Recommendation 27

Brass-plating allows broadcasters to meet their regional production criteria while using production companies that may not be based in Wales. Ofcom acknowledges that relying on the “substantive base” criterion alone provides an opportunity for the system to be manipulated. We recommend that Ofcom examine whether this 46 Broadcasting in Wales criterion alone should be sufficient to qualify a production as being based in Wales. We call on the Government to amend the Draft Media Bill to address this problem. (Paragraph 142) Broadcasting in Wales 47