The UK Government has now published a draft of the regulations required to bring the most popular video-on-demand (VOD) services under stricter Ofcom regulation.

Until the implementation of the Media Act 2024, many popular VOD services were outside of the remit of the UK’s broadcasting regulator.

The proposed On-demand Programme Services (Tier 1 Services) Regulations 2026 (the Regulations), which are intended to come into force on 1 April 2026, mark a significant shift in how streaming platforms will be regulated in the UK.

The Media Act 2024 introduced significant updates to the UK’s broadcasting regulatory framework, recognising the fundamental shift in how audiences now consume television content. According to Ofcom’s Media Nations 2025 Report, 85% of adults now use a VOD service every month, compared to 67% who watch live television. The majority of viewers now bypass traditional television channels entirely in favour of streaming services.

Historically, mainstream streaming services have not been regulated to the same extent as traditional broadcast television. Although UK-based VOD services have been required to comply with Ofcom’s On-Demand Programme Service Rules and Guidance, these are not as extensive as the Ofcom Broadcasting Code. VOD services based outside the UK, typically avoided UK regulation altogether.

The Government identified the disparity in recourse for audiences encountering harmful or concerning content as posing a risk to viewers and creating a lack of consistency across media regulation. In response, the Media Act 2024 gave the Secretary of State for Culture, Media and Sport the power to designate certain VOD services as “Tier 1” services, bringing them under enhanced regulation by Ofcom.

The draft On-demand Programme Services (Tier 1 Services) Regulations 2026 were published on 24 February 2026 and, once laid before Parliament, are intended to come into force on 1 April 2026. The Regulations extend to England and Wales, Scotland, and Northern Ireland.

Under the Regulations, a VOD service will qualify as a Tier 1 service if it has more than 500,000 average monthly UK users. This threshold is calculated by taking the mean number of UK users per month over the preceding 12‑month period, or (where a service has been operating for less than 12 months) over the period for which the service has been in operation.

The Regulations include two notable exemptions. Firstly, users who access a VOD service via a “user-to-user service” (such as a video-sharing platform) are not counted as UK users for the purpose of calculating the 500,000 threshold. Secondly, VOD services provided by the BBC, such as BBC iPlayer, are exempt from designation as Tier 1 services (because BBC services will, for the time being, continue to be regulated under the Broadcasting Code via the BBC Framework Agreement). The Government estimates that this threshold will capture more than 20 of the most popular services used by UK audiences and has indicated that it will keep this threshold under review.

Tier 1 services will be required to comply with a new VOD standards code, which will be similar to the Broadcasting Code and will set appropriate standards for services and protections against harmful and offensive material.

Audiences will be able to complain to Ofcom if they encounter concerning content, and Ofcom will have powers to investigate and take action where it determines that there has been a breach of the new code. Tier 1 services will also need to comply with a new VOD accessibility code, which will set minimum requirements for content accessibility features.

Statutory sanctions that Ofcom can apply to linear broadcasters by will be available for on-demand services. For VOD services, the maximum fine per breach will be £250,000 or 5% of qualifying revenue.

Following entry into force of the Regulations on 1 April 2026, Ofcom will engage with VOD services to determine which services qualify as Tier 1. The Government estimates the regulations will capture more than 20 of the most popular services used by UK audiences, including Netflix, Amazon Prime Video, Disney+, ITVX, and Channel 4.

Ofcom will then publicly consult on and draft the VOD standards and accessibility codes. The standards code will come into force one year after it is published by Ofcom. For the accessibility code, Tier 1 services will have four years to meet the full requirements, with interim two-year targets designed to encourage progressive provision over the total period. The Department for Culture, Media and Sport will continue to monitor the implementation and impact of these measures on an ongoing basis.

VOD services that expect to meet the 500,000 UK user threshold should begin preparing for compliance with the forthcoming standards and accessibility codes.

The VOD standards code is expected to be similar to the existing Broadcasting Code, applicable to licensed television and radio services. Prospective Tier 1 services should therefore familiarise themselves with the structure and requirements of the Broadcasting Code as a guide to the likely compliance areas that they will need to address. The Broadcasting Code covers several distinct sections, and streaming providers should anticipate potential obligations in comparable areas, including:

Whilst not all VOD services carry commercial advertising, there may also be rules that ad-funded models may need to take note of.

Streaming providers should also begin assessing their catalogues against the forthcoming content accessibility requirements (80% subtitled, 10% audio-described, and 5% signed) to understand the potential scale of work required and to develop implementation plans that will enable them to meet the interim two-year targets and full four-year compliance deadline.

Services should also monitor Ofcom’s forthcoming public consultation on the standards and accessibility codes, which will provide an opportunity for providers to set out their views on the rules that will be within the codes. Engaging with this consultation process will provide an opportunity to help shape rules that are workable and proportionate for the industry.