Fragmentation: Fourteen separate codes of practice Australias system of media standards is fragmented. The principal division is between broadcast media and print/online, but there are separate schemes even within those sectors. 87 In the broadcast environment, there are eight separate sets of rules as each type of broadcasting service (e.g., commercial television, commercial radio) has its own code of practice, as does each of the national broadcasters. For print and online news and comment, most large publishers and some smaller publishers are members of the Australian Press Council (APC) and therefore subject to its two statements of principles (together the equivalent of a broadcast code of practice). The exception is Seven West Media, which established the Independent Media Council (IMC) with its own standards and complaints scheme. Overlaying all of this is the code of ethics operated by the journalists union, the Media, Entertainment and Arts Alliance.

The current list of codes is as follows: 1. Commercial Television Industry Codes of Practice 2015 (March 2018) 2. Commercial Radio Codes of Practice March 2017 (March 2018) 3. ABC Code of Practice 2011 (March 2016) 4. SBS Codes of Practice 2014 (October 2018) 5. Community Radio Broadcasting Codes of Practice 2008 6. Community Television Codes of Practice 2011 7. Subscription Broadcast Television Codes of Practice 2013 (March 2018) 8. Subscription Narrowcast Television Code of Practice 2013 (March 2018) 9. Open Narrowcast Television Codes of Practice 2009 10. Subscription Narrowcast Radio Codes of Practice 2013 11. Open Narrowcasting [Radio] Codes of Practice 12. Australian Press Council Statement of General Principles/Statement of Privacy Principles (2014) 13. Independent Media Council Code of Conduct (2012) 14. MEAA Journalist Code of Ethics (1999). Rulemaking, complaints and enforcement Regulatory framework

Broadcasting The media standards schemes for broadcasting can be said to be co-regulatory because the rules are developed by industry (via the respective industry bodies) then registered with and enforced by the statutory regulator (the ACMA) under the Broadcasting Services Act 1992 (BSA). Complaints go to the broadcaster (not the industry body) in the first instance but the complainant may take their complaint to the 88 ACMA if they do not receive a response within 60 days or if they consider the response inadequate.17 The key legislative provision is section 123 which explains that it is Parliaments intention that representative industry groups, in consultation with the ACMA, develop codes of practice.18 The section specifies the following as one of the matters to which the codes may relate: promoting accuracy and fairness in news and current affairs programs. This is against the backdrop of Object 3(1)(g) of the Act:

(g) to encourage providers of commercial and community broadcasting services to be responsive to the need for a fair and accurate coverage of matters of public interest and for an appropriate coverage of matters of local significance Under s 123 the representative industry groups develop the codes and ACMA is then given the decision to approve and register them (which in turn gives it an enforcement role). In fact, under this section the ACMA has no choice to approve a code provided a group representing that section of the industry develops it and that the ACMA is satisfied that i. the code of practice provides appropriate community safeguards for the matters covered by the code; and ii. the code is endorsed by a majority of the providers of broadcasting services in that section of the industry; and iii. members of the public have been given an adequate opportunity to comment