Submission to the Communications Authority in Response to the Public Consultation on Renewal of Domestic Free Television Programme Service Licences 2025

1. The Consumer Council (the Council) is pleased to submit its views to the Communications Authority (CA) on the renewal of domestic free television programme service (free TV) licences.

The Council’s overall views

2. Without doubt, domestic free TV programmes are a valuable source of information and entertainment for the public.  Given their reach to a wide range of audiences, the Council deems it essential for free TV licensees to ensure the quality of their programmes as well as the appropriateness of their advertisements.  While the Council has received a limited number of complaints related to free TV licensees in the past, as noted in Section 1.5 of the Information Document, the CA has received over 80,000 complaints in the past decade, indicating a certain level of public dissatisfaction.  In light of the complaints as well as current social trends, such as the increasing adoption of artificial intelligence (AI) and the growing advocacy for inclusion, the Council is of the view that measures might be considered to enhance the service quality of licensees in response to these developments when reviewing their renewal applications. 

3. In the following parts, the Council puts forward its views and suggestions on various aspects that concern consumer interests for the CA to take into consideration when making recommendations regarding the renewal applications.  

Safeguards on the use of artificial intelligence

Setting guidelines on the use of AI

4. The Council notices that at least two licensees have revealed in their six-year investment plans that they would deploy or use AI solutions (Section 1.8 of the Information Document).  As a matter of fact, a licensee has recently already been broadcasting a programme where an AI-generated reporter delivers health-related news.  To mitigate potential issues associated with AI hallucination and the dissemination of inaccurate messages in TV programmes, the Council opines that robust guidelines on the use of AI specific for the TV broadcasting sector are vital.  As it seems such guidelines in the local TV broadcasting sector are yet to be in place according to the Council’s observation, the Council suggests that the CA may establish such guidelines by making reference to both local and global standards.

5. Locally, the Council notes that the Government or statutory bodies have issued guidelines on general AI adoption.  For instance, the Digital Policy Office released the “Generative Artificial Intelligence Technical and Application Guideline” in April 2025 which offers practical guidance on effectively addressing the security issues and social risks in connection to generative AI technology_[1]; and the Office of the Privacy Commissioner for Personal Data also published the “Artificial Intelligence: Model Personal Data Protection Framework” in June 2024 to help organisations using AI technology to comply with data protection principles_[2].

6. Globally, some broadcasters have published guidelines on the use of AI in their content.  For instance, the British Broadcasting Corporation (BBC) in the United Kingdom (UK) has introduced comprehensive guidance on its use of AI_[3], stipulating high-level principles that the usage must (i) never undermine audiences’ trust, (ii) be transparent and accountable with effective and informed human oversight, and (iii) be used in a manner consistent with the editorial values of BBC, particularly accuracy, impartiality, fairness, and privacy.  The guidance also covers practical matters such as stipulating the staff responsible for overseeing the use of AI for editorial purposes, and instances where use of generative AI or synthesised audio is prohibited or allowed.  The Council believes the above guidelines are worth referencing.  

Providing notifications for AI-generated content

7. Particularly, clearly identifying AI-generated content is essential to uphold the audience’s right to be informed, for example, when AI avatars are used.  Globally, the AI Act in the European Union requires content that is generated or modified with the assistance of AI needs to be clearly labelled as such to alert users coming across such content_[4].  Meanwhile, the Hong Kong “Generative Artificial Intelligence Technical and Application Guideline” also mentions that service users of generative AI should explicitly indicate whether such AI technology has been involved in content generation.  The Council thus suggests the CA might consider incorporating such information disclosure obligations into the renewal requirements.

Safeguards for Quick Response code-linked content

8. The Council notices that some licensees have broadcast programmes where the audience is invited to scan Quick Response (QR) codes on the screen to access additional content, interact with others, or enjoy discounts on products shown in the programmes.  While the Council notes that the CA has already regulated the use of QR codes in TV advertising, for example regulating how QR codes should direct audience to information that backs up factual claims in advertisements, how long they should be displayed, etc._[5], the Council suggests the CA may consider expanding supervision of the use of QR codes to programme content (such as ”infotainment” programmes) where appropriate_[6], for better alignment.  This would ensure audiences’ right to access correct information all round and that they are not exposed to inappropriate, shocking, or offensive content.

Further diversifying programme content to raise awareness of matters of public interest

9. One key function that TV programmes serve is to inform and educate audience on matters of public interest.  While current free TV programmes already cover a variety of genres, the Council further suggests the CA may consider encouraging licensees to embrace greater social responsibility.  For instance, licensees may produce more dedicated programmes that address public-interest topics, such as anti-deception, sustainable consumption, and elderly rights, or to incorporate more such elements in existing programmes.  Through a diverse range of TV programmes, licensees can play a more proactive role in empowering viewers to make informed choices, safeguard their interests, and strengthen engagement with pressing social concerns.

Facilitating access to TV programmes for marginalised groups

10. The Council considers that free TV programmes should be accessible for people from all walks of life, including marginalised groups who face barriers in enjoying such content.  With technological advancements, the Council anticipates that licensees might find it increasingly feasible and cost-effective to enhance the accessibility of their programmes for marginalised groups.  The CA may consider requiring licensees to:
    1. Increase the percentage of subtitled programmes to cover programmes other than those between 7 p.m. and 11 p.m. (paragraph 2.1.3), and examine the feasibility of widening the subtitle languages to include ethnic minority languages, in addition to Chinese and English;
    2. Expand the provision of sign language interpretation to more types of programmes (apart from Cantonese news programmes), and more than 25 minutes each day (paragraph 2.1.4); and
    3. Provide audio description for certain TV programmes.  For instance, Radio Television Hong Kong has already been providing audio description services on RTHK TV 31 for selected programmes, demonstrating that such services are feasible and practicable in the context of Hong Kong.      

Conclusion

11. The Council is of the view that the free TV licensing framework should evolve to meet emerging challenges and public expectations by promoting service quality, responsible use of AI, transparency in content creation, awareness of public matters, and inclusive access for all viewers.  Thus, the Council calls upon the CA to take into consideration the above comments in making recommendations on the renewal of free TV licences so as to ensure free TV content is of high quality, safe, civic interest and as accessible as possible for the Hong Kong public.