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Sonia Livingstone and Peter Lunt's work on regulation is the third named theoretical pillar of the AQA A-Level Industries component. Their 2012 paper The Media Regulation Debate: A Decade After the UK Communications Act 2003 analyses the consequences of the 2003 act that created Ofcom and made the case for understanding regulation as a contested political project. In this lesson we will set out their argument, map the UK regulatory landscape, and connect their framework to contemporary debates about online platforms, data, and the Online Safety Act 2023.
Sonia Livingstone is Professor of Social Psychology at the London School of Economics and one of the world's leading researchers on media, children, and the internet. Peter Lunt is Professor of Media and Communication at the University of Leicester. Their collaboration brings together Livingstone's focus on audiences, children, and rights with Lunt's work on consumer culture and regulation. Together, they have examined how the 2003 reforms repositioned the UK media regulatory framework — and in particular how the idea of the "citizen" has been partially displaced by the idea of the "consumer".
Livingstone and Lunt's core argument is that media regulation has shifted from a traditional, protectionist framework aimed at citizens toward a neoliberal framework aimed at consumers. They do not say the shift is total — regulation still contains citizen-protecting elements — but they argue the balance has moved, with important consequences for media content, democracy, and public culture.
Breaking this down:
Let us set out the distinction clearly.
| Dimension | Citizen Model | Consumer Model |
|---|---|---|
| Primary subject | Citizens with rights | Consumers with choices |
| Justification | Democracy, public good | Market efficiency, choice |
| Regulatory stance | Positive obligations (PSB, impartiality) | Negative prohibitions (harm, misleading ads) |
| Funding | Licence fee, public money acceptable | Market funding preferred |
| Typical concerns | Pluralism, accuracy, education | Competition, price, choice |
| Example | BBC charter, impartiality rules | Ofcom spectrum auctions, Competition and Markets Authority rulings |
The citizen model treats media as a public good requiring active shaping; the consumer model treats media as a market requiring only light-touch oversight. Livingstone and Lunt argue Ofcom's remit combines both, but the neoliberal strand has grown stronger over time.
The Communications Act 2003 was a major reshaping of UK media regulation. It:
Ofcom's dual citizen/consumer mandate is the heart of Livingstone and Lunt's analysis. Ofcom has to protect audiences (as citizens) from harm, bias, and offence — classic citizen-model tasks — while also promoting competition, innovation, and consumer choice (neoliberal-model tasks). These can conflict.
flowchart TD
A[Ofcom] --> B[Citizen Duties]
A --> C[Consumer Duties]
B --> B1[Impartiality rules]
B --> B2[Harm & offence protection]
B --> B3[PSB obligations]
B --> B4[Media literacy]
C --> C1[Competition]
C --> C2[Spectrum auctions]
C --> C3[Switching & choice]
C --> C4[Consumer protection]
This is a common source of confusion for A-Level students. Let us be precise.
Ofcom regulates:
Ofcom does NOT regulate:
A crucial historical point for your exam. Before the Online Safety Act 2023 (fully in force from 2024/25), Ofcom had essentially no jurisdiction over social media content. Livingstone and Lunt's original 2012 paper was written in a world where online platforms were largely unregulated. This is a major context for their globalisation argument, which we will come to.
Livingstone and Lunt's second major theme is globalisation. National regulators like Ofcom were designed for national markets. But media increasingly operates across borders:
This creates regulatory gaps and races to the bottom. A streamer operating from Luxembourg may not follow UK PSB rules. A social-media platform based in California may not recognise UK defamation law. Advertising on global platforms may skirt the UK code.
The EU Audiovisual Media Services Directive (AVMSD) and the UK's post-Brexit equivalents attempt to address cross-border broadcasting, but the problem is deep. Livingstone and Lunt argue that globalisation exposes the limits of national regulatory models and calls for new, more international approaches — which remain only partially developed.
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