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A summary of Yle´s comment on government proposal on amending the Act on the Finnish Broadcasting Company

Text based content is an important part of the public service. Yle (the Finnish Broadcasting Company) welcomes the fact that the proposed amendment to the Act on the Finnish Broadcasting Company explicitly states that text based content publication is part of Yle’s remit.

The restriction proposed in the law proposal should not be tightened up from the version in the existing draft. Reducing the list of exceptions on page 16 of the draft, i.e. tightening the text format restriction, would prevent Yle from providing a public service equally to its whole audience and different audience groups, and this would reduce the diversity of communications.

Audience needs for text publication

Text based content will be an important part of Yle’s publishing activities in the future, which is why it is necessary that text based content publishing is explicitly stated to be part of Yle’s remit.

Without text publication, Yle would not be able to fulfil its public service mission to serve the entire Finnish audience. Yle’s nationwide regional news coverage, which produces regional equality, also requires publishing text based content. Excessive restrictions would also impair Yle’s ability to fulfil its security of the supply function.

The text based content published by Yle ensures the fulfilment of freedom of speech and the diversity of media services.

Yle plays a central and important role in the exercise of an individual’s rights related to speech. Stricter restrictions on Yle’s publishing activities would narrow the public’s ability to receive information, opinions and other messages, as required by the Constitution of Finland. Mechanical restriction of Yle’s content on the basis of whether the published content is audio, video or text would prevent, for example, the supply of investigative journalism published in textual form. The contents of investigative journalism with a lot of detailed information can only be adopted in textual form. Limiting such content to commercial media would fundamentally limit the audience’s ability to receive information on fundamental societal issues.

Text based content published by Yle is a necessary requirement in order for Yle’s services to be available and accessible to different audience groups. A text format is necessary, e.g. for the hearing impaired and those with limited language proficiency. There are other special groups that also have difficulty perceiving and receiving information through audio- and video-based communication.

Citizens who are unable to receive information fluently through image and sound would have to make more effort in order to have access to public service media content. The number of optional additional services, such as subtitles and audio description, would increase. Achieving Yle content would become more difficult as the number of choices increases. This would be focused on those individuals who have fewer digital skills and less ability to make these choices compared to the rest of the population.

A stricter restriction of the text based content would make it more difficult to provide a public media service to all citizens on equal terms. It would significantly limit the access of persons belonging to special groups to information on important social issues. The situation would be exorbitant for special groups who would otherwise have a more limited capacity to exercise their freedom of expression compared with other citizens. This would be a significant restriction of freedom of expression.

The role of Yle’s Administrative Council is to oversee that tasks involving public service programme activities are carried out and to supervise the tasks, which is why the supervisory role assigned to the Administrative Council is a self-evident part of its tasks. The Administrative Council has procedures for carrying out its supervisory tasks, e.g. using stakeholder consultations and independent external experts. The Administrative Council will continue to be responsible for overseeing Yle’s overall publishing activities, including the text based format as part of all publishing.