Dr. T.J. McIntyre:

I do not think I would attempt to change those definitions in this context. The problem is we are trying to take a model which tries to do a few different things. We are trying to regulate these services and the content produced by individuals on the services as though they were produced by professional organisations in traditional broadcast media. The audiovisual media services directive is an outgrowth of traditional media regulation. It takes a regulatory scheme that was designed with traditional media in mind and transposes that to a class of bodies such as video on demand, YouTube etc., and adopts a much narrower set of obligations on the narrower entities that fall within these definitions. It is not intended to apply across the board to regulation of individual speech. The problem is that, by bringing in online safety issues more generally, we are taking that narrow, rather intrusive model and expanding it unnecessarily.

I will give a concrete example. The AVMSD is primarily aimed at illegal content. It deals with harmful content which is accessible by children. What is proposed is an expansion of this kind of scheme to deal with content which is harmful generally. We would be moving from regulating what children see to regulating what adults see. That is a significant step.