Annual reports

It is considered that the most effective starting point for compliance monitoring and enforcement is an annual report from the broadcaster that provides verifiable evidence of compliance with the terms and conditions of the licence agreement.

However, broadcasters should be not be required to provide multiple reports about licence issues to multiple agencies. Reports therefore need to be sufficiently comprehensive to meet the information needs of all relevant agencies.

There appears to be scope for a common high-level template for such reports. Commonality at the detail level is less easy to establish, as terms and conditions, even at the most general level, necessarily vary from one type of licence to another (‘local’, ‘Māori’, Access, etc). A structure based on topical headings with guidelines on the presentation of evidence within each would, however, simplify the task of the evaluator.

Ideally, an annual report would present the managing agency with sufficient verifiable evidence to establish compliance with the licence agreement. In practice, the evidence may indicate, through insufficiency or suspected lack of veracity, that there is a compliance issue to address.

It is noted that such reports may inform the content of reports required for other purposes ― for example, for funding agencies and the provisions of the Companies Act 1993.

A draft reporting template based on these principles is attached (Appendix 3).

Issue 3a

Do you agree that annual reports, as defined above, are the most cost-effective means of establishing compliance? Why or why not? If not, what alternative would you suggest?

Issue 3b

Do you agree with the format for annual reports suggested in Appendix 3? Why or why not? If not, what alternative would you suggest?