The mid-term BBC charter review of 2024 recommended that Ofcom, the UK’s broadcast regulator, take on responsibility for oversight of the BBC’s online content as well as their broadcast programming.
As Ofcom prepares to assume that role, it has an opportunity to confront a problem considerably greater than the distinction between television and the internet. Modern wars are fought partly through information. Journalism does not merely report on the battlefield.
The information environment is itself part of the battlefield. Reporters can therefore inadvertently find themselves recruited into the information strategies of parties to a conflict. The BBC’s duty of impartiality consequently requires a battlefield-level responsibility to guard against the circulation of propaganda on its online platforms.
Here are three specific, crucial additions that need to be made to the regulations in order to meet the obligations created by the changed nature of conflict reporting.
The BBC must never create an incentive to harm children.
It is a sickening and tragic truth that in asymmetric warfare civilian suffering can have exceptional strategic communications value. If greater civilian suffering produces more damaging international coverage of an adversary, armed groups have an incentive to expose civilians, and in particular children, to danger.
The war in Gaza provides a particular case study of this situation, but it is by no means exclusive to Gaza or to Palestinians.
It is a well-documented fact that Hamas embeds itself in civilian infrastructure. What needs to be honestly confronted is the strategic value they derive from the continued deaths of Palestinian children. Hamas leadership has been open about the value they see in civilian deaths, even pointing specifically to the relationship between civilian suffering in Gaza and the international isolation of Israel, ultimately serving one of their key war aims.
However, this strategy only works if the media plays its role. If every time a child died in Gaza in circumstances involving Hamas embedment in civilian infrastructure the BBC ran the formulation “Hamas routinely maximises civilian suffering in Gaza for strategic reasons” would Hamas continue to see a strategic benefit in those deaths? The horrifying prospect then, is that the BBC, by uncritically spreading images of child suffering, without proper contextual labelling of the cause of that suffering, is actively incentivizing more of that suffering.
The British national broadcaster must never be implicated in incentivizing the harm of any child, anywhere in the world. This makes proper contextual labelling absolutely crucial as a child protection measure.
The BBC must always remove content later found to be materially false or misleading.
Online news is not a newspaper that will be tomorrow’s fish wrapping. The online record becomes the historical record. Therefore, small correction notices, or larger corrections available elsewhere, are not sufficient when a piece of content is later found to be materially false or misleading.
For example, the original BBC reporting on the Al Ahli hospital blast was proven to be substantially wrong and catastrophically misleading. However, much of it is still available online.
The defence, essentially “this is what we knew at the time”, does not carry over from broadcast news to perpetually available online content. Similarly, as new information emerges surrounding the allegations of famine and deliberate starvation in Gaza, it becomes unconscionable that such allegations become part of the historical record.
Should UN humanitarian chief Tom Fletcher’s false claim that 14000 babies would die within 48 hours remain indefinitely available, continuing to feed the information battlefield, if the evidential basis for that claim subsequently collapsed?
The online environment is not the broadcast environment, and its impact can be cumulative and not necessarily mitigated by minor notices of correction.
The BBC must label content obtained in coercive environments.
Where the BBC operates in areas of high coercion, such as areas run by authoritarian governments or armed groups, civilian testimony cannot be treated as entirely freely given. In a situation where fixers, facilitators, participants, freelancers and local populations may be under considerable threat, the BBC should disclose that limitation on free expression to its audiences.
For example, if a freelance camera crew is operating in Gaza, the BBC cannot know if participants are under any pressure or threat, or have been cherrypicked for specific reasons.
There is no freedom of the press in Gaza, and therefore the content produced in that environment must be labeled as such, in order to ensure that audiences are not being misled. Crucially the British national broadcaster must never be found to be prioritising access over the truth. If the price of access is reporting only what an armed group or authoritarian government permits, the BBC imports the censorship of that environment into the information it provides to British audiences.
Revocation of access would be a story in itself. If that would be the case, so be it.
These examples are all related to Gaza because the war there has brought these issues into sharp focus, but they are applicable across all theatres of war in the modern world.
The BBC cannot control how wars are fought, but it can control whether its journalism creates incentives for child suffering, whether information it knows to be false remains in the permanent historical record, and whether audiences are told when information reaching them was produced under coercive conditions.
If you would like to have your say on the Ofcom consultation you can do so here.