Financial services firms are not trusted to regulate themselves. After decades of scandals — mis-selling, market manipulation, culture failures — the industry accepted that external, structured oversight was not only appropriate but necessary. Compliance functions became mandatory. Senior managers became personally accountable. Outcomes were measured, not just intentions.
Broadcast media has not had its equivalent reckoning.
The asymmetry of accountability
Consider the parallel. A regulated financial firm must demonstrate that its processes produce fair outcomes for customers. The framework is explicit: document your controls, test them, audit them, and accept that if customers are harmed, there will be consequences for individuals — not just the institution.
A broadcaster, by contrast, can demonstrably mislead millions of viewers for years and face no equivalent personal accountability. Ofcom's regulatory toolkit is slow, opaque, and rarely results in consequences that meaningfully change behaviour. The structure rewards minimising complaints, not maximising accuracy.
This is not a small gap. The reach of major broadcast outlets dwarfs the customer base of most regulated financial firms. The potential for harm — through misinformation, through the amplification of extremism, through the systematic distortion of public understanding — is arguably greater.
The reach of broadcast media dwarfs the customer base of most regulated firms. The potential for harm is arguably greater — yet the accountability framework is a fraction of the rigour.
What financial services compliance actually does
In regulated firms, the compliance function exists to ask hard questions about whether the business is doing what it says it is doing, and whether what it is doing is actually good for its customers.
The key mechanisms are:
First line of defence: the business itself, owning its compliance obligations and embedding controls into its daily operations.
Second line: the compliance function, providing independent oversight, challenge, and assurance that the first line is working.
Third line: internal and external audit, providing independent verification.
This three-lines model is imperfect — compliance failings still occur, often catastrophically — but it is infinitely more structured than anything that exists in broadcast media, where the equivalent of the first line is the editorial team, the second and third lines are absent, and the external regulator has limited investigatory powers and a reluctance to use them.
Applying the framework
What would a financial services-style compliance framework look like applied to broadcast media?
Individual accountability: Senior responsible individuals within broadcasting — editors, programme controllers, compliance officers — should face the prospect of personal accountability for systematic failures, not just institutional censure. The Senior Managers and Certification Regime (SM&CR) has transformed accountability culture in financial services. Something analogous could do the same in media.
Outcome measurement: Compliance in financial services moved decisively away from box-ticking towards outcomes-focused regulation. What actually happened to the customer? In media terms: what did viewers actually believe as a result of this content? What happened to accuracy, to fairness, to the representation of minority voices? These are measurable — imperfectly, but measurably.
Systematic monitoring: Regulated firms are required to monitor their own compliance, record it, and make it available to regulators. Broadcasters do none of this in any systematic way. An AI-powered monitoring system — recording, transcribing, analysing, and flagging content against declared editorial standards — would be a technical challenge but not an impossible one.
Whistleblower protections: Financial services has hard-won protections for individuals who raise compliance concerns internally. Broadcast journalism has a culture of editorial loyalty that actively discourages internal challenge. Creating safe channels for concerns to be raised — and acted upon — would change this.
The objections
The obvious objection is editorial freedom. Any compliance framework for media risks becoming a mechanism for state control of content — an Ofcom with teeth might be an Ofcom with dangerous teeth.
This concern is legitimate but not decisive. The SM&CR does not tell financial firms what products to sell; it holds senior individuals accountable for the systems and processes by which products reach customers. A media equivalent need not tell editors what to say; it would hold them accountable for whether the systems they operate actually produce the accuracy and fairness they claim to provide.
The second objection is practicality. Compliance functions are expensive. Small broadcasters could not sustain them. But the major platforms — BBC, ITV, Sky, GB News, Channel 4 — are not small. They operate significant businesses with significant public impact. The costs of proper compliance structures would be proportionate.
A moment for reform
Public trust in broadcast media is in sustained decline. The industry's response has been largely defensive — pointing to editorial guidelines, pointing to Ofcom, pointing to the fact that regulation already exists. The equivalent argument in financial services — that the industry had codes of conduct and was therefore sufficiently regulated — was recognised as inadequate two decades ago.
The question is not whether broadcast media should face more rigorous accountability. It should. The question is whether the political will exists to design and impose it — and whether the tools to do so are available.
On the second point, at least, the answer is increasingly yes.
David Kershook is a compliance professional and founder of Xelvio, a compliance consultancy, and TalkScore, an AI-powered media integrity analysis platform.