4.36)
Further guidance:
For harm and offence issues see:
Editorial Guidelines: Section 5 Harm and Offence: content that includes racist or discriminatory language (Guideline 5.4.35)
Editorial Guidelines: Section 5 Harm and Offence: archive content – harmful and imitative behaviour (Guideline 5.4.56)
Editorial Guidelines: Section 13 Use of Content after publication or broadcast: harm and offence issues (Guideline 13.4.21 - 23)
For interactivity issues see:
Editorial Guidelines: Section 17 Competitions Votes and Interactivity
Editorial Guidelines: Section 17 Competitions, Votes and Interactivity: content on catch-up services or repeated (Guideline 17.4.12 - 13)
43. Flashing lights/flash photography/strobing/lighting effects which have failed technical review
YES: If content features flashing lights or strobing that has failed AQC, or just narrowly passed review, cannot be fixed or further reduced, and where there is editorial justification.
Where a programme which failed, is then fixed and passes, this might not be enough to answer NO, particularly if the pass is a narrow one and has only been achieved by multiple attempts. Further advice should be sought from the Channel Compliance Managers (see ‘Getting more advice’ below).
Approval to go ahead on the basis of a YES must be sought through the relevant editorial chain. Where approval is given, please note in the referral section before submitting the form. The programme will then be preceded by a clear continuity warning or given clear guidance labelling online.
Editorial Guidelines: Section 5 Harm and offence – mandatory referrals (Guideline 5.3.9)
Editorial Guidelines: Section 5 Harm and Offence: flashing images, strobing and images of very brief duration (Guideline 5.4.72).
44 – 48. Competitions, votes and interactivity
Votes on matters of public policy, political or industrial controversy or any other ‘controversial’ subject must be referred to Chief Adviser Politics (see Q23-24 Accuracy and Q36 Opinion polls/surveys).
Editorial Guidelines: Section 11 Statistics, Data, Polls and Surveys
All ÃÛÑ¿´«Ã½ competitions and votes must be approved by a senior editorial figure (Guideline 17.3.1).
Anyone proposing to carry out a phone, text or online vote or competition which involves audience interaction must refer to the ÃÛÑ¿´«Ã½â€™s Interactivity Technical Advice and Contacts Unit (ITACU) and complete the appropriate approval process.
Editorial Guidelines: Section 17 Competitions, Votes and Interactivity: mandatory referrals 17.3.11 - 17
Any proposal for the ÃÛÑ¿´«Ã½ to accept a donated career or life-changing opportunity for contestants or participants must be referred to Editorial Policy
Editorial Guidelines: Section 17 Competitions, Votes and Interactivity: mandatory referrals 17.3.22
Most interactivity requires approval forms which can be found on the .
Where approval is given, please give notes in the Referral section before submitting the form.
Further guidance:
Programmes with interactive elements (competitions, phone votes, other calls to action) may need to be reviewed/re-edited for availability on iPlayer after the interactive elements have expired.
Editorial Guidelines: Section 17 Competitions, Votes and Interactivity: content on catch-up services or repeated (Guideline 17.4.12 - 13)
49. Interactivity approval form authorisation
If YES to questions 44 - 48 confirm the mandatory Interactivity Approval Form has been authorised by the relevant editorial figure.
Please give notes in the Referral section before submitting the form.
Editorial Guidelines: Section 17 Competitions Votes and Interactivity: ITACU (Guideline 17.4.23)
Getting more advice on completing the form
Please see the compliance section of the contacts page for Channel Compliance Managers and Duty Lawyer contact details.
In cases where a serious issue of editorial judgment is concerned (e.g. use of very strong language or surreptitious recording), this should not replace your usual editorial referrer.
TV: mandatory referrals
Referrals to David Jordan, Director, Editorial Policy and Standards are mandatory for the inclusion of specific content in a TV programme. This includes the broadcast of secretly recorded material, interviewing a criminal or the dramatic portrayal of a real person against the wishes of the individual or their relatives.
I&RP Ofcom compliance form
As part of our commitment to supporting the growth of television production out of London we need to formally track and record the location of our productions. Suppliers must report this to us via the Independent and Regional Production (I&RP) form.
Please see the Portrayal and production location reporting page for further information.
Online: clip compliance
Please note, programme clips published online which are extracts taken directly from a broadcast programme do not require a separate compliance form. Please see the publicity page for information about the delivery requirements for programme extract clips used online.
A short-form compliance form must be completed for all content that is published online which is not a direct extract of a broadcast programme to conform it complies with the ÃÛÑ¿´«Ã½ Editorial guidelines and to ensure that guidance labels are applied where necessary.
A single form can be used for multiple online clips when there are no compliance issues that need noting and they relate to the same programme or product.
The completed form must be submitted with sign off from the independent production company executive producer. The form will then be sent to the ÃÛÑ¿´«Ã½ executive producer for final sign off before the content is published.
If a clip is being republished due to technical issue or with minor changes, eg spelling mistakes, a new form does not need to be submitted. A new form must be submitted if there is a significant editorial change to the content.
If, for technical or procedural reasons such as a live programme, it is not going to be possible to submit an short-form compliance form before publication of a clip an alternative sign off process should be agreed in advance by the ÃÛÑ¿´«Ã½ executive producer.
Download the (Excel).
Email the completed form to:
For all Network programmes (other than Children's): shortformvideoteam@bbc.co.uk
For Children’s: Children’s Delivery Unit
Online: clip compliance responsibility
The ÃÛÑ¿´«Ã½ executive producer is responsible for the content being compliant. The executive producer can designate a member of the production team with appropriate editorial expertise to view the content and sign the form on their behalf if they consider the online content carries a low level of risk. The executive producer must record the fact that compliance has been delegated via an email to the designated member of staff. However, overall responsibility for compliance still rests with them. Likewise, the independent executive producer can delegate sign off in the same way as the ÃÛÑ¿´«Ã½ executive producer.
It is essential that either the executive producer or the designated team member has viewed the video (or listened to the audio) and, if it is derived from a programme, is familiar with the programme's content.
Delegated compliance is not always advisable. Executive producers should assess the level of risk involved in online content which may include issues such as but not restricted to the following:
Is the programme on the managed risk list? Does it contain controversial or extremely sensitive material? Is there a risk that material taken out of context could lead to legal or Editorial Policy issues? Does a careful assessment need to be made regarding young or vulnerable contributors? Will the embedding of the clip cause problems for the programme or for contributors? Does the clip meet user expectations? Is the clip representative of the TV programme?
The ÃÛÑ¿´«Ã½ requires consistency in compliance across all ÃÛÑ¿´«Ã½ platforms.
Channel compliance managers can provide guidance on short-form content. If the video carries content that requires a mandatory referral, the executive producer or designated individual must contact the relevant controller and obtain authorisation. Find contacts for compliance teams.
Online: clip guidance labels
Some clips may require a guidance label.
Download .
Online: other content
Other content such as text and images do not have be individually complied but the executive must ensure that they have put in place satisfactory procedures to ensure that content is compliant with the ÃÛÑ¿´«Ã½ Editorial guidelines.
This includes a process for the escalation of issues or queries. The executive should also decide whether it is necessary to re-check ongoing updates based on what content is planned.
Sign off of this content can be done via email confirmation. Save a copy of the paperwork.
The clip will be a permanent record of the programme. It should be representative of the programme and the content should meet the audience expectation of the show.
Contacts
Please visit the to find specific compliance contacts.