Leveson Inquiry

An independent self regulatory body should be governed by an independent Board. In order to ensure the independence of the body, the Chair and members of the Board must be appointed in a genuinely open, transparent and independent way, without any influence from industry or Government.

The Inquiry recommended that an independent press self-regulatory body be governed by an independent board. In March 2018, the Department for Digital, Culture, Media and Sport noted that establishing voluntary press self-regulation enshrined in a Royal Charter formed a key part of the government response (Department for Digital, Culture, Media and Sport, Mar 2018). The Royal Charter on Self-Regulation of the Press, granted by the Privy Council in October 2013, set criteria requiring an independent board appointed without industry or government influence (Royal Charter on Self-Regulation of the Press, Oct 2013). In November 2012, David Cameron, Prime Minister, accepted these governance principles and stated that the onus was on the press to implement them (David Cameron response, Nov 2012).

The appointment of the Chair of the Board should be made by an appointment panel. The selection of that panel must itself be conducted in an appropriately independent way and must, itself, be independent of the industry and of Government.

The Inquiry recommended that the regulatory board chair be appointed by an independent panel. In a statement to the House of Commons on the Leveson Inquiry report in November 2012, David Cameron, Prime Minister, accepted the principles of independent self-regulation and stated that the onus was on the press to implement them (David Cameron response, Nov 2012). The Royal Charter on Self-Regulation of the Press, granted by the Privy Council in October 2013, established that the board chair must be nominated by an appointment panel independent of industry and government (Royal Charter on Self-Regulation of the Press, Oct 2013).

The appointment panel: (a) should be appointed in an independent, fair and open way; (b) should contain a substantial majority of members who are demonstrably independent of the press; (c) should include at least one person with a current understanding and experience of the press; (d) should include no more than one current editor of a publication that could be a member of the body.

The Inquiry asked the press to establish independent, fair regulatory appointment panels. In a statement to the House of Commons on the Leveson Inquiry report in November 2012, David Cameron, Prime Minister, accepted the report's regulatory principles, including independence of appointments, stating that the onus was on the press to implement them (David Cameron response, Nov 2012). The Royal Charter on Self-Regulation of the Press, granted by the Privy Council in October 2013, specified that an appointment panel must be appointed openly and fairly, maintain a substantial majority independent of the press, and contain at least one experienced industry member and at most one serving editor (Royal Charter on Self-Regulation of the Press, Oct 2013).

The appointment of the Board should also be an independent process, and the composition of the Board should include people with relevant expertise. The requirement for independence means that there should be no serving editors on the Board.

The Inquiry recommended that press regulatory board appointments be independent and exclude serving editors. In a statement to the House of Commons on the Leveson Inquiry report in November 2012, David Cameron, Prime Minister, accepted the principles of independent self-regulation and stated that the onus was on the press to implement them (David Cameron response, Nov 2012). The Royal Charter on Self-Regulation of the Press, granted by the Privy Council in October 2013, specified that the appointment process for the board must be independent, include people with relevant expertise, and contain no serving editors (Royal Charter on Self-Regulation of the Press, Oct 2013).

The members of the Board should be appointed by the same appointment panel that appoints the Chair, together with the Chair (once appointed), and should: (a) be appointed by a fair and open process; (b) comprise a majority of people who are independent of the press; (c) include a sufficient number of people with experience of the industry who may include former editors and senior or academic journalists; (d) not include any serving editor; and (e) not include any serving member of the House of Commons or any member of the Government.

The Inquiry recommended independent appointment of press regulatory boards excluding serving editors and politicians. In a statement to the House of Commons in November 2012, David Cameron, Prime Minister, accepted the Leveson principles and said the onus was on the press to implement them (David Cameron response, Nov 2012). In October 2013, the Royal Charter on Self-Regulation of the Press, granted by the Privy Council, required board members to be nominated by a fair and open process involving the Chair (Royal Charter on Self-Regulation of the Press, Oct 2013). The Charter also required the board to include an independent majority, members with industry experience, and no serving editors or parliamentarians (Royal Charter on Self-Regulation of the Press, Oct 2013).

Funding for the system should be settled in agreement between the industry and the Board, taking into account the cost of fulfilling the obligations of the regulator and the commercial pressures on the industry. There should be an indicative budget which the Board certifies is adequate for the purpose. Funding settlements should cover a four or five year period and should be negotiated well in advance.

The Inquiry recommended multi-year funding agreements between the press and the regulatory board. In a statement to the House of Commons on the Leveson Inquiry report in November 2012, David Cameron, Prime Minister, accepted the principles of independent funding and stated that the onus was on the press to implement them (David Cameron response, Nov 2012). In October 2013, the Royal Charter on Self-Regulation of the Press, granted by the Privy Council, provided that funding settlements should be agreed between the industry and the board for a four or five year period, based on an indicative budget certified as adequate (Royal Charter on Self-Regulation of the Press, Oct 2013).

The standards code must ultimately be the responsibility of, and adopted by, the Board, advised by a Code Committee which may comprise both independent members of the Board and serving editors.

The Inquiry recommended that the regulatory board oversee and adopt the standards code. In November 2012, David Cameron, Prime Minister, stated to the House of Commons that he accepted the Leveson principles, including a standards code, and placed the onus on the press to implement them (David Cameron response, Nov 2012). In October 2013, the Royal Charter on Self-Regulation of the Press, granted by the Privy Council, specified that the standards code must ultimately be the responsibility of and adopted by the Board, advised by a Code Committee comprising independent members and serving editors (Royal Charter on Self-Regulation of the Press, Oct 2013).

The code must take into account the importance of freedom of speech, the interests of the public (including the public interest in detecting or exposing crime or serous impropriety, protecting public health and safety and preventing the public from being seriously misled) and the rights of individuals. Specifically, it must cover standards of: (a) conduct, especially in relation to the treatment of other people in the process of obtaining material; (b) appropriate respect for privacy where there is no sufficient public interest justification for breach and (c) accuracy, and the need to avoid misrepresentation.

The Inquiry asked the press to establish a code covering conduct, privacy, and accuracy. In a statement to the House of Commons on the Leveson Inquiry report in November 2012, David Cameron, Prime Minister, accepted the principles of self-regulation and stated that the onus was on the press to implement them (David Cameron response, Nov 2012). In October 2013, the Royal Charter on Self-Regulation of the Press, granted by the Privy Council, specified that a regulatory code must govern standards of conduct, privacy, and accuracy while taking into account freedom of speech and the public interest (Royal Charter on Self-Regulation of the Press, Oct 2013).

The Board should require, of those who subscribe, appropriate internal governance processes, transparency on what governance processes they have in place, and notice of any failures in compliance, together with details of steps taken to deal with failures in compliance.

The Inquiry asked that press subscribers maintain internal governance processes and report compliance failures. David Cameron, Prime Minister, in a statement to the House of Commons on the Leveson Inquiry report in November 2012, accepted the Leveson principles and said the onus was on the press to implement them (David Cameron response, Nov 2012). The Royal Charter on Self-Regulation of the Press, granted by the Privy Council in October 2013, provided that a regulatory board should require subscribers to establish internal governance processes, ensure transparency, and give notice of compliance failures (Royal Charter on Self-Regulation of the Press, Oct 2013).

The Board should require all those who subscribe to have an adequate and speedy complaint handling mechanism; it should encourage those who wish to complain to do so through that mechanism and should not receive complaints directly unless or until the internal complaints system has been engaged without the complaint being resolved in an appropriate time.

The Inquiry asked that press regulators require subscribers to operate speedy complaint mechanisms. David Cameron, Prime Minister, stated in November 2012 that he accepted the principles of independent self-regulation, including a speedy complaints mechanism, and said the "onus should now be on the press to implement them" (David Cameron response, Nov 2012). In October 2013, the Royal Charter on Self-Regulation of the Press, granted by the Privy Council, set out that the regulatory board should require subscribers to have an adequate complaints process and resolve issues internally before direct board involvement (Royal Charter on Self-Regulation of the Press, Oct 2013).

The Board should have the power to hear and decide on complaints about breach of the standards code by those who subscribe. The Board should have the power (but not necessarily in all cases depending on the circumstances the duty) to hear complaints whoever they come from, whether personally and directly affected by the alleged breach, or a representative group affected by the alleged breach, or a third party seeking to ensure accuracy of published information. In the case of third party complaints the views of the party most closely involved should be taken into account.

The Inquiry asked that a press regulatory board have power to hear standards complaints. In November 2012, David Cameron, Prime Minister, stated that he accepted the Leveson principles for independent self-regulation, including a speedy complaint-handling mechanism, and placed the onus on the press to implement them (David Cameron response, Nov 2012). In October 2013, the Royal Charter on Self-Regulation of the Press, granted by the Privy Council, specified that the board should have the power to decide on complaints from affected individuals, representative groups, or third parties, alongside discretion to decline unjustified complaints (Royal Charter on Self-Regulation of the Press, Oct 2013).

Decisions on complaints should be the ultimate responsibility of the Board, advised by complaints handling officials to whom appropriate delegations may be made.

The Inquiry recommended that a press regulatory board hold ultimate responsibility for complaint decisions. In a statement to the House of Commons on the Leveson Inquiry report in November 2012, David Cameron, Prime Minister, accepted the Leveson principles and stated that the onus was on the press to implement them (David Cameron response, Nov 2012). The Royal Charter on Self-Regulation of the Press, granted by the Privy Council in October 2013, set out that a regulatory body's board must retain final authority over complaints, supported by handling officials (Royal Charter on Self-Regulation of the Press, Oct 2013).

Serving editors should not be members of any Committee advising the Board on complaints and any such Committee should have a composition broadly reflecting that of the main Board, with a majority of people who are independent of the press.

The Inquiry recommended that complaints committees exclude serving editors and include an independent majority. In a November 2012 statement to the House of Commons, David Cameron, Prime Minister, accepted the Leveson principles and stated that the onus was on the press to implement them (David Cameron response, Nov 2012). In October 2013, the Royal Charter on Self-Regulation of the Press, granted by the Privy Council, provided that serving editors should not be members of committees advising on complaints and required such committees to have a majority independent of the press (Royal Charter on Self-Regulation of the Press, Oct 2013).

It should continue to be the case that complainants are able to bring complaints free of charge.

The Inquiry recommended that complainants continue to be able to bring complaints free of charge. David Cameron, Prime Minister, in a statement to the House of Commons on the Leveson Inquiry report in November 2012, accepted the principles of press self-regulation, stating that the media must implement a speedy complaint-handling mechanism, though the statement did not mention free complaints (David Cameron response, Nov 2012). The Royal Charter on Self-Regulation of the Press, granted by the Privy Council in October 2013, stated that complainants should continue to be able to bring complaints free of charge (Royal Charter on Self-Regulation of the Press, Oct 2013).

In relation to complaints, the Board should have the power to direct appropriate remedial action for breach of standards and the publication of corrections and apologies. Although remedies are essentially about correcting the record for individuals, the power to require a correction and an apology must apply equally in relation to individual standards breaches (which the Board has accepted) and to groups of people (or matters of fact) where there is no single identifiable individual who has been affected.

The Inquiry recommended that a regulatory board have power to direct remedies and apologies. In a statement to the House of Commons on the Leveson Inquiry report in November 2012, David Cameron, Prime Minister, accepted the principles of self-regulation and stated that the onus was on the press to implement them (David Cameron response, Nov 2012). The Royal Charter on Self-Regulation of the Press, granted by the Privy Council in October 2013, stated that the regulatory board should have the power to direct remedial action, corrections, and apologies for individual standards breaches, groups of people, and matters of fact (Royal Charter on Self-Regulation of the Press, Oct 2013).

The power to direct the nature, extent and placement of apologies should lie with the Board.

The Inquiry recommended that a regulatory board have the power to direct apologies. David Cameron, Prime Minister, stated in November 2012 that he accepted the principles of the report, affirming that a self-regulatory body must have authority to require prominent apologies and that the onus lay with the press to implement them (David Cameron response, Nov 2012). The Royal Charter on Self-Regulation of the Press, granted by the Privy Council in October 2013, set out that the power to direct the nature, extent and placement of apologies and corrections should lie with the regulatory board in the absence of an agreement (Royal Charter on Self-Regulation of the Press, Oct 2013).

The Board should not have the power to prevent publication of any material, by anyone, at any time although (in its discretion) it should be able to offer a service of advice to editors of subscribing publications relating to code compliance which editors, in their discretion, can deploy in civil proceedings arising out of publication.

The Inquiry asked that a press regulatory board hold no power to prevent publication. In a statement to the House of Commons on 29 November 2012, David Cameron, Prime Minister, accepted the central Leveson principles and stated that the onus should be on the press to implement them (David Cameron response, Nov 2012). The Royal Charter on Self-Regulation of the Press, granted by the Privy Council on 30 October 2013, specified that the board should not have the power to prevent publication of any material at any time, but could offer code compliance advice to editors of subscribing publications (Royal Charter on Self-Regulation of the Press, Oct 2013).

The Board, being an independent self-regulatory body, should have authority to examine issues on its own initiative and have sufficient powers to carry out investigations both into suspected serious or systemic breaches of the code and failures to comply with directions of the Board. Those who subscribe must be required to cooperate with any such investigation.

The Inquiry recommended that an independent press self-regulatory body have authority to conduct investigations. In a statement to the House of Commons on the Leveson Inquiry report in November 2012, David Cameron, Prime Minister, accepted the Leveson principles and said the onus was on the press to implement them, though he did not mention investigation powers (David Cameron response, Nov 2012). The Royal Charter on Self-Regulation of the Press, granted by the Privy Council in October 2013, provided that an independent self-regulatory board should have authority to examine issues on its own initiative, investigate serious or systemic code breaches, and require subscribers to cooperate (Royal Charter on Self-Regulation of the Press, Oct 2013).

The Board should have the power to impose appropriate and proportionate sanctions, (including financial sanctions up to 1% of turnover with a maximum of £1m), on any subscriber found to be responsible for serious or systemic breaches of the standards code or governance requirements of the body. The sanctions that should be available should include power to require publication of corrections, if the breaches relate to accuracy, or apologies if the breaches relate to other provisions of the code.

The Inquiry recommended empowering a press regulator to impose financial sanctions, corrections, and apologies. In a statement to the House of Commons on the Leveson Inquiry report in November 2012, David Cameron, Prime Minister, accepted these principles, stating that a regulatory body must be able to demand apologies and impose fines up to one million pounds, with the onus on the press to implement them (David Cameron response, Nov 2012). In January 2025, Hacked Off found that the power to fine publishers exists on paper but has never been exercised, reporting that no financial sanctions were levied against any publisher between 2014 and 2024 (Hacked Off, Jan 2025).

The Board should have both the power and a duty to ensure that all breaches of the standards code that it considers are recorded as such and that proper data is kept that records the extent to which complaints have been made and their outcome; this information should be made available to the public in a way that allows understanding of the compliance record of each title.

The Inquiry asked the press regulatory board to record code breaches and publish compliance data. In a statement to the House of Commons on the Leveson Inquiry report in November 2012, David Cameron, Prime Minister, accepted the Inquiry's principles for independent self-regulation, stating that the onus was on the press to implement them (David Cameron response, Nov 2012). The Royal Charter on Self-Regulation of the Press, granted by the Privy Council in October 2013, specified that the regulatory board should have the power and duty to record all code breaches and publish data on complaints and outcomes to allow public understanding of each title's compliance record (Royal Charter on Self-Regulation of the Press, Oct 2013).

The Board should publish an Annual Report identifying: (a) the body's subscribers, identifying any significant changes in subscriber numbers; (b) the number of complaints it has handled and the outcomes reached, both in aggregate for the all subscribers and individually in relation to each subscriber; (c) a summary of any investigations carried out and the result of them; (d) a report on the adequacy and effectiveness of compliance processes and procedures adopted by subscribers; and (e) information about the extent to which the arbitration service had been used.

The Inquiry recommended that the regulatory Board publish an annual report on its operations. The Royal Charter on Self-Regulation of the Press, granted by the Privy Council on 30 October 2013, specified that the Board should publish an Annual Report covering subscriber numbers, complaints handling and outcomes, investigation summaries, compliance processes, and arbitration service use (Royal Charter on Self-Regulation of the Press, Oct 2013). Earlier, in a statement to the House of Commons on 29 November 2012, David Cameron, Prime Minister, accepted the Leveson principles and stated that the onus was on the press to implement them (David Cameron response, Nov 2012).

The Board should provide an arbitral process in relation to civil legal claims against subscribers, drawing on independent legal experts of high reputation and ability on a cost-only basis to the subscribing member. The process should be fair, quick and inexpensive, inquisitorial and free for complainants to use (save for a power to make an adverse order for the costs of the arbitrator if proceedings are frivolous or vexatious). The arbitrator must have the power to hold hearings where necessary but, equally, to dispense with them where it is not necessary. The process must have a system to allow frivolous or vexatious claims to be struck out at an early stage.

The Inquiry recommended an arbitration service for civil legal claims against press subscribers. In a statement to the House of Commons on the Leveson Inquiry report in November 2012, David Cameron, Prime Minister, accepted the Leveson principles including an arbitration service, stating that the onus was on the press to implement them (David Cameron response, Nov 2012). The Royal Charter on Self-Regulation of the Press, granted by the Privy Council in October 2013, specified that a regulatory board should provide a fair, quick, and inquisitorial arbitral process for civil legal claims (Royal Charter on Self-Regulation of the Press, Oct 2013).

A new system of regulation should not be considered sufficiently effective if it does not cover all significant news publishers.

The Inquiry recommended that effective press regulation must cover all significant news publishers. In March 2018, the Department for Digital, Culture, Media and Sport (DCMS) relayed that the Independent Press Standards Organisation (IPSO) regulated over 95 per cent of national newspapers by circulation and did not intend to seek recognition under the Royal Charter, finding that few publishers had joined a recognised regulator (Department for Digital, Culture, Media and Sport, Mar 2018; Department for Digital, Culture, Media and Sport, Mar 2018). Earlier, the Royal Charter on Self-Regulation of the Press, granted by the Privy Council in October 2013, required the Recognition Panel to report annually if regulation does not cover all significant relevant publishers (Royal Charter on Self-Regulation of the Press, Oct 2013). In November 2012, Prime Minister David Cameron accepted the Leveson principles, stating that the onus was on the press to implement them (David Cameron response, Nov 2012).

The membership of a regulatory body should be open to all publishers on fair, reasonable and non-discriminatory terms, including making membership potentially available on different terms for different types of publisher.

The Inquiry recommended that press regulator membership be open fairly to all publishers. David Cameron, Prime Minister, in a statement to the House of Commons on the Leveson Inquiry report in November 2012, accepted the Leveson principles and stated that the onus was on the press to implement them radically (David Cameron response, Nov 2012). The Royal Charter on Self-Regulation of the Press, granted by the Privy Council in October 2013, provided that membership of a regulatory body should be open to all publishers on fair, reasonable and non-discriminatory terms, including different terms for different publisher types (Royal Charter on Self-Regulation of the Press, Oct 2013).

In any reconsideration of the powers of the Information Commissioner (or replacement body), power should be given to that body to determine that membership of a satisfactory regulatory body, which required appropriate governance and transparency standards from its members in relation to compliance with data protection legislation and good practice, should be taken into account when considering whether it is necessary or proportionate to take any steps in relation to a subscriber to that body.

The Inquiry recommended taking regulatory body membership into account during data protection enforcement. In January 2013, the Information Commissioner’s Office (ICO) acknowledged "the importance of Lord Justice Leveson’s recommendations about the recognition the ICO might be able to give" (Information Commissioner’s Office response, Jan 2013). The response does not mention statutory powers or considering membership when taking enforcement steps (Information Commissioner’s Office response, Jan 2013).

It should be open any subscriber to a recognised regulatory body to rely on the fact of such membership and on the opportunity it provides for the claimant to use a fair, fast and inexpensive arbitration service. It could request the court to encourage the use of that system of arbitration and, equally, to have regard to the availability of the arbitration system when considering claims for costs incurred by a claimant who could have used the arbitration service. On the issue of costs, it should equally be open to a claimant to rely on failure by a newspaper to subscribe to the regulator thereby depriving him or her of access to a fair, fast and inexpensive arbitration service. Where that is the case, in the exercise of its discretion, the court could take the view that, even where the defendant is successful, absent unreasonable or vexatious conduct on the part of the claimant, it would be inappropriate for the claimant to be expected to pay the costs incurred in defending the action.

The Inquiry asked the government to adjust court costs rules to encourage recognised arbitration. In May 2024, section 50(2) of the Media Act 2024, enacted by Parliament, provided that "Section 40 (awards of costs) is omitted" (Media Act 2024, section 50, May 2024). In March 2018, Matt Hancock, Secretary of State for Digital, Culture, Media and Sport, stated that the government decided not to commence Section 40 of the Crime and Courts Act 2013 and would seek repeal, with the department confirming it would find a legislative vehicle to repeal the provision without commencing it first (Matt Hancock response, Mar 2018; Department for Digital, Culture, Media and Sport, Mar 2018; Matt Hancock, Mar 2018; Department for Digital, Culture, Media and Sport, Mar 2018). In March 2013, David Cameron, Prime Minister, had stated that costs rules in civil claims against publishers would be changed to incentivise joining a regulator (David Cameron, Mar 2013).

In order to meet the public concern that the organisation by the press of its regulation is by a body which is independent of the press, independent of Parliament and independent of the Government, that fulfils the legitimate requirements of such a body and can provide, by way of benefit to its subscribers, recognition of involvement in the maintenance of high standards of journalism, the law must identify those legitimate requirements and provide a mechanism to recognise and certify that a new body meets them.

The Inquiry recommended establishing legal requirements and a mechanism to recognise independent press regulators. In the Royal Charter on Self-Regulation of the Press, granted by the Privy Council in October 2013, recitals addressed the recommendation for a recognition body to certify independent press regulators (Royal Charter on Self-Regulation of the Press, Oct 2013). Earlier, in March 2013, David Cameron, Prime Minister, stated that statutory regulation to create a recognition body was not necessary and announced that it would be achieved "via a royal charter" (David Cameron response, Mar 2013).

The responsibility for recognition and certification of a regulator shall rest with a recognition body. In its capacity as the recognition body, it will not be involved in regulation of any subscriber.

The Inquiry recommended establishing a recognition body to certify regulators without directly regulating subscribers. The Royal Charter on Self-Regulation of the Press, granted by the Privy Council in October 2013, recited that a recognition body should certify independent regulators without being involved in regulating the press (Royal Charter on Self-Regulation of the Press, Oct 2013). Earlier, David Cameron, Prime Minister, stated in March 2013 that statutory regulation to create a recognition body was unnecessary and that it would be established through a royal charter (David Cameron response, Mar 2013).

The requirements for recognition should be those set out the recommendations set out above numbered 1 to 24 inclusive and more fully described in Part K, Chapter 7, Section 4 of the Report.

The Inquiry asked the UK Government to base regulator recognition requirements on recommendations 1 to 24. The Royal Charter on Self-Regulation of the Press, granted by the Privy Council in October 2013, provided that the Board of the Recognition Panel shall grant recognition if a regulator meets recognition criteria 1 to 23, with the Board required to consider the concepts articulated in Part K, Chapter 7, Section 4 of the Leveson Report when making its decision (Royal Charter on Self-Regulation of the Press, Oct 2013). Earlier, in a March 2013 House of Commons speech, David Cameron, Prime Minister, stated that statutory regulation was unnecessary because the Leveson principles would be achieved through a royal charter (David Cameron response, Mar 2013).

The operation of any certified body should be reviewed by the recognition body after two years and thereafter at three yearly intervals.

The Inquiry recommended reviewing any certified press regulator after two years and every three years. The Royal Charter on Self-Regulation of the Press, granted by the Privy Council in October 2013, specifies that the Board of the Recognition Panel must review a regulator after two years and every three years thereafter (Royal Charter on Self-Regulation of the Press, Oct 2013). Earlier, in March 2013, Prime Minister David Cameron stated that statutory regulation was "not necessary to achieve the Leveson principles" and would instead be carried out through a royal charter (David Cameron response, Mar 2013).

The role of recognition body, that is to say, to recognise and certify that any particular body satisfies (and, on review, continues to satisfy) the requirements set out in law should fall on Ofcom. A less attractive alternative (on the basis that any individual will not have the requisite authority or experience and will only be occasionally be required to fulfil these functions) is for the appointment of an independent Recognition Commissioner supported by officials at Ofcom.

The Inquiry recommended that Ofcom or an independent commissioner serve as press recognition body. In March 2013, Prime Minister David Cameron rejected appointing the regulator, explaining that he had "grave misgivings" about giving the task to an already powerful body and opted to establish a recognition body through a royal charter instead (David Cameron response, Mar 2013; David Cameron, Mar 2013). The alternative of an independent Recognition Commissioner supported by its officials was not mentioned in the statement (David Cameron response, Mar 2013; David Cameron, Mar 2013).

It should be possible for the recognition body to recognise more than one regulatory body, should more than one seek recognition and meet the criteria, although this is not an outcome to be advocated and, should it be necessary for that step to be taken, would represent a failure on the part of the industry.

The Inquiry recommended enabling the recognition body to recognise more than one regulatory body. In March 2013, David Cameron stated that creating a recognition body to achieve the Leveson principles would proceed through a royal charter rather than statutory regulation, without addressing multiple regulatory bodies (David Cameron response, Mar 2013). In February 2026, the Press Recognition Panel found that the recognition framework permits it to recognise more than one qualifying regulator (Press Recognition Panel, Feb 2026). The panel noted that Impress became the initial recognised regulator in 2016 and remains the single body to meet all requirements, confirmed across three cyclical reviews (Press Recognition Panel, Feb 2026).

In passing legislation to identify the legitimate requirements to be met by an independent regulator organised by the press, and to provide for a process of recognition and review of whether those requirements are and continue to be met, the law should also place an explicit duty on the Government to uphold and protect the freedom of the press.

The Inquiry recommended placing a statutory duty on ministers to uphold press freedom. In March 2013, Prime Minister David Cameron stated that statutory regulation to create a recognition body was not necessary and would instead be achieved through a royal charter (David Cameron response, Mar 2013; David Cameron, Mar 2013). An explicit legal duty to uphold and protect press freedom is not mentioned in the sources (David Cameron response, Mar 2013; David Cameron, Mar 2013).

In addition to Recommendation 10 above, a new regulatory body should consider requiring: (a) that newspapers publish compliance reports in their own pages to ensure that their readers have easy access to the information; and (b) as proposed by Lord Black, that a named senior individual within each title should have responsibility for compliance and standards.

The Inquiry asked that regulators consider requiring newspaper compliance reports and senior standards leads. In a statement to the House of Commons on the Leveson Inquiry report in November 2012, David Cameron, Prime Minister, accepted the central principles of independent self-regulation, stating that the onus was on the press to implement them (David Cameron response, Nov 2012). The Royal Charter on Self-Regulation of the Press, granted by the Privy Council in October 2013, provided that the Board of the Recognition Panel may take this recommendation into account when considering an application, but shall not refuse recognition to a regulator for failing to comply with it (Royal Charter on Self-Regulation of the Press, Oct 2013).

A new regulatory body should consider establishing a kite mark for use by members to establish a recognised brand of trusted journalism.

The Inquiry recommended that press regulators consider establishing a kite mark for trusted journalism. In a statement to the House of Commons on the Leveson Inquiry report in November 2012, David Cameron, Prime Minister, accepted the inquiry's regulatory principles and stated that the onus was on the press to implement them, without mentioning a kite mark (David Cameron response, Nov 2012). The Royal Charter on Self-Regulation of the Press, granted by the Privy Council in October 2013, provided that the Recognition Panel may take this recommendation into account when assessing a regulator, but cannot refuse recognition if a regulator does not meet it (Royal Charter on Self-Regulation of the Press, Oct 2013).

A regulatory body should consider engaging in an early thorough review of the Code (on which the public should be engaged and consulted) with the aim of developing a clearer statement of the standards expected of editors and journalists.

The Inquiry recommended that a press regulatory body review its standards code with public consultation. In a statement to the House of Commons in November 2012, David Cameron, Prime Minister, accepted the principles for independent self-regulation and stated that the onus was on the press to implement them (David Cameron response, Nov 2012). The Royal Charter on Self-Regulation of the Press, granted by the Privy Council in October 2013, provided that the Recognition Panel may take this recommendation into account when determining an application from a regulator, but cannot refuse recognition because of a failure to comply with it (Royal Charter on Self-Regulation of the Press, Oct 2013).

A regulatory body should be prepared to allow a complaint to be brought prior to commencing legal proceedings if so advised. Challenges to that approach (and applications to stay) can be decided on the merits.

The Inquiry recommended that press regulatory bodies allow complaints before legal proceedings commence. In a statement to the House of Commons on the Leveson Inquiry report in November 2012, David Cameron, Prime Minister, accepted the central principles for independent self-regulation, though he did not mention pre-litigation complaints (David Cameron response, Nov 2012). The Royal Charter on Self-Regulation of the Press, granted by the Privy Council in October 2013, specified that a regulatory board should be prepared to allow complaints before legal proceedings commence (Royal Charter on Self-Regulation of the Press, Oct 2013). It added that challenges to that approach and applications to stay can be decided on the merits (Royal Charter on Self-Regulation of the Press, Oct 2013).

In conjunction with Recommendation 11 above, consideration should also be given to Code amendments which, while fully protecting freedom of speech and the freedom of the press, would equip that body with the power to intervene in cases of allegedly discriminatory reporting, and in so doing reflect the spirit of equalities legislation.

The Inquiry recommended code amendments empowering a regulatory body to intervene in discriminatory reporting. In a statement to the House of Commons in November 2012, David Cameron, Prime Minister, accepted the Leveson principles and stated that the onus should be on the press to implement them (David Cameron response, Nov 2012). The Royal Charter on Self-Regulation of the Press, granted by the Privy Council in October 2013, provided that the Recognition Panel may take this recommendation into account when assessing a regulator, but cannot refuse recognition by reason of a failure to comply with it (Royal Charter on Self-Regulation of the Press, Oct 2013).

A new regulatory body should establish a ring-fenced enforcement fund, into which receipts from fines could be paid, for the purpose of funding investigations.

The Inquiry recommended that a new press regulatory body establish a ring-fenced enforcement fund. In November 2012, David Cameron, Prime Minister, in a statement to the House of Commons on the Leveson Inquiry report, accepted the inquiry's principles for independent press self-regulation, including powers to impose fines, but stated that the onus was on the press to implement them (David Cameron response, Nov 2012). The Royal Charter on Self-Regulation of the Press, granted by the Privy Council in October 2013, provided that the regulatory board should establish a ring-fenced enforcement fund from financial sanctions to fund investigations (Royal Charter on Self-Regulation of the Press, Oct 2013).

A new regulatory body should continue to provide advice to the public in relation to issues concerning the press and the Code along with a service to warn the press, and other relevant parties such as broadcasters and press photographers, when an individual has made it clear that they do not welcome press intrusion.

The Inquiry recommended that a new regulatory body provide public advice and intrusion warnings. In a statement to the House of Commons on the Leveson Inquiry report in November 2012, David Cameron, Prime Minister, accepted the principles of independent self-regulation and stated that the onus was on the press to implement them, though the statement did not mention advice or warning services (David Cameron response, Nov 2012). In October 2013, the Royal Charter on Self-Regulation of the Press, granted by the Privy Council, provided that a self-regulatory body should advise the public on press and standards code issues and warn the press, broadcasters, and press photographers when an individual states that press intrusion is unwelcome (Royal Charter on Self-Regulation of the Press, Oct 2013).

A new regulatory body should make it clear that newspapers will be held strictly accountable, under their standards code, for any material that they publish, including photographs (however sourced).

The Inquiry recommended that a new regulatory body hold newspapers strictly accountable for published material. In a statement to the House of Commons in November 2012, David Cameron, Prime Minister, accepted the Leveson principles and stated that the onus was on the press to implement them (David Cameron response, Nov 2012). In October 2013, the Royal Charter on Self-Regulation of the Press, granted by the Privy Council, set a criterion that a regulatory body should ensure subscribers are held strictly accountable under their standards code for published material, excluding advertising (Royal Charter on Self-Regulation of the Press, Oct 2013).

A regulatory body should provide guidance on the interpretation of the public interest that justifies what would otherwise constitute a breach of the Code. This must be framed in the context of the different provisions of the Code relating to the public interest, so as to make it easier to justify what might otherwise be considered as contrary to standards of propriety.

The Inquiry recommended that a press regulator provide guidance on interpreting the public interest. In a statement to the House of Commons on the Leveson Inquiry report in November 2012, David Cameron, Prime Minister, accepted the principles for independent press self-regulation and stated that the onus was on the press to implement them, without mentioning public interest guidance (David Cameron response, Nov 2012). The Royal Charter on Self-Regulation of the Press, granted by the Privy Council in October 2013, set out that a self-regulatory body should provide non-binding guidance on interpreting the public interest in the context of different code provisions to justify what would otherwise breach standards (Royal Charter on Self-Regulation of the Press, Oct 2013).

A new regulatory body should consider being explicit that where a public interest justification is to be relied upon, a record should be available of the factors weighing against and in favour of publication, along with a record of the reasons for the conclusion reached.

The Inquiry asked press regulators to consider requiring records for public interest justifications. In a statement to the House of Commons in November 2012, David Cameron, Prime Minister, accepted the Leveson principles for independent self-regulation, stating that the onus was on the press to implement them (David Cameron response, Nov 2012). The Royal Charter on Self-Regulation of the Press, granted by the Privy Council in October 2013, provided that the Recognition Panel may, but need not, take this recommendation into account when determining an application for recognition, and cannot refuse recognition by reason of a failure to comply with it (Royal Charter on Self-Regulation of the Press, Oct 2013).

A new regulatory body should consider whether it might provide an advisory service to editors in relation to consideration of the public interest in taking particular actions.

The Inquiry recommended that a press regulator consider offering public interest advice to editors. In November 2012, David Cameron, Prime Minister, stated to the House of Commons that he accepted the Leveson principles and that the onus lay with the press to put them in place (David Cameron response, Nov 2012). The Royal Charter on Self-Regulation of the Press, granted by the Privy Council in October 2013, provided that a regulatory body should give non-binding guidance on interpreting the public interest that justifies code breaches, and that its board should have discretion to advise editors on code compliance (Royal Charter on Self-Regulation of the Press, Oct 2013; Royal Charter on Self-Regulation of the Press, Oct 2013).

A new regulatory body should consider encouraging the press to be as transparent as possible in relation to the sources used for stories, including providing any information that would help readers to assess the reliability of information from a source and providing easy access, such as web links, to publicly available sources of information such as scientific studies or poll results. This should include putting the names of photographers alongside images. This is not in any way intended to undermine the existing provisions on protecting journalists' sources, only to encourage transparency where it is both possible and appropriate to do so.

The Inquiry recommended that a new regulatory body encourage press source transparency. In a statement to the House of Commons on the Leveson Inquiry report in November 2012, David Cameron, Prime Minister, accepted the central recommendations on independent self-regulation and stated that the onus was on the press to implement them (David Cameron response, Nov 2012). The Royal Charter on Self-Regulation of the Press, granted by the Privy Council in October 2013, provided that the Recognition Panel may take recommendation 45 into account but cannot refuse recognition for non-compliance (Royal Charter on Self-Regulation of the Press, Oct 2013).

A regulatory body should establish a whistleblowing hotline for those who feel that they are being asked to do things which are contrary to the code.

The Inquiry recommended that a press regulatory body establish a whistleblowing hotline. In November 2012, David Cameron, Prime Minister, in his statement to the House of Commons on the Leveson Inquiry report, accepted the Leveson principles and stated that the onus was on the press to implement them, though a whistleblowing hotline was not mentioned (David Cameron response, Nov 2012). The Royal Charter on Self-Regulation of the Press, granted by the Privy Council in October 2013, provided that a self-regulatory body should establish a whistleblowing hotline for those who feel asked to act contrary to the standards code (Royal Charter on Self-Regulation of the Press, Oct 2013).

The industry generally and a regulatory body in particular should consider requiring its members to include in the employment or service contracts with journalists a clause to the effect that no disciplinary action would be taken against a journalist as a result of a refusal to act in a manner which is contrary to the code of practice.

The Inquiry recommended contractual protections for journalists refusing to breach codes of practice. The Royal Charter on Self-Regulation of the Press, granted by the Privy Council in October 2013, addressed this for press regulators applying for recognition (Royal Charter on Self-Regulation of the Press, Oct 2013). It provided that the board of the Recognition Panel may, but need not, take recommendation 47 into account when determining an application (Royal Charter on Self-Regulation of the Press, Oct 2013). It also specified that the panel must not refuse recognition because of a failure to comply with this recommendation, provided the regulator meets the recognition criteria (Royal Charter on Self-Regulation of the Press, Oct 2013).

The exemption in section 32 of the Data Protection Act 1998 should be amended so as to make it available only where: (a) the processing of data is necessary for publication, rather than simply being in fact undertaken with a view to publication; (b) the data controller reasonably believes that the relevant publication would be or is in the public interest, with no special weighting of the balance between the public interest in freedom of expression and in privacy; and (c) objectively, that the likely interference with privacy resulting from the processing of the data is outweighed by the public interest in publication.

The Inquiry recommended amending the Data Protection Act exemption for journalism. In December 2017, Lord Keen of Elie, Advocate-General for Scotland, responding for the UK Government, addressed the recommendation regarding special weighting, stating that weighting for freedom of expression and information was "an essential way of ensuring that information that is in the public interest is not buried" (Lord Keen of Elie, Dec 2017). In November 2012, Prime Minister David Cameron stated that proposals reducing the special treatment afforded to journalists under data protection legislation required careful consideration (David Cameron response, Nov 2012; David Cameron, Nov 2012).

The exemption in section 32 of the Data Protection Act 1998 should be narrowed in scope, so that it no longer allows, by itself, for exemption from: (a) the requirement of the first data protection principle to process personal data fairly (except in relation to the provision of information to the data subject under paragraph 2(1)(a) of Part II Schedule 1 to the 1998 Act) and in accordance with statute law; (b) the second data protection principle (personal data to be obtained only for specific purposes and not processed incompatibly with those purposes); (c) the fourth data protection principle (personal data to be accurate and kept up to date); (d) the sixth data protection principle (personal data to be processed in accordance with the rights of individuals under the Act); (e) the eighth data protection principle (restrictions on exporting personal data); and (f) the right of subject access. The recommendation on the removal of the right of subject access from the scope of section 32 is subject to any necessary clarification that the law relating to the protection of journalists' sources is not affected by the Act.

The Inquiry recommended narrowing the scope of data protection exemptions available to journalists. In December 2017, Lord Keen of Elie, Advocate-General for Scotland, stated for the UK Government that the Data Protection Bill protected journalists relying on exemptions for public interest journalism regardless of regulator membership, though the specific restrictions named in the recommendation were not mentioned (Lord Keen of Elie, Dec 2017). Earlier, in November 2012, Prime Minister David Cameron told the House of Commons that proposals reducing special data protection treatment for journalists required careful consideration regarding their potential effect on investigative journalism (David Cameron response, Nov 2012; David Cameron, Nov 2012).

It should be made clear that the right to compensation for distress conferred by section 13 of the Data Protection Act 1998 is not restricted to cases of pecuniary loss, but should include compensation for pure distress.

The procedural provisions of the Data Protection Act 1998 with special application to journalism in: (a) section 32(4) and (5) (b) sections 44 to 46 inclusive should be repealed.

The Inquiry recommended repealing specific procedural provisions for journalism under data protection legislation. In November 2012, Prime Minister David Cameron stated that proposals reducing special data protection treatment for journalists required careful consideration, noting he was "instinctively concerned" about the impact on investigative journalism, though sections 32(4), 32(5), and 44 to 46 are not mentioned in the sources (David Cameron response, Nov 2012; David Cameron, Nov 2012).

In conjunction with the repeal of those procedural provisions, consideration should be given to the desirability of including in the Data Protection Act 1998 a provision to the effect that, in considering the exercise of any powers in relation to the media or other publishers, the Information Commissioner's Office should have special regard to the obligation in law to balance the public interest in freedom of expression alongside the public interest in upholding the data protection regime.

Specific provision should be made to the effect that, in considering the exercise of any of its powers in relation to the media or other publishers, the Information Commissioner's Office must have regard to the application to a data controller of any relevant system of regulation or standards enforcement which is contained in or recognised by statute.

The necessary steps should be taken to bring into force the amendments made to section 55 of the Data Protection Act 1998 by section 77 of the Criminal Justice and Immigration Act 2008 (increase of sentence maxima) to the extent of the maximum specified period; and by section 78 of the 2008 Act (enhanced defence for public interest journalism).

The Inquiry recommended commencing increased penalties and journalistic defences for unlawfully obtaining data. In May 2018, the Department for Digital, Culture, Media and Sport and the Home Office stated that the provisions were omitted and never commenced, explaining that offences, defences, and penalties were instead set out in the Data Protection Act 2018 (Data Protection Act 2018: Explanatory Notes, May 2018). Earlier, in January 2013, Helen Grant, Parliamentary Under-Secretary of State at the Ministry of Justice, stated that the Government was considering whether to introduce them given potential consequences for investigative journalism (Helen Grant, Jan 2013). In November 2012, Prime Minister David Cameron stated that the Government needed to look at the issue very carefully (David Cameron response, Nov 2012; David Cameron, Nov 2012).

The prosecution powers of the Information Commissioner should be extended to include any offence which also constitutes a breach of the data protection principles.

A new duty should be introduced (whether formal or informal) for the Information Commissioner's Office to consult with the Crown Prosecution Service in relation to the exercise of its powers to undertake criminal proceedings.

The opportunity should be taken to consider amending the Data Protection Act 1998 formally to reconstitute the Information Commissioner's Office as an Information Commission, led by a Board of Commissioners with suitable expertise drawn from the worlds of regulation, public administration, law and business, and active consideration should be given in that context to the desirability of including on the Board a Commissioner from the media sector.

The Inquiry asked the Government to reconstitute the Information Commissioner's Office as an Information Commission. In September 2026, Stephanie Peacock, Parliamentary Under-Secretary of State for Digital, Culture, Media and Sport, stated that regulations had commenced sections of the Data (Use and Access) Act 2025 to abolish the office and transfer its functions to a new Information Commission on 30 September (Stephanie Peacock, Sep 2026; Stephanie Peacock, Sep 2026). The Minister explained that the body corporate would have non-executive and executive members with collective responsibility for decision-making, though the statement did not address board expertise or including a commissioner from the media sector (Stephanie Peacock, Sep 2026; Stephanie Peacock, Sep 2026).

The Information Commissioner's Office should take immediate steps to prepare, adopt and publish a policy on the exercise of its formal regulatory functions in order to ensure that the press complies with the legal requirements of the data protection regime.

The Inquiry asked the Information Commissioner's Office to publish a press regulation policy. In January 2013, it accepted the recommendation and stated that it was revising its Data Protection Regulatory Action Policy to address how it would regulate the press (Information Commissioner's Office response, Jan 2013). That statement described revising the policy, but did not mention adopting or publishing it (Information Commissioner's Office response, Jan 2013).

In discharge of its functions and duties to promote good practice in areas of public concern, the Information Commissioner's Office should take immediate steps, in consultation with the industry, to prepare and issue comprehensive good practice guidelines and advice on appropriate principles and standards to be observed by the press in the processing of personal data. This should be prepared and implemented within six months from the date of this Report.

The Inquiry asked the Information Commissioner's Office to publish data protection guidance for the press. In September 2014, it published guidance for the media explaining data protection obligations, clarifying journalism exemptions, and advising on good practice (Information Commissioner's Office, Sep 2014). It had previously reported in June 2013 that it had consulted on developing guidance for the press and on issuing it as a code of practice (Information Commissioner's Office, Jun 2013). In January 2013, it recognised the need to prepare guidance based on data protection law as it then stood and the importance of consultation with the press and broadcasting industry (Information Commissioner's Office response, Jan 2013).

The Information Commissioner's Office should take steps to prepare and issue guidance to the public on their individual rights in relation to the obtaining and use by the press of their personal data, and how to exercise those rights.

The Inquiry asked the Information Commissioner's Office to publish public guidance on press data rights. In January 2013, it stated that it recognised the importance of developing this guidance and would publish it alongside a proposed code of practice, aiming to have it ready by the end of May 2013 (Information Commissioner's Office response, Jan 2013).

In particular, the Information Commissioner's Office should take immediate steps to publish advice aimed at individuals (data subjects) concerned that their data have or may have been processed by the press unlawfully or otherwise than in accordance with good practice.

The Inquiry asked the Information Commissioner's Office to publish advice on press data processing. In January 2013, it stated that it understood the importance of ensuring that individuals are aware of their rights if their data has been unlawfully processed by the press, but publishing advice was not mentioned in the source (Information Commissioner's Office response, Jan 2013).

The Information Commissioner's Office, in the Annual Report to Parliament which it is required to make by virtue of section 52(1) of the Act, should include regular updates on the effectiveness of the foregoing measures, and on the culture, practices and ethics of the press in relation to the processing of personal data.

The Inquiry asked the Information Commissioner's Office (ICO) to report annually on press data practices. In January 2013, it stated that it accepted "the spirit of this recommendation" and would provide regular updates to Parliament on the effectiveness of its measures and on press culture, practices and ethics regarding personal data (Information Commissioner's Office response, Jan 2013).

The Information Commissioner's Office should immediately adopt the Guidelines for Prosecutors on assessing the public interest in cases affecting the media, issued by the Director of Public Prosecutions in September 2012.

The Inquiry asked the Information Commissioner's Office to adopt prosecution guidelines for media cases. The office stated in January 2013 that, by the time the Inquiry's report was published, it had already endorsed and adopted the September 2012 guidelines issued by the Director of Public Prosecutions on assessing public interest (Information Commissioner's Office response, Jan 2013).

The Information Commissioner's Office should take immediate steps to engage with the Metropolitan Police on the preparation of a long-term strategy in relation to alleged media crime with a view to ensuring that the Office is well placed to fulfil any necessary role in this respect in the future, and in particular in the aftermath of Operations Weeting, Tuleta and Elveden.

The Inquiry asked the Information Commissioner's Office to agree a media crime strategy with police. In January 2013, it accepted the recommendation, explaining that it had begun engaging with the Metropolitan Police Service (MPS) and the Association of Chief Police Officers (ACPO) to establish formal policies, though it did not mention Operations Weeting, Tuleta or Elveden (Information Commissioner's Office response, Jan 2013). It stated that it would meet with the MPS in January 2013 to set out protocols and amend guidance (Information Commissioner's Office response, Jan 2013).

The Information Commissioner's Office should take the opportunity to review the availability to it of specialist legal and practical knowledge of the application of the data protection regime to the press, and to any extent necessary address it.

The Inquiry asked the Information Commissioner to review specialist knowledge regarding the press. In January 2013, the Information Commissioner's Office stated that it had undertaken the review and recognised the need for more specialist knowledge of press workings and data protection, but addressing that need was not mentioned in the sources (Information Commissioner's Office response, Jan 2013).

The Information Commissioner's Office should take the opportunity to review its organisation and decision-making processes to ensure that large-scale issues, with both strategic and operational dimensions (including the relationship between the culture, practices and ethics of the press in relation to personal information on the one hand, and the application of the data protection regime to the press on the other) can be satisfactorily considered and addressed in the round.

The Inquiry asked the Information Commissioner's Office to review its organisation and decision-making processes. In January 2013, it stated that its management structure and controls were very different from those that existed during the events examined in detail by the Inquiry (Information Commissioner's Office response, Jan 2013). It explained in January 2013 that its current arrangements were designed to ensure that large-scale issues with both strategic and operational dimensions are properly considered and addressed in the round (Information Commissioner's Office response, Jan 2013). The record holds nothing dated later than the response of January 2013 (Information Commissioner's Office response, Jan 2013).

On the basis that the provisions of s77-78 of the Criminal Justice and Immigration Act 2008 are brought into effect, so that increased sentencing powers are available for breaches of s55 of the Data Protection Act 1998, the Secretary of State for Justice should use the power vested in him by s124(1)(a)(i) of the Coroners and Justice Act 2009 to invite the Sentencing Council of England and Wales to prepare guidelines in relation to data protection offences (including computer misuse).

The Inquiry asked the government to request sentencing guidelines for data protection offences. In May 2018, the Department for Digital, Culture, Media and Sport and the Home Office stated that sections 77 to 78 of the Criminal Justice and Immigration Act 2008 were never commenced and were omitted (Data Protection Act 2018: Explanatory Notes, May 2018). The departments explained that these provisions were no longer needed because offences, defences, and penalties were set out in the Data Protection Act 2018 (Data Protection Act 2018: Explanatory Notes, May 2018). An invitation for the Sentencing Council of England and Wales to prepare guidelines is not mentioned in the sources (Data Protection Act 2018: Explanatory Notes, May 2018).

The Home Office should consider and, if necessary, consult upon: (a) whether paragraph 2(b) of Schedule 1 to the Police and Criminal Evidence Act 1984 (PACE) should be repealed; (b) whether PACE should be amended to provide a definition of the phrase "for the purposes of journalism" in s13(2); and (c) whether s11(3) of PACE should be amended by providing that journalistic material is only held in confidence for the PACE provisions if it is held or has continuously been held since it was first acquired or created subject to an enforceable or lawful undertaking, restriction or obligation.

The Inquiry asked the Home Office to consider amending statutory protections for journalistic material. In May 2024, Lord Sharpe of Epsom, Parliamentary Under-Secretary of State at the department, stated that "All the recommendations have been addressed", though his answer did not mention the specific amendments to the Police and Criminal Evidence Act 1984 (PACE) (Lord Sharpe of Epsom, May 2024). Earlier, in February 2013, the department accepted the recommendation and announced that it would consult before the end of 2013 on proposed changes to PACE, including the protection of journalistic sources (Home Office response, Feb 2013; Home Office, Feb 2013).

There should be a review of damages generally available for breach of data protection, privacy, breach of confidence or any other media-related torts, to ensure proportionate compensation including for non-pecuniary loss (all referable to the duration, extent and gravity of the contravention).

The Inquiry recommended a review of damages available for media torts and privacy breaches. In a written parliamentary answer in April 2013, Jeremy Wright, Parliamentary Under-Secretary of State for Justice, stated that the Civil Justice Council was to consider damages awarded for certain media torts following its work on costs protection (Jeremy Wright, Apr 2013). The Minister noted that taking this forward would ultimately be for the courts to consider, though the statement did not mention breach of data protection, privacy, breach of confidence, or non-pecuniary loss (Jeremy Wright, Apr 2013).

The Civil Justice Council should consider the level of damages in privacy, breach of confidence and data protection cases, being prepared to take evidence (from the Information Commissioner, the media and others) and thereafter to make recommendations on the appropriate level of damages for distress in such cases. How the matter is then taken forward will ultimately be for the courts to consider.

The Inquiry recommended that the Civil Justice Council review media damages for distress. In an April 2013 written answer, Jeremy Wright, Parliamentary Under-Secretary of State for Justice, stated that the council would consider damages awarded for certain media torts following its work on costs protection (Jeremy Wright, Apr 2013). The Minister did not mention taking evidence from the Information Commissioner or other parties, and the answer did not specify data protection (Jeremy Wright, Apr 2013). The Minister affirmed that how the issue is taken forward would ultimately be for the courts to consider (Jeremy Wright, Apr 2013).

The Report of the Law Commission on Aggravated, Exemplary and Restitutionary Damages should be adopted in relation to its recommendations that legislation should provide that: (a) aggravated damages should only be awarded to compensate for mental distress and should have no punitive element; (b) exemplary damages should be retained (although re-titled as punitive damages).

The Inquiry recommended adopting Law Commission proposals on aggravated and exemplary damages legislation. In April 2013, Jeremy Wright, Parliamentary Under-Secretary of State for Justice, stated that provisions in the Crime and Courts Bill before Parliament gave effect to the recommendations on aggravated and exemplary damages (Jeremy Wright, Apr 2013). The Minister explained that these provisions would introduce "strong and effective incentives" for relevant publishers to join a recognised independent self-regulator (Jeremy Wright, Apr 2013). The Minister did not mention adopting the Law Commission report, restricting aggravated damages to mental distress, or retitling exemplary damages as punitive damages (Jeremy Wright, Apr 2013).

Exemplary damages (whether so described or renamed as punitive damages) should be available for actions for breach of privacy, breach of confidence and similar media torts, as well as for libel and slander. The application to a defendant of any relevant system of regulation of standards enforcement which is contained in or recognised by statute and good internal governance in relation to the sourcing of stories should be relevant to the decisions reached in relation to such damages.

The Inquiry asked the UK Government to make exemplary damages available for media torts. In March 2018, the Department for Digital, Culture, Media and Sport stated that exemplary damages provisions in sections 34 to 38 of the Crime and Courts Act 2013 commenced in November 2015, exempting publishers in a recognised regulator from exemplary damages in relevant media-related court cases, though internal governance was not mentioned (Department for Digital, Culture, Media and Sport, Mar 2018). Prime Minister David Cameron had confirmed in March 2013 that the Government accepted the recommendation and would establish exemplary damages through legislation (David Cameron response, Mar 2013).

The Civil Procedure Rules should be amended to require the court, when considering the appropriate order for costs at the conclusion of proceedings, to take into account the availability of an arbitral system set up by an independent regulator itself recognised by law. The purpose of this recommendation is to provide an important incentive for every publisher to join the new system and encourage those who complain that their rights have been infringed to use it as a speedy, effective and comparatively inexpensive method of resolving disputes.

The Inquiry recommended amending civil court costs rules to incentivise joining a recognised regulator. In May 2024, Parliament enacted the Media Act 2024, which omitted section 40 of the Crime and Courts Act 2013 on awards of costs (Media Act 2024, section 50, May 2024). In February 2024, Julia Lopez, Minister of State at the Department for Culture, Media and Sport, stated that the government was not proposing to instruct the Civil Procedure Rule Committee to amend rules of court to support section 40, aligning with its commitment to repeal it (Julia Lopez, Feb 2024).

In the absence of the provision of an approved mechanism for dispute resolution, available through an independent regulator without cost to the complainant, together with an adjustment to the Civil Procedure Rules to require or permit the court take account of the availability of cost free arbitration as an alternative to court proceedings, qualified one way costs shifting should be introduced for defamation, privacy, breach of confidence and similar media related litigation as proposed by Lord Justice Jackson.

The Inquiry recommended introducing qualified one-way costs shifting for media litigation without approved arbitration. In November 2018, the Ministry of Justice stated that the Government did not believe introducing a bespoke costs protection regime was "the right way forward" (Ministry of Justice, Nov 2018; Ministry of Justice, Nov 2018). Previously, in March 2018, Matt Hancock, Secretary of State for Digital, Culture, Media and Sport, announced a decision not to commence Section 40 of the Crime and Courts Act 2013 (Matt Hancock response, Mar 2018). In April 2013, Jeremy Wright, Parliamentary Under-Secretary of State for Justice, stated that the Government was considering advice received from the Civil Justice Council (Jeremy Wright, Apr 2013).

The term 'off-the-record briefing' should be discontinued. The term 'non-reportable briefing' should be used to cover a background briefing which is not to be reported, and the term 'embargoed briefing' should be used to cover a situation where the content of the briefing may be reported but not until a specified event or time. These terms more neutrally describe what are legitimate police and media interactions.

The Inquiry recommended that police replace off-the-record briefings with non-reportable or embargoed briefings. In May 2024, Lord Sharpe of Epsom, Parliamentary Under-Secretary of State at the Home Office, stated that recommendations on the police and the press had been accepted by the National Police Chiefs' Council (NPCC) and were all addressed (Lord Sharpe of Epsom, May 2024). In October 2025, the College of Policing updated its media relations guidance, stating: "Avoid the term 'off the record' as the basis for a conversation" (College of Policing, Oct 2025).

It should be mandatory for ACPO rank officers to record all of their contact with the media, and for that record to be available publicly for transparency and audit purposes. This record need be no more than a very brief note to the effect that a conversation has taken place and the subject matter of that conversation. Where the discussion involves a more significant operational or organisational matter, then it may be sensible for a more detailed note to be retained. Finally, in circumstances where policy or organisation matters may be on the agenda for discussion, it is good practice for a press officer also to be present.

The Inquiry recommended that chief police officers publicly record all contact with the media. In a May 2024 written answer, Lord Sharpe of Epsom, Parliamentary Under-Secretary of State at the Home Office, relayed that the recommendation was accepted by the Association of Chief Police Officers, superseded by the National Police Chiefs’ Council (NPCC), and stated that "All the recommendations have been addressed" (Lord Sharpe of Epsom, May 2024). In Authorised Professional Practice updated in October 2025, the College of Policing stated that chief officers should publicly record all media contact where policing matters are discussed (College of Policing, Oct 2025).

The simple rule included within the 'Interim ACPO Guidance for Relationships with the Media' should be adopted as good practice. This is: "Police officers and staff should ask: 'am I the person responsible for communicating about this issue and is there a policing purpose for doing so?' If the answer to both parts of this question is 'yes', they should go ahead."

The Inquiry recommended adopting a simple rule to govern police contact with the media. In May 2024, Lord Sharpe of Epsom, Parliamentary Under-Secretary of State at the Home Office, stated that recommendations on the press and the police had been accepted by the National Police Chiefs' Council (NPCC) and addressed (Lord Sharpe of Epsom, May 2024). In October 2025, the College of Policing published updated Authorised Professional Practice on media relations, confirming that officers and staff should communicate with journalists if they are responsible for the issue and have a policing purpose (College of Policing, Oct 2025).

The Police Service should re-examine the rigour of the auditing process and the frequency of the conduct of audits in relation to access to the Police National Computer (PNC). Additional consideration should also be given to the number of people given access to the PNC and the associated rules which govern its usage.

The Inquiry recommended reviewing Police National Computer access rules and audit rigour. In May 2024, Lord Sharpe of Epsom, Parliamentary Under-Secretary of State at the Home Office, stated that policing recommendations accepted by the National Police Chiefs' Council had been addressed (Lord Sharpe of Epsom, May 2024). The Minister did not detail the auditing frequency or limits on the number of people granted access (Lord Sharpe of Epsom, May 2024). Earlier, in February 2013, the department reported that the Association of Chief Police Officers supported applying greater rigour to access audits, alongside a planned inspection of the system (Home Office, Feb 2013).

The recent ACPO Guidance should more specifically spell out the dangers of consuming alcohol in a setting of casual hospitality (without necessarily specifying a blanket ban).

The Inquiry asked police guidance to warn against alcohol consumption during casual hospitality. In May 2024, Lord Sharpe of Epsom, Parliamentary Under-Secretary of State at the Home Office, stated that the recommendation was accepted by the then Association of Chief Police Officers (ACPO) and that all policing and press recommendations have been addressed, though the answer did not specifically mention alcohol guidance (Lord Sharpe of Epsom, May 2024). The department had previously reported in February 2013 that ACPO committed to reinforce its guidance on the consumption of alcohol at events (Home Office, Feb 2013).

Consideration should be given to the terms upon which ACPO rank officers are appointed and, in particular, whether these terms should include some limitation upon the nature of any employment within or by the media that can be undertaken without the approval of the relevant authority for a period of 12 months following the cessation of the appointment.

The Inquiry recommended considering 12-month post-employment media work restrictions for senior police officers. In May 2024, Lord Sharpe of Epsom, Parliamentary Under-Secretary of State at the Home Office, stated in a written answer that recommendations on the police and the press had been accepted by the government, the College of Policing, and the former Association of Chief Police Officers (ACPO), and that all had been addressed (Lord Sharpe of Epsom, May 2024). The department had accepted the recommendation in February 2013, noting that it would work on implementation with police and crime commissioners and ACPO (Home Office, Feb 2013).

An enhanced system for protection of whistleblowers and for providing assistance for the Police Service on general ethical issues should at least comprise the following: (a) greater prominence should be given to the Public Interest Disclosure Act (PIDA) telephone line operated by the Independent Police Complaints Commission (IPCC); (b) there should be an 'ethics line' to the IPCC, available for all serving Police Officers, providing general ethical guidance; (c) to avail those at rank of Chief Constable (Assistant Commissioner level within the Metropolitan Police Service), Her Majesty's Inspectorate of Constabulary should identify one of its members, a former Chief Constable, as the designated point of contact for confidential ethics guidance. The Chief Officer seeking and obtaining that advice would be able to refer to it should any issue subsequently arise on a complaint to a Professional Standards Department, a Police and Crime Commissioner, or indeed the IPCC itself. The advice would not be determinative of the complaint, but the fact that it was sought and received, as well as its content, would be a matter to be taken into account; (d) within the IPCC itself, there is a need for an enhanced 'filter system' whereby the nature of complaints are appropriately addressed at an early stage so that (a) they can be investigated at the right level, and (b) sufficient structures are put in place to maintain confidentiality of the complaint, and differentiate as soon as is appropriate between genuine whistleblowers and those who are merely ventilating a personal grievance; (e) the former Chief Constable referred to under sub-paragraph (c) above should also be the recipient of complaints about Chief Constables made to the IPCC. In the event that he or she may already have given informal advice in relation to the subject-matter of the complaint, as per sub-paragraph (c) above, a substitute HMI would be deputed to act; and (f) Chief Officers should also be the subject of regular independent scrutiny by HMIC, including through unannounced inspections.

The Inquiry recommended an enhanced system to protect police whistleblowers and provide ethical guidance. In May 2024, Lord Sharpe of Epsom, Parliamentary Under-Secretary of State at the Home Office, stated that the recommendations were accepted by the then Association of Chief Police Officers, superseded by the National Police Chiefs' Council, and that "all the recommendations have been addressed" (Lord Sharpe of Epsom, May 2024). In March 2018, the Department for Digital, Culture, Media and Sport reported that the Metropolitan Police Service, the College of Policing, and Her Majesty's Inspectorate of Constabulary and Fire & Rescue Services were implementing all law enforcement recommendations, noting that the Policing and Crime Act 2017 strengthened whistleblower protections (Department for Digital, Culture, Media and Sport response, Mar 2018).

As a first step, political leaders should reflect constructively on the merits of publishing on behalf of their party a statement setting out, for the public, an explanation of the approach they propose to take as a matter of party policy in conducting relationships with the press.

Party Leaders, Ministers and Front Bench Opposition spokesmen should consider publishing: (a) the simple fact of long term relationships with media proprietors, newspaper editors or senior executives which might be thought to be relevant to their responsibilities and, (b) on a quarterly basis: i. details of all meetings with media proprietors, newspaper editors or senior executives, whether in person or through agents on either side, and the fact and general nature of any discussion of media policy issues at those meetings; and ii. a fair and reasonably complete picture, by way of general estimate only, of the frequency or density of other interaction (including correspondence, phone, text and email) but not necessarily including content.

The Inquiry asked politicians to publish relevant relationships and regular details of media contacts. In July 2013, Ed Vaizey, Parliamentary Under-Secretary of State for Culture, Media and Sport, stated in a written answer that the government publishes details of meetings held by ministers and special advisers with editors, proprietors, and senior media executives, but did not mention long-term relationships, interaction frequency, or opposition spokespersons (Ed Vaizey, Jul 2013). In November 2012, David Cameron, Prime Minister, had stated to the House of Commons that the government accepted the recommendation (David Cameron response, Nov 2012).

The suggestions that I have made in the direction of greater transparency about meetings and contacts should be considered not just as a future project but as an immediate need, not least in relation to interactions relevant to any consideration of this Report.

The particular public policy goals of ensuring that citizens are informed and preventing too much influence in any one pair of hands over the political process are most directly served by concentrating on plurality in news and current affairs. This focus should be kept under review.

The Inquiry asked ministers to concentrate media plurality policy on news and current affairs. In August 2014, the Department for Culture, Media and Sport concluded that online content should be included within any measurement framework and that news and current affairs is most relevant to media plurality, but it did not mention keeping this focus under review (Department for Culture, Media and Sport response, Aug 2014).

Online publication should be included in any market assessment for consideration of plurality.

The Inquiry recommended that online publication be included in market assessments for media plurality. In August 2014, the Department for Culture, Media and Sport concluded that online publications should be included within the scope of any new measurement framework, noting that news and current affairs content is most relevant to plurality (Department for Culture, Media and Sport response, Aug 2014).

Ofcom and the Government should work, with the industry, on the measurement framework, in order to achieve as great a measure of consensus as is possible on the theory of how media plurality should be measured before the measuring system is deployed, with all the likely commercial tensions that will emerge.

The Inquiry recommended creating a media plurality measurement framework in consultation with industry. In November 2015, Ofcom advised the Secretary of State that, following a request to develop indicators in consultation with industry, it had published a call for inputs in October 2014 and consulted on a draft framework in March 2015 (Ofcom, Nov 2015). Earlier, in August 2014, the Department for Culture, Media and Sport stated that it would commission the regulator to develop suitable indicators in consultation with the industry (Department for Culture, Media and Sport response, Aug 2014).

The levels of influence that would give rise to concerns in relation to plurality must be lower, and probably considerably lower, than the levels of concentration that would give rise to competition concerns.

The Inquiry recommended setting media plurality concern thresholds lower than those for competition. In August 2014, the Department for Culture, Media and Sport stated that it would not consider framework changes until a measurement framework and baseline assessment were delivered (Department for Culture, Media and Sport response, Aug 2014). It explained that its consultation response did not seek to review existing policy levers or propose remedies (Department for Culture, Media and Sport response, Aug 2014).

Ofcom has presented the Inquiry and the Government with a full menu of potential remedies, and it has not been argued or suggested that any of them are inappropriate in principle. Each of them might be appropriate in a given set of circumstances and the relevant regulatory authority should have all of them in its armoury.

The Inquiry recommended that regulatory authorities hold a full menu of media plurality remedies. In a written parliamentary answer in November 2015, Ed Vaizey, Minister of State for Culture and the Digital Economy, stated that Ofcom had published a measurement framework, but the government needed to consider it and how to make a baseline assessment before considering further work in this area (Ed Vaizey, Nov 2015). The Department for Culture, Media and Sport previously stated in its August 2014 consultation report that it would not review existing regulatory levers or propose remedies until both the framework and baseline assessment were produced (Department for Culture, Media and Sport response, Aug 2014).

The Government should consider whether periodic plurality reviews or an extension to the public interest test within the markets regime in competition law is most likely to provide a timely warning of, and response to, plurality concerns that develop as the result of organic growth, recognising that the proposal for a regular plurality review is more closely focussed on plurality issues.

The Inquiry asked the UK Government to consider periodic plurality reviews or competition test extensions. In August 2014, the Department for Culture, Media and Sport stated that it asked the Office of Communications (Ofcom) to develop a measurement framework for a baseline plurality assessment, but that no decision had been made on periodic reviews (Department for Culture, Media and Sport response, Aug 2014). The department added that it was "reserving its position on future media plurality policy until after a baseline assessment", while an extension to the public interest test in competition law was not mentioned (Department for Culture, Media and Sport response, Aug 2014).

Before making a decision to refer a media merger to the competition authorities on public interest grounds, the Secretary of State should consult relevant parties as to the arguments for and against a referral, and should be required to make public his reasons for reaching a decision one way or the other.

The Inquiry recommended consulting relevant parties and publishing reasons regarding media merger referrals. In August 2014, the Department for Culture, Media and Sport stated that it would not consider changes to the regulatory framework for media plurality until a measurement framework and baseline assessment were delivered (Department for Culture, Media and Sport response, Aug 2014). The department noted that its consultation response did not review existing policy levers or propose remedies (Department for Culture, Media and Sport response, Aug 2014).

The Secretary of State should remain responsible for public interest decisions in relation to media mergers. The Secretary of State should be required either to accept the advice provided by the independent regulators, or to explain why that advice has been rejected. At the same time, whichever way the Secretary of State decides the matter, the nature and extent of any submissions or lobbying to which the Secretary of State and his officials and advisors had been subject should be recorded and published.

The Inquiry asked ministers to explain rejected regulator advice and publish lobbying on media mergers. In August 2014, the Department for Culture, Media and Sport stated that the government would not consider changes to the regulatory framework for media plurality until a measurement framework and baseline assessment had been delivered (Department for Culture, Media and Sport response, Aug 2014). Consequently, the department did not review existing regulatory levers or propose potential remedies (Department for Culture, Media and Sport response, Aug 2014).