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Tackling the prominence challenge: measurement solutions for media regulators

Connected TV has transformed the broadcasting industry. LUCAS BERTRAND plots the changes and explains why it’s important for regulators to understand prominence

In January 2007, Netflix transformed the entertainment industry by launching its first streaming service. Fast forward to today, and there are over 200 streaming services worldwide1 with the video streaming market projected to generate $108.5 billion in 2024.2 This rapid expansion has made the task of regulating media, particularly concerning content prominence on digital platforms, increasingly complex.

Changing consumer habits

Consumers are currently consuming content in a variety of ways, driven by advancements in technology and the rise of digital platforms. The traditional model of linear TV viewing has been significantly disrupted by on-demand streaming services, where viewers have the flexibility to watch content whenever they choose. This shift is largely influenced by the convenience and accessibility offered by devices such as smartphones, tablets and smart TVs, which allow for content consumption on-the-go.

For broadcasters, this shift poses significant challenges. Traditional broadcasters, who rely on scheduled programming and fixed channel placements, find it increasingly difficult to compete with the vast libraries and flexible viewing options offered by streamers. They must now navigate a landscape where their content needs to be as discoverable as that of the global streaming giants.

Industry trends impacting the TV industry

Over the past five years, several key trends have significantly influenced the global and UK television industry.

The popularity of streaming services surged, particularly during the Covid-19 pandemic, accelerating the transition from traditional television to digital formats. Major studios launched their own streaming platforms such as Disney+, Paramount+, and Discovery+, unbundling paid TV channels into individual apps. Subscription video on demand (VOD) services, such as Netflix and Prime Video, solidified their positions as major content providers, regularly offering original content.

Pay TV providers aim to integrate content from major streaming services alongside traditional broadcast channels and VOD within a unified user interface (UI).

Broadcaster VOD services have evolved from primarily offering catch-up TV to becoming digital destinations with expanding catalogues of boxsets and exclusive content.

The availability of more channels and larger curations on connected TV programme guides have been notable with the expansion of free ad-supported television (FAST) channels. Established global production companies are also entering this space, distributing show formats directly to consumers via FAST channels.

Sports leagues and federations have increasingly launched direct-to-consumer streaming services, offering live coverage and additional content that was previously unavailable. This trend includes providing coverage in regions without existing licensing deals, contributing to the fragmentation of sports rights.

The evolving content discovery landscape

The growth in streaming and consumer choice has generally been seen as beneficial, improving the television ‘product.’ However, the proliferation of content sources has also made it harder for consumers to decide what to watch or to find the content they seek. Furthermore, the use of personalised recommendations and algorithms by streaming platforms has changed viewing habits, with users often discovering new content based on their viewing history and preferences. This personalised approach means that streaming services can better cater to individual tastes, potentially drawing viewers away from traditional broadcasters which may not have the same level of technological sophistication or data analytics capabilities.

Social media platforms also play a crucial role in content discovery and promotion. Viral trends and shared content on platforms, such as Twitter, Facebook and TikTok, can significantly influence what people watch. Streamers often capitalise on these platforms to market their content more effectively, further enhancing their reach and visibility compared to traditional broadcasters which may not have the same digital marketing resources.

Streaming services can better cater to individual tastes, potentially drawing viewers away from traditional broadcasters which may not have the same level of technological sophistication or data analytics capabilities

The discovery landscape has evolved dramatically, with content titles and apps now taking precedence over traditional channel listings. This, combined with the proliferation of storefronts on connected TV devices, has made determining visibility more challenging for regulators. Content discovery has become a central concern for the television industry. Platform providers focus on making a wide range of content easily accessible, while content providers strive to ensure their offerings are visible and engaging.

On-platform content discovery has driven significant UI innovation. Notable trends over the past five years include a shift from electronic programme guide-led discovery to content-first discovery, with show titles prominently displayed on home pages. UIs have become more visual, featuring compelling artwork and auto-play trailers that provide cinematic previews of shows. There has been tighter integration of streaming content into pay TV platform UIs, including deep linking from home pages. Streaming-only linear channel listings have also grown on smart TVs, in the form of FAST channels. At an app level, personalisation of the UI has become standard, with individual profiles for household members and recommendations tailored to their viewing habits. Platforms have also implemented more sophisticated search functions, including voice-based search with natural language processing. UI innovation has been underpinned by improvements in processing program-related metadata and consumer usage data, enabling a better understanding of content and audience preferences in a privacy-compliant manner.

The importance of measuring prominence

Prominence on digital platforms is crucial for the success of content providers. When content is easily discoverable and accessible, it attracts more viewers, which translates to higher engagement and revenue. For local and culturally significant content, prominence ensures it reaches its intended audience, preserving cultural heritage and diversity in media consumption. Prominence is particularly important in the digital age, where viewers are bombarded with an overwhelming array of choices. Content that is prominently displayed has a better chance of being noticed and consumed. This is why broadcasters argue for advantageous positioning on digital platforms—to maintain visibility and compete with the vast amount of global content available.

Measuring prominence helps content providers and regulators understand how visible a piece of content is on digital platforms. It allows them to assess whether the content is reaching its target audience and to what extent it is being engaged with. This measurement is critical for developing strategies to improve content visibility and ensuring that local and culturally significant content is not overshadowed by that of the global giants. By measuring prominence, regulators can ensure that digital platforms comply with policies designed to promote diversity and fair representation. It also helps identify any biases or discrepancies in how content is displayed, enabling corrective actions to be taken.

Australia’s legislative efforts for prominence

Regulators in Australia are grappling with ensuring fair representation and marketing prominence on digital platforms. Towards the end of 2023, Australian media was rife with headlines such as ‘Now the government wants to control your TV’ and ‘The streaming players are hiding local television services’.3 This debate was ignited by the Australian government’s plans to introduce legislation on how content is displayed on smart TVs and apps. Free-to-air networks, including Nine, Seven and Ten, argued that local and culturally significant content such as news, sport and entertainment should be given preferential positioning on new TV sets to enhance visibility. Australian Prime Minister Anthony Albanese emphasised that ‘this isn’t about controlling what people can watch, it’s about ensuring access’.4 Local broadcasters have recognised that the linear model of guaranteed placement is being replaced by new gatekeepers in the connected TV world, comprising smart TVs, streaming devices and gaming consoles, as against the old world of TV guides for FTA, cable and satellite operators.

Free TV Australia, representing these networks, countered claims of governmental overreach by stating, ‘Don’t let big tech take your freedom away. When big tech controls your TV, you’re the one who pays.’5 This was supported by research indicating that 84 per cent of Australians opposed apps and content being prioritised over free or editorially placed content. Meanwhile, ASTRA, the lobbying body for subscription media providers, found that 94 per cent of Australians did not want the government to decide which content and apps are prioritised on their TVs. While both sides present valid arguments, the power struggle between new gatekeepers and traditional media continues. Prominence legislation in Australia will require manufacturers of newer smart TV models to ensure that Australian TV channels are prominently displayed.6 The legislation, passed in July 2024, will mandate that manufacturers introduce features like pre-installed apps and separate tiles, tabs or links to enhance accessibility. Australian TV channels may also take additional measures outside this legislation, such as implementing search functions that prioritise their services on devices. This initiative aims to give local networks a fighting chance against global streamers.

This legislation is designed to support local free-to-air TV services, such as Seven, Nine, Ten, SBS and ABC, ensuring that local news, emergency information and creative industries are easily accessible to Australian audiences. The Minister for Communications, the Hon Michelle Rowland MP, stated, ‘The Albanese government’s new prominence framework delivers on our election commitment to modernise media laws and level the playing field, recognising the important role that free-to-air broadcasters continue to play for Australians – no matter where they live or what they earn.’7 Prominence is described by RMIT’s8 associate professor Ramon Lobato as an existential challenge for Australian public service broadcasters, who cannot afford market rates for visibility on smart TVs. Lobato noted, ‘The smart TV testing we’ve done at RMIT suggests that local broadcaster apps are substantially less visible, less frequently preinstalled, and less discoverable through search and recommendations than major US services like Netflix, YouTube, Prime Video, and Disney+.’

Prominence in the United States

In the United States, the challenge of representing local broadcasters varies by market, with different priorities ranging from balancing commercial and public service interests to navigating the global versus local streamer dynamics and personalising versus surfacing new and unknown titles. Concerns were raised by the Writers Guild of America in an August 2023 report titled ‘The New Gatekeepers – How Disney, Amazon, and Netflix Will Take Over Media’.9 The report highlighted how streaming services transitioned from increasing competition to becoming dominant forces in the entertainment space, dictating what content is created, who gets to see it and how it’s distributed. The main concerns include reduced creativity, content innovation and choice, along with declining writers’ pay and higher consumer prices.

The prominence and prioritisation of apps and content on connected TV devices initially favoured early innovators, such as YouTube, Netflix and the iPlayer, which received priority placements across device UIs and custom remote control buttons and were even embedding on TV chipsets for higher performance (with only five spots available on most). This left later entrants competing by leveraging their marketing power and budgets to secure more and better shelf space to attract new customers, increase engagement and reduce churn. Prominence is an ongoing issue that requires constant attention from regulators to ensure fair representation and visibility for all content providers. The challenge is compounded by the lack of unity among regulators on how to measure and address prominence issues effectively. This inconsistency makes it difficult to implement standardised solutions across different regions.

The approach to prominence in the UK and Europe

The prominence issue in the UK dates back to 2019 when Sir David Clementi, then chairman of the BBC, called for regulatory changes to allow the BBC, ITV, and Channel 4 to ‘adapt and innovate in the digital world’.10 At around the same time, Channel 4’s chief executive Alex Mahon urged for public service broadcasters to be easily found by viewers.11 Following Australia’s example, the UK Department for Culture, Media and Sport introduced a media bill in November 2023.12 It aims to update old legislation to empower British broadcasters and boost the creative industries by £50 billion, adding one million jobs by 2030. It was passed in May 2024.13

The legislation focuses on improving prominence for broadcasters, supporting the BBC, ITV, and Channel 4 with new requirements to ensure their apps are prominently displayed on major smart TVs and streaming devices. The ‘Prominence on television selection services’ section of the bill specifies that public service broadcaster apps and programmes will be easily accessible on smart TVs and similar devices, and highlighted on homepages and within recommendation sections. Global streaming services are also responding. In 2023, major streamers, such as Netflix, Warner Bros, Discovery and Disney, formed the Streaming Innovation Alliance. This powerful group aims to handle any current and future streaming regulations imposed by federal governments.

One approach for regulators is to collaborate with streaming services, broadcasters and platforms to understand content release and promotion strategies. However, this method faces challenges due to the diverse streams of information from each party, each with its own agenda

This challenge extends to the European context, where prominence for specific content or services is also being debated. The Audiovisual Media Services Directive (AVMSD) regulates audiovisual media services within the EU, covering traditional TV broadcasters and on-demand services.14 The AVMSD aims to level the playing field and promote European works by requiring certain types of content, such as European works, to receive appropriate visibility and accessibility on platforms. These requirements support cultural diversity, promote European content and ensure a diverse audiovisual media landscape. Regulators complain that they don’t have the same tools as the platforms and are after the data that they can provide. Creative solutions are essential to address the prominence challenge, as progress has been slow and the pressure is mounting.

Regulatory intervention

To tackle this issue effectively, regulators must be able to monitor the vast amounts of content available globally across all digital platforms. This requires understanding which entities deserve shelf space and for how long. Monitoring and comprehending the positioning of services on major connected TV devices worldwide is crucial. Without this visibility and detailed data, creating effective action plans and making informed decisions that impact millions of users is nearly impossible.

One approach for regulators is to collaborate with streaming services, broadcasters and platforms to understand content release and promotion strategies. However, this method faces challenges due to the diverse streams of information from each party, each with its own agenda. Additionally, managing large, complex datasets makes it difficult to combine, compare and fully understand the data, requiring significant time and resources. This information is often not real-time, consistent or accurate due to last-minute changes in schedules and marketing strategies.

Previously, regulators faced challenges in fully understanding and tracking merchandising efforts across digital storefronts, leading to limited visibility into the prominence of apps or content. Share of voice on connected TV platforms has its limitations, mainly because it focuses only on how often content appears, ignoring the effectiveness of the placements or their quality, such as their position on the screen or how much users engage with them.

A measurement, such as media placement value (MPV), provides a more comprehensive way to measure digital merchandising performance. MPV evaluates placements by considering their strategic importance within the user interface and their prominence, offering a weighted share of voice that reflects how close content or apps are to the user and indicating the potential for engagement. Two other metrics can be useful. $MPV quantifies the financial value of the connected TV media space, translating it into clear financial value.  pMPV estimates impressions or views based on cost-per-thousand values, providing predictive insights into performance.

Looking to the future, the regulatory landscape for media can be expected to evolve alongside these technological and market trends. Regulators will need to address the implications for public service and local broadcasters, ensuring that they can maintain visibility and accessibility in a highly competitive environment. This will in all likelihood involve continued innovation in content discovery and prominence measurement, as well as ongoing collaboration between regulators, content providers and platform operators, to create a balanced and fair digital ecosystem.

Looper Insights are specialists in tracking analytics on internet-connected TV devices. MPV is a proprietary tool of Looper Insights.


Lucas Bertrand

Lucas Bertrand is the co-founder and chief executive officer of Looper Insights. [email protected]

1 Fitzgerald T (2024). The Best Streaming Services for 2024. Forbes, 10 January. bit.ly/4dEl7RN

2 Statista (2024). bit.ly/3M8E0Ak

3 Jaspan C (2023). Brawl erupts over which apps get shown first on your smart TV. The Sydney Morning Herald, 6 November. bit.ly/3YJP52C

4 Free TV Australia. LinkedIn, 2024. bit.ly/4fW9QhH

5 Dumas D (2023). Free-to-air group rubbishes claims Australian government wants to ‘control your TV’. The Guardian, 20 November. bit.ly/3Ag5ph9

6 Meade A (2024). Smart TVs must showcase Australian free-to-air channels alongside streaming services under proposed legislation. The Guardian, 6 February. bit.ly/46NnWOk

7 See note 6.

8 The Royal Melbourne Institute of Technology.

9 Lee W (2023). WGA slams Netflix, Amazon and Disney as ‘new gatekeepers’ in antitrust report. Los Angeles Times, 17 August. lat.ms/3X0HsmV

10 Green A (2019). Change regulations to allow TV broadcasters to take on Netflix, BBC chairman urges. The Independent, 18 March. bit.ly/4fLYrAL

11 Davie T, McCall C, Mahon A and Kyriacou M (2020). Public service channels must remain easy to find on new viewing platforms. BBC, 19 November. bbc.in/3WGLDmF

12 Woodhouse J (2023). Media Bill Research Briefing. House of Commons Library, 17 November. bit.ly/3yGzSEL

13 Media Act 2024. bit.ly/4dmDlr1

14 See digital-strategy.ec.europa.eu/en/policies/audiovisual-and-media-services