The Office for Students (OfS) has recently issued Freedom of Speech guidance (2025) that takes a “very strong” approach to permitting lawful speech on campus. This guidance, rooted in the new Higher Education (Freedom of Speech) Act, underscores that unlawful speech is not protected and that universities must uphold a “particularly high” bar before restricting lawful speech. In practical terms, this means universities should allow controversial or even uncomfortable viewpoints as long as they remain within the law. Blanket bans – for example, on student protests or on hosting certain speakers – are discouraged. Instead, institutions are expected to take “reasonably practicable steps” to secure free speech, not penalising students or staff for lawful expression of a viewpoint.
The guidance provides examples: universities should support constructive dialogue on contentious subjects and avoid any policy that effectively censors lawful speech or forces ideological conformity. While universities can regulate the time, place and manner of expression to avoid disruption of core activities (no one has to allow shouting in an exam room), they “can’t ban ideas” simply because those ideas are unpopular. The overarching message from OfS Director for Free Speech, Arif Ahmed, is that free speech within the law is fundamental to the mission of education, and only in exceptional cases should it be curtailed.
This robust free speech stance reflects wider concerns that many academics feel unable to discuss controversial topics. One in five academics (across the political spectrum) feel “not at all free” or “not very free” to teach or debate contentious issues. The OfS guidance is a response to such “chilling effects,” aiming to reassure that academic freedom and free expression should be “prized and given the utmost protection” within the law. Universities are instructed that punishing lawful speech – for example, disciplining an academic or student for expressing critical views – would likely breach their duty to secure free speech.
At the same time, the guidance acknowledges complexity: institutions can and should still act against harassment or genuinely harmful speech (for instance, racist harassment is never to be tolerated). But importantly, the default presumption is in favour of allowing speech, with any restrictions needing clear justification under law or necessary institutional function. In essence, the OfS is telling higher education: commit to being a forum for diverse ideas and debate, even those that shock or challenge, so long as they’re lawful. This sets a tone of maximal free expression in academia – a useful point of comparison when we turn to community media and broadcasting.
Community Radio and Ofcom’s Broadcasting Code
By contrast, community radio in the UK operates under a different regulatory framework: it is licensed and regulated by Ofcom, which enforces the Broadcasting Code for all radio content. Unlike a university campus where debate can flourish under broad free-speech principles, a community radio station must adhere to strict content standards that reflect both legal requirements and ethical broadcasting obligations. The Ofcom Broadcasting Code is comprehensive – it spans ten sections covering everything from protecting children to ensuring fairness.
For example, Section Two demands that broadcasters provide the public with “adequate protection” from harmful or offensive content. Section Three outright prohibits any material likely to incite crime, disorder, or hate. In news programming, due accuracy and due impartiality are required, meaning community radio news must be reported truthfully and even-handedly. Other rules ensure the fair treatment and privacy of individuals who feature in broadcasts. These standards go beyond simply outlawing what is illegal; they impose editorial discipline to uphold trust and avoid harm.
What this means in practice is that a community radio producer cannot take an absolutist “anything goes” approach to content – even if certain extreme opinions are lawful to utter in public, broadcasting them without context or caution could violate Ofcom’s Code. Hate speech, for instance, is forbidden on air unless it is editorially justified within context (for example, in a news report where it is necessary to understand a story). Libel laws, contempt of court restrictions, and election impartiality rules also tightly constrain what can be aired. Community radio stations, often run by volunteers with limited resources, must be acutely conscious of these rules; a single on-air misstep – a defamatory comment or a biased election segment – could result in complaints and sanctions that threaten the station’s existence.
It’s a striking contrast: the OfS guidance extols the broad freedom to voice opinions “within the law,” whereas Ofcom’s Broadcasting Code actively delineates boundaries of content even beyond the letter of the law. The Broadcasting Code’s intent is to safeguard the public. It asks community broadcasters to exercise judgment: to consider audience expectations, to provide warnings or scheduling appropriate for sensitive material, and to ensure that a “range of alternative views” are heard, especially on matters of controversy. In other words, community radio must balance freedom of expression with obligations of accuracy, impartiality, and harm prevention at all times. Failure to maintain this balance can lead to reputational damage or even the loss of a broadcast licence.
Yet, it would be wrong to see Ofcom’s regulatory approach as inimical to free expression. On the contrary, Ofcom emphasizes the importance of free speech and pluralism in broadcasting, within an editorial framework. As Ofcom’s Chief Executive Melanie Dawes noted, the code’s requirements (like impartial news) are designed to protect audiences from harm while ensuring they “hear the other side” through a range of views so they can judge for themselves. She stresses that the principle of freedom of expression is highly valued and that the rules still permit “controversial opinions that challenge the mainstream or status quo” to be broadcast. In effect, the Broadcasting Code seeks to manage how free expression is exercised in radio, rather than to muzzle it. Community radio producers operate with this understanding: they are free to amplify diverse community voices and challenge power, but they must do so responsibly, mindful of context, audience, and factual integrity.
Balancing Free Expression with Editorial Responsibility
For community media producers, the juxtaposition of the OfS free speech ethos and Ofcom’s broadcasting rules highlights a fundamental challenge: how to balance the ideal of freedom of speech with the practical responsibilities of editorial integrity, community impact, and regulatory compliance. On one hand, community media thrives on the open exchange of ideas. We want local voices – including those with critical or dissenting viewpoints – to be heard and empowered. In that spirit, the OfS’s call for institutions to “support constructive dialogue on contentious subjects” resonates strongly.
Community radio, much like a university debate, should be a forum where difficult conversations can happen rather than be suppressed. Our stations often give airtime to views and topics that mainstream media overlook, aligning with the OfS guidance’s philosophy that no idea should be banned outright, only handled appropriately.
On the other hand, with great freedom comes great responsibility. Community broadcasters carry a duty to their audience – typically their own neighbours and peers – to be accurate, fair, and culturally sensitive. Unlike a campus discussion that might be attended by a limited group, a radio broadcast can unexpectedly reach a wide cross-section of the public, including children or vulnerable groups. The community impact of what we air is immediate and tangible. A careless remark can offend or misinform hundreds of listeners; a poorly handled debate can inflame tensions in a small town.
Moreover, editorial integrity is the currency of community media – trust, once lost, is difficult to regain. Thus, we find ourselves constantly asking: Is this content editorially justified? Is a given provocative statement serving a genuine public interest or illuminating a community issue – or is it gratuitous provocation? If a caller or guest expresses an extreme view, have we provided proper context or challenge to that view, to keep the discussion fair and rooted in fact?
These are not just abstract ethical questions; they tie directly into compliance with the Broadcasting Code and the station’s own guidelines. Ensuring fairness (as mandated by Section Seven of the Code) means giving individuals and opposing viewpoints a chance to be represented accurately. Ensuring “adequate protection” from offence means thinking about how a reasonable listener would perceive the content, and whether the benefits of broadcasting certain words or ideas outweigh the potential harm.
Crucially, the culture of community media encourages us to weigh freedom and responsibility not as opposites, but as complementary values. We often invoke the mantra: “maximum diversity of voices, minimum harm.” This means we strive to include voices that are marginalised or seldom heard, in line with the OfS’s spirit of protecting lawful speech, but we also moderate discussions to prevent the spread of hate or falsehood.
We foster robust debate on local issues while also being ready to hit the “off” switch if a participant crosses into harassment or incitement. Our producers and presenters are trained to understand that free expression in community broadcasting must be paired with editorial judgment. Indeed, Ofcom expects stations to make such judgments in real time, and the best community journalists do so instinctively, always asking: Does this serve our community’s interests?
Editorial Questions and Prompts for Community Producers
To help community media producers navigate these complex waters, we suggest a set of editorial questions and practical prompts. These can serve as a guiding checklist when planning programs or responding on-the-fly during live broadcasts:
- Accuracy Check: Have we verified the facts and sources in this content? Ensuring due accuracy is both a legal duty and a trust issue – even in a casual community show, double-check names, dates, and claims. If you’re unsure of something, clarify or leave it out.
- Fair Representation: Are we presenting multiple perspectives fairly? If the topic is controversial, consider who might have a differing view. Community radio isn’t bound to strict neutrality in every talk show, but basic fairness (and Section Five impartiality for news) means “hearing the other side” on important issues.
- Editorial Justification: If our content may offend or shock, is it editorially justified and presented with context? It’s fine to tackle contentious subjects – in fact, it’s often our role – but do so with clear purpose. Explain why a disturbing anecdote or strong language is included (for example, to illustrate a real community problem), and give any necessary warnings. Nothing should be on air just for sensation.
- Civic Relevance: How does this content serve our community’s civic needs? Every program segment can be asked: does it inform, educate, or constructively engage our listeners? Content of civic relevance might share local information, encourage dialogue on community issues, or celebrate local culture. If a piece has no clear value for public interest or community development, rethink it.
- Community Impact: What potential impact – positive or negative – could this content have on our community? Try to anticipate listener reactions. Will it bring people together, spark healthy debate, empower someone? Or could it alienate, mislead, or harm? This doesn’t mean avoiding all controversy; it means planning how to handle the fallout. If you discuss a polarising local issue, be ready to facilitate follow-up conversations or provide support resources.
- Inclusion and Voice: Whose voice is being amplified, and have we included those affected? Community media should reflect its community. If you’re covering a story about, say, a local immigrant group or youth issue, have you invited someone from that group to speak? Empowering marginalised voices by giving them a platform is a core principle – it leads to more authentic, relatable content.
- Compliance Scan: Does anything in this content risk breaching regulations or our station’s code of conduct? Do a mental scan for libel (is an allegation backed by evidence?), privacy (are we exposing someone’s personal info without consent?), and Ofcom red lines (no hate speech, no election endorsement during purdah, etc.). When in doubt, consult a senior producer or err on the side of caution – it’s easier to edit or omit now than to face a complaint later.
- Engagement and Dialogue: Are we inviting listeners to engage and respond? Community media is a conversation, not a lecture. Think of prompts to encourage listener input – be it phone-ins, social media comments, or community forums. This ensures we’re not just broadcasting at people, but fostering a two-way dialogue that can enhance understanding and accountability.
By routinely considering these prompts, community producers can create content that is accurate, fair, and civically relevant – content that exercises freedom of expression in a constructive way, true to both the spirit of open debate and the letter of broadcasting standards.
Inclusion, Engagement, and Democratic Dialogue in Community Media
A key part of balancing free speech with responsibility is emphasizing inclusion, social engagement, and democratic dialogue. Community media is at its best when it operates as an open, participatory platform where diverse voices can speak – especially those that mainstream media or academic circles might overlook. This ethos aligns with Decentered Media’s development and training values, such as ABCD (Asset-Based Community Development) and C4D (Communication for Development), which foreground community strengths, participation, and empowerment.
Rather than imposing a top-down agenda, an ABCD approach starts with “what communities have” – their knowledge, skills, and stories – and builds on these assets to encourage local ownership and engagement. In a radio context, that means programming which highlights local talents and solutions, not just problems, and treating listeners as potential contributors, not passive recipients.
Similarly, C4D principles remind us that communication is a tool for social development. The aim is not just to disseminate information, but to enable communities to voice their aspirations and work collectively towards change. Indeed, internationally recognized community media principles (as championed by UNESCO and AMARC) call for media that enables pluralism in public discourse, reflects cultural diversity, ensures editorial independence, and promotes democratic governance.
These values “align naturally with the participatory ethos of ABCD and C4D, which foreground self-determination, local capability, and civic empowerment”. In practice, this could mean a community radio show that not only reports local council decisions but invites residents to discuss what those decisions mean for them, or a podcast series co-created with youth groups to let young people set the agenda. It’s a decentralised practice of media – one where power to create content is shared widely, not concentrated.
As we often say at Decentered Media, innovation in community communications is not something handed down from on high; it’s co-created on the ground. Our approach encourages a “more decentralised and participatory orientation” in media, where community members are agents in shaping content, not just consumers. This decentralisation is itself a guardrail for freedom of speech: it ensures no single gatekeeper can silence a perspective, as multiple grassroots voices are producing media in parallel.
Voice empowerment is another way to describe what happens when inclusion and participation are prioritized. Community media explicitly aims to give a platform to marginalised groups, allowing them to share their own stories and perspectives – an effort that is “essential for promoting social justice, diversity, and equality”. In concrete terms, this might look like a community radio training program for immigrant women to host their own show, or a series of features recorded by people with disabilities about accessibility in the city.
When people hear themselves and their neighbours on air, it not only validates their experiences, but also educates others, fostering empathy. This kind of democratic dialogue – many voices contributing to a shared public conversation – can heal divisions and build community, where one-sided narratives often sow discord. It’s the grassroots parallel to the OfS’s vision of campuses where students hear views unlike their own; in community media, neighbours hear neighbours, across social, ethnic, and political divides.
Alongside voice empowerment, we champion community literacy, by which we mean the media literacy and communication skills of everyday people. Community media is not just about producing content, but also about teaching and learning. Through participatory workshops and on-air experience, residents learn how media works, how to critically assess information, and how to articulate their thoughts effectively.
As one of our alliance documents notes, supporting community media “contributes to developing media literacy skills among community members,” empowering individuals to engage more critically and responsibly with content. In an era of rampant misinformation, this local media literacy mission is incredibly civic-minded: it helps create informed citizens who can exercise their freedom of expression wisely and discern truth from falsehood.
All these values – inclusion, participation, empowerment, localism – shape an editorial stance that complements free speech with social responsibility. A community radio guided by ABCD will ask, “Whose asset or voice can we highlight here?” A C4D perspective will ask, “How does this content drive positive change or development?” The result is content that doesn’t shy away from tough issues or critical voices, but approaches them in a solution-oriented, inclusive manner.
By embedding such values, community producers find it more natural to uphold editorial integrity: you are less likely to produce harmful or unfair content when your mindset is about uplifting community voices and bridging understanding. In effect, these values act as an internal compass aligning freedom of expression with the public interest – very much in line with Ofcom’s emphasis that broadcast freedom must work in service of democratic participation and audience trust.
Planning and Evaluating Content Impact: The Role of Communications Impact Assessment
Maintaining the balance of free expression and responsibility is not a one-off task – it requires ongoing reflection and adjustment. This is where using a Communications Impact Assessment (CIA) approach becomes valuable. A Communications Impact Assessment is essentially a planning and evaluation tool that asks: What are the intended outcomes of our communication, and are we achieving them in a way that aligns with our values and duties? Rather than just measuring success in terms of audience size or number of programs, CIA looks at how our content resonates with specific groups, how it aligns with social values, and what broader civic goals it supports. It is a structured method to assess “not just delivery but consequence” of media interventions.
In practice, applying a Communications Impact Assessment mindset might involve setting objectives for a program (e.g. increase local awareness of council services among elderly listeners, or spark a public discussion about youth unemployment) and then later gathering feedback to see if those objectives were met. It encourages community producers to think in advance about impact: Who do we hope to empower or inform with this piece? What change might it inspire? and also to think in review: Did the way we handled that controversial on-air debate help people understand the issue better, or just create confusion?
This kind of evaluation goes hand-in-hand with editorial responsibility. It can catch instances where, for example, a show intended to give voice to minorities inadvertently left some feeling misrepresented. By evaluating impact, we learn and iterate – maybe adjusting formats to be more inclusive or providing additional context in future episodes.
At Decentered Media, we advocate for making evaluation “inclusive, accessible, and representative of real-world community experiences”. This means involving community members in assessing our media efforts – through surveys, forums, or participatory feedback sessions. It also means valuing qualitative outcomes (stories of personal empowerment, instances of constructive dialogue) alongside quantitative metrics.
A Communications Impact Assessment approach formalises this by building reflection into the editorial cycle. Just as one would not build a public infrastructure project without an impact assessment, we argue that communication projects deserve similar rigour – to ensure they truly serve the community and uphold the values of free expression and fairness we cherish.
In the current climate, with regulators like the OfS pushing strongly for freedom of speech “within the law” and Ofcom guarding the air waves for fairness and accuracy, community media producers stand at the intersection of these principles. We are, in a sense, free-speech activists with broadcasting licences – uniquely positioned to amplify voices and foster debate, yet duty-bound to do so conscientiously.
The task is not always easy: we operate in real time, with limited resources, often covering emotionally charged local issues. But by grounding our work in editorial integrity, community values, and reflective practice, we can turn this challenge into an opportunity. We demonstrate that freedom of speech and editorial responsibility are not mutually exclusive, but mutually reinforcing. When a community radio station upholds high standards of accuracy and inclusion, its platform becomes more credible – which in turn attracts a wider range of voices who trust they will get a fair hearing. When we balance robust debate with compassion and context, we create safer spaces for dissent – listeners know we will handle sensitive topics with care, not censorship, encouraging more engagement rather than self-silencing.
In community media, our ultimate accountability is to the people we serve. By asking the right questions before the microphone goes live, by embedding development models like ABCD and C4D that elevate local strengths and needs, and by evaluating the impact of our words, we ensure that free expression in our stations is a tool for empowerment rather than division.
We prize inclusion and democratic dialogue not just as lofty ideals but as daily practices – seen in the neighbourly tone of our broadcasts, the diversity of our volunteer teams, and the open-door policies at our studios. This culture, combined with a clear understanding of Ofcom’s rules and the ethical implications of our content, is what sustains community media’s public value.
The new OfS guidance challenges all of us in education and media to reaffirm our commitment to free speech. In community media, we answer that challenge with a resounding yes – we will champion free expression – and we will do it the way we always have: by coupling it with responsibility to our community, respect for human dignity, and a relentless focus on truth and inclusion. In doing so, we keep the air waves not only free, but also worth listening to.
Sources:
- Office for Students – Freedom of Speech Guidance Press Release (19 Jun 2025)
- The Guardian – “English universities barred from enforcing blanket bans on student protests”
- House of Lords Library – Overview of Ofcom Broadcasting Code
- House of Lords Library – Melanie Dawes on Broadcasting Code and Free Expression
- Decentered Media – “Valuing Volunteers in Community Media With ABCD” (Rob Watson, 2024)
- Decentered Media – “Reframing Innovation – A Community Media Development Model” (Rob Watson, 2025)
- Decentered Media – “Wanted – A Civic and Community Media Alliance” (Rob Watson, 2023)
- Decentered Media – “Wanted – A Civic and Community Media Alliance” (Media Literacy & Engagement)
- Decentered Media – “Reframing Innovation – A Community Media Development Model” (Communications Impact Assessment)