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 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).

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 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 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).