Skip to main content
SearchLoginLogin or Signup

The Independent Press Standards Organisation: Standard setter or complaints pacifier?


Published onApr 06, 2024
The Independent Press Standards Organisation: Standard setter or complaints pacifier?

The Independent Press Standards Organisation is the largest press regulator in the UK chosen by the majority of national and regional publishers to protect standards. Ipso was established in controversial circumstances following the 2011 Leveson Inquiry into press practices and ethics after the tabloid phone hacking scandal. The Press Complaints Commission, which preceded Ipso, was disbanded having received considerable criticism at the inquiry for its limited regulation of the press. The Leveson report recommended a new system that included legislative backing through a Press Recognition Panel to guarantee independent press regulation, a proposal accepted by parliament. Ipso was set up by publishers without this recognition and to a background of publisher hostility to the Leveson report. Ipso, in its corporate strategy, says it does protect the public and freedom of expression. This paper attempts to examine that claim by looking in detail at the complaints made to Ipso and the resulting action to see if it really does protect the public in the way Leveson called for and parliament supported.

Key words: Ipso standards, discrimination, children, privacy, accuracy, regulation, press, complaints


Regulation of the press is a complex issue globally with modern democracies seeking to allow the press as much freedom as possible to inform the public and criticise government and public institutions whilst upholding the rights of private citizens to protect their privacy and their reputation.

More oppressive regimes limit the press in terms of what they can say, usually by legislation or by licensing the right to publish or broadcast and thereby allowing the prevention of publication of hostile broadcasters, newspapers or websites.

Press regulation started in Sweden with the Publicists Club in 1874 (Nordlund 1991: 2). This mixture of journalists, publishers and editors became a self-appointed tribunal to hear complaints. Regulation expanded in the rest of Europe and America in the early 20th century, always attempting to protect both free expression and the individual’s human rights.

Background to Ipso

Britain first set up a complaints body for the press with the Press Council in 1953. This followed a Royal Commission (the Ross Commission) which looked at a range of issues facing the press (Frost 2016: 267- 269).

The Press Council took complaints from the public but the numbers were relatively small and a code of conduct against which to measure complaints did not come into existence until late in the 1980s (ibid: 277). The Press Council was not looked on fondly by the public or politicians and faced consistent criticism as being protectionist of the industry.

In 1989, the government set up a commission under David Calcutt QC to examine the Press Council and the publishers moved quickly to launch the Press Complaints Commission (PCC), a streamlined complaints body with only editors and a small number of public representatives, as a replacement.

The Press Complaints Commission was also criticised by many for falling short of protecting the rights of celebrities and those who, through no fault of their own, rose to public prominence. The life and then tragic death in 1997 of Princess Diana, in particular, caused problems for a press trying to provide the public with news of their favourite celebrity and those who would have preferred a little more privacy for the wife of the heir to the throne.

In 2007, the News of the World’s royal editor, Clive Goodman, was jailed for phone hacking together with private detective Glen Mulcaire who had assisted him. This was the first known criminal case of the now notorious phone hacking. However, it was not until 2010 when the Guardian exposed that hacking was still continuing, despite strong denials from most publishers, that the public became enraged and the then-Prime Minister, David Cameron, called for a public inquiry, which was led by Lord Justice Leveson (Frost 2021: 298).

The PCC at first publicly claimed to be on top of the issue but then swiftly accepted that it was just a complaints body and not a regulator and agreed that it would shut up shop when a new regulator was formalised.

Conception of Ipso

Britain has two press regulators: The Independent Press Standards Organisation and Impress. The latter was set up in 2016, is recognised by the Press Recognition Panel and works under the Leveson report recommendations. However, it regulates only 128 independent publishers publishing 211 publications, a small number of the UK total.

Ipso was set up in 2014 by the main UK publishers and regulates most of the national press and much of the provincial press. The publishers said at the time they would launch a regulator that would truly regulate and set press standards and not just deal with complaints following widespread agreement that the PCC had failed. Leveson had examined the PCC in his inquiry and found:

... the PCC is hidebound by its inherent structure such that it has lacked the powers and sanctions required to do an effective job, which was – or at least ought to have been – to regulate the industry under its umbrella. Instead, self-regulation was simultaneously a panacea, a misnomer and a contradiction in terms (Leveson 2012: 1515).

It was the systems that Leveson sought to overhaul, including the optional nature of the PCC which came in for specific criticism:

... participation has been optional, and in the event never universal; and has always been contingent on an evaluation by individual titles or publishers of their self-interest. Newspapers notionally sign up, and remain tied into the rules of the system, but only for the period and to the extent that they judge that this is in their best interests (ibid).

Leveson recommended a system that would have ensured that regulation would remain optional but that there would be strong rewards for those who chose to participate and serious penalties for those who did not. These penalties and rewards were inserted in the Royal Charter and the Crime and Courts Act (2013) where Section 40 protected a publication from expensive litigation if it were a member of an approved regulator but ensured costs against a publication if it were not a member of an approved regulator.

Influential publishers refused to accept this proposal claiming that it was a restriction of free speech, persuading the government not to enact the agreed legislation. Instead, they set up Ipso that remained entirely optional using a system of contracts tying members to the organisation.

Ipso is made up of a board of 12 members ( we-do/people/board/) responsible for strategic oversight, a complaints committee of 12 members that rules on complaints ( what-we-do/people/complaints-committee/) and 20 salaried staff to handle complaints and arbitration, monitor press standards and provide administrative support. All of these people seem seriously concerned to do a good job of regulating the press.

Ipso’s work relies heavily and, indeed, in its day to day work, entirely upon the Editors’ Code. This came in for little criticism during the Leveson Inquiry but only because there were other, more important issues of concern such as the unwillingness of the PCC to set standards or investigate serious or systemic breaches unless it received a complaint. There are plenty of critics who believe that the code sets a minimum standard that is applied with a very light touch. Leveson felt that it was for the regulator to deal with the code rather than the inquiry. He pointed out, whilst discussing misogyny and other discrimination issues:

Those representing women’s and minority groups would be entitled to retort that if the Code as currently worded creates the kind of legalistic difficulties which have just been outlined, then the solution is a straightforward one: simply amend the Code. The force of this point is noted, but it should be considered in depth by any future regulator, rather than by this Inquiry (Leveson 2012: 661).

Ipso claims that independence is critical to its credibility and this is certainly important, but in its desperation to remain independent of parliament and government many claim it has tied itself too closely to the industry that funds it and provides many of the people who sit on its committees.

The newspaper industry presented draft proposals for this new regulator to the Leveson Inquiry in July 2012, but these were ‘rejected as an effective plan by Sir Brian Leveson’ (Ramsay and Barnett 2021: 6). The publishers claimed that the Leveson plan was ‘statutory regulation’ and was anathema to press freedom but Sir Brian Leveson dismissed this claim and rejected concerns that a libel disputes arbitration service would lead to additional costs ( leveson-dismisses-press-concerns-about-statutory-regulation-and-libel- arbitration/, accessed on 8 November 2023).

The publishers ignored his view and constituted the new regulator, including three quarters of the 84 draft industry proposals in the governance documents for Ipso (Ramsay and Barnett 2021: 6).

Most significantly, Ipso amended the crucial phrasing of a regulator’s ability to monitor, investigate and impose sanctions against publications found to have breached the Editors’ Code.

There had been much debate at the launch of Ipso about how this change from the PCC would be made to a new regulator and what specific changes would turn it from being merely a complaints handler. Leveson had rightly identified that Ipso should play a stronger role in setting standards but also identified that the new regulator should have the power to investigate and monitor the press with significant regulatory muscle to enforce its decisions. The Leveson report’s recommendation 19 says that a regulator:

... should have the power to impose appropriate and proportionate sanctions (including financial sanctions of up to 1% turnover with a maximum of £1m.) on any subscriber found to be responsible for serious or systemic breaches of the standards code or governance requirements of the body (Leveson 2012: 1805).

Alongside its new powers to investigate and monitor, this should have allowed Ipso to deter wayward publications from their worst excesses. However, Ipso was persuaded to change this recommendation in its governance documents from ‘serious or systemic’ breaches to ‘serious and systemic’. Ipso says:

Ipso can undertake a standards investigation to investigate where it has serious concerns about the behaviour or actions of one or more of its members ... Ipso may require that a standards investigation takes place where:

  • there may have been serious and systemic breaches of the Editors’ Code;

  • there has been one or more failure or failures to comply with the requirements of the Board;

  • an annual statement identifies significant issues of concern either in relation to a single incident or a pattern of significant, serial or widespread breaches of the Editors’ Code (, accessed on 22 August 2023).

Ipso goes on to say that if the matter is considered sufficiently serious it can impose one or more of the following sanctions:

  • publish an adjudication, which may include a requirement to address the concerns raised;

  • impose a fine on the member(s) of up to £1m.;

  • require the member to pay the reasonable costs of the investigation;

  • require a publisher to submit a quarterly statement for an agreed period;

  • terminate membership of Ipso (ibid).

To date, Ipso has only ever applied the first sanction. Ramsay and Barnett explain:

... it is clear that the Regulatory Articles are drafted in such a way as to render those powers virtually worthless. Crucially, the ‘serious and systemic failure’ formulation – inserted at the last minute into Ipso’s regulations by industry representatives – significantly raises the bar by which an investigation may be proactively launched, and thus weakens a core regulatory function. It remains unclear why representatives of Ipso, in public statements that in many ways echo those of the PCC, defend those parts of its constitutional documents that significantly limit its own power (op cit: 8).

As identified, this change significantly raises the bar. It is no surprise that no standards investigation has ever been carried out nor that any sanction other than the publication of a correction or a report of the adjudication has ever been enforced. Whilst many newspapers have arguably breached the code systemically and several have breached it seriously on occasion, breaching it seriously and systemically, apparently, has yet to happen. Ipso updated its corporate strategy in 2023 claiming:

Our purpose is to protect the public and freedom of expression by upholding high editorial standards. By protecting the public, we also protect freedom of expression, because we demonstrate that the press can uphold high standards without the need for further measures that would undermine press freedom ( what-we-do/our-corporate-strategy/, accessed on 22 August 2023).

Ipso does not explain how it intends to protect the public or press freedom that is any different to the guidance it used before 2023 and its approach to standards, regulation and complaints remains largely the same as it was under the PCC.

How Ipso handles complaints

Ipso makes complaining fairly straightforward, explaining on its website who can complain, whom can be complained about and refers the public to the Editor’s Code to find out what can be complained about.

Ipso says that anyone who is the subject of an article or who has been affected by a journalist’s behaviour can make a complaint or ask someone to complain on their behalf. In cases involving accuracy as defined by the Editors’ Code, any member of the public or any organisation can make a complaint.

Sometimes, Ipso will accept a complaint from a representative group affected by the alleged breach of the Editors’ Code. There is a time limit on complaints, usually four months. Ipso provides an online form but will also accept complaints by email or post. Ipso prefers complainants to have contacted the publication first but in any case will pass the complaint to the publication for them to try to resolve it before investigation. Ipso will help to mediate a satisfactory outcome where possible (, accessed on 22 August 2023).

Research questions

The aim of the research is to identify and gather evidence to allow the following questions to be answered.

  1. Is Ipso matching or exceeding the standards identified by Leveson as being required by a UK press regulator?

  1. Is Ipso a significant improvement on its predecessor, the PCC, in terms of the standards identified for a regulator by the Leveson Inquiry?

  2. Does Ipso maintain the standards it claims to set for itself as a press regulator?


In order to answer the research questions there needs to be a way of measuring Ipso’s performance as a regulator and being able to compare that with the PCC’s performance until it closed down in 2014.

One method of measuring performance would be to see if the ethical standards of UK publications have improved over time since 2011, when the Leveson Inquiry was set up. This would require a qualitative methodology, possibly using subjective analysis such as surveys or interviews since no direct quantitative method would be able to measure standards over a period of time. The use of surveys or interviews would be complex and largely meaningless as it would be very difficult to justify any readership sample in measuring ethical standards over a ten- year period.

It was decided to use a straightforward statistical analysis of Ipso’s regulatory performance as reported on their website (www.Ipso. and updated regularly and compare this with the performance of the PCC to allow a comparison with the work of the PCC from 1991 to 2014 and to identify Ipso’s performance since 2014. Since virtually all witnesses to the Leveson Inquiry accepted that the PCC was merely a complaint handler rather than a regulator and that this was unacceptable, Ipso would need to show a marked improvement in regulation performance over the PCC.

Ipso publishes details of each complaint it adjudicates in a publicly accessible website, identifying the publication, complainant, Editors’ Code elements complained of and the complaints committee’s decision. This index of complaints leads to the detailed decision of the complaints committee. Each complaint made to Ipso that has been adjudicated has been entered into a database set up by the researcher. The entry for every complaint in the database includes all the complaint details including the decision of Ipso on each aspect of the complaint and the action taken, if any.

The eventual verdict was listed against one of the following categories that Ipso uses:

Breach – sanction: action as offered by publication.

Breach – sanction: publication of adjudication.

Breach – sanction: publication of correction (these last two are combined for statistical purposes as there is little significant difference in terms of outcome).

Resolved – a resolution was reached often moderated by Ipso.

No breach – after investigation. The complaint is rejected and no further action is required either by Ipso or by the publication.

Many complaints concern two or more clauses of the editors’ code so, for instance, a complainant might complain about accuracy, privacy and children (see Figure 1 below).

Figure 1: Ipso website complaint listing showing complaints with multiple alleged breaches (, accessed on 22 August 2023)

Ipso identifies each complaint saying if it is in breach or not but does not specify in this indexing system which clause is in breach and which is rejected. Ipso claims it attempts to be open and transparent. But any inquirer seeking more detail than is presented in this index must access each individual complaint and read through the detail of the complaint to discover which clauses of the code complained of Ipso has adjudicated as being in breach of the Editors’ Code and to discover the details of the restitution or penalty. The database designed for this research allows the entry of details for specific complaint clauses in order to identify the number upheld for each clause as many complaints are only upheld for accuracy. Figure 1 above shows case No. 09841- 22. This covers accuracy, privacy and harassment but only the alleged accuracy breach is upheld by the complaints committee in this case. This is not unusual.

In order to ensure consistency in the analysis, the following rules were adhered to when identifying complainants:

  • Any complaint involving one complainant but more than one publication is listed as a separate complaint against each publication.

  • Complaints may involve several clauses of the code but this is still treated as one complaint. Complaints may, therefore, on occasion total more than 100 per cent.

    Ipso issues a range of data about its work, but none of it is particularly easy to access unless the investigator simply wants to find out the outcome of a particular case.

There is an index of investigated cases at resolution-statements/ that leads to each case (see Figure 1 above). Alongside it is a user definable filter index that should allow access to rulings by date, code provision, outcome and/or publication, but this does not work well with multiple filters, making access to performance data laborious. Searching for all privacy complaints against the Daily Mail from 2014 to date that were resolved, for instance, is cumbersome and very slow and often fails. It proved faster to load the index into Microsoft Access to make manipulation far faster and more detailed. Access to specific cases on the Ipso website can be made directly through Google, which proved far faster than using the Ipso’s own search.

Research data

Ipso issues figures for its work each year in its annual report. This gives the number of complaints and whether they were upheld, resolved, or rejected as follows:

Table 1: Complaints to IPSO according to the annual reports. (, accessed on 14 December 2023)

The annual report 2022 shows there were 35,658 complaints made in that year but 25,100 of these concerned one story – the Jeremy Clarkson column in the Sun concerning the Duchess of Sussex, a complaint that was eventually upheld. Typically there are around 14,000 complaints a year, although this can vary enormously. Taking this average as a possibility of complaints for 2023, Ipso will probably have received 162,631 complaints by the end of 2023.

Ipso rarely considers multiple complaints about the same article preferring to take a complaint from a person mentioned in the article to represent all the complaints or use a sample complainant. In the case of the Duchess of Sussex, the complaint from two representative campaigning groups were used.

Many of the complaints made to Ipso are rejected for the following reasons. For instance, in 2022, 38,658 complaints were made and 38,300 (99 per cent) were not adjudicated. Of those complaints investigated, 18 per cent were upheld, 0.2 per cent of the total complaints made. Those not investigated as being outside Ipso’s remit were as follows:

Table 2: Reasons for rejecting complaints 2022 ( Report 2022, accessed on 14 December 2023)

Complaint handling

Ipso will only accept third party complaints, that is a complaint from someone not directly involved in the article complained about, if the matter concerns accuracy. Ipso complaints officer Thomas Moseley explains in an Ipso blog: ‘as most matters of accuracy concern facts, anyone can complain’ ( blog-explaining-third-party-complaints/). However, he cautions: ‘Our regulations do not allow us to take forward complaints about issues other than accuracy from people with no connection to the alleged breach of the Code.’ This is, Ipso claims, largely because a complainant may not know how the person mentioned in the story feels about it. However, Ipso also does not take third party complaints even if no specific individual is mentioned.

Ipso only takes a complaint from the ‘lead complainant’. This will normally be the person mentioned in the story but might be someone else. Since some stories can attract hundreds or even thousands of complaints it makes sense for Ipso to choose a representative complaint to consider rather than rule on each of the hundreds of complaints.

Many publications are not members of Ipso. Some belong to IMPRESS, another regulator and some belong to no regulator and run their own in-house complaints system. Notable examples are the Guardian, the Independent and the Financial Times.

League table of complaints

Ipso does publish an annual ‘top 20’ league table of complained of publications in its annual report. The report for 2021 is headed ‘Newspapers with the highest circulation, digital reach and readership numbers receive the most complaints, but have the lowest proportion of breaches’. It goes on to report: ‘Unsurprisingly, the publications with the highest circulation and readerships received the most complaints’ ( but gives no reason why it believes high circulation or readership should have any effect on the number of complaints.

It only takes one person, usually the subject of the story, to complain. Indeed, for a large national newspaper, the type of persons they are writing about are often the very ones who are used to criticism and are more likely to shrug it off. Even if we concentrate on national newspapers, the Daily Express has only had half the complaints of the Daily Mail and the Daily Mail itself, only slightly more than a half of its sister, Mail Online. The Daily Mirror, meanwhile, has only about one third of the complaints of the Sun or the Daily Mail.

Table 3: top 30 complained of publications

The number of editions or total story count, of course, may be significant but whilst most national papers are dailies so are many regionals and whilst the nationals’ circulations will be higher, it is difficult to see how that would affect the level of complaints about issues such as accuracy, privacy, children and crime which form the majority of complaints to Ipso. Ipso also usually only takes complaints from the person involved in the complaint and even when they allow third parties to complain, they still only have one lead complainant. Get something wrong in the Sun, for example, and whilst there may be several thousand complaints, that still only counts for one complaint to be adjudicated as far as Ipso is concerned.

Ipso also identifies the number of complaints upheld as significant and it is certainly true that some highly complained of newspapers have relatively low rates of those complaints upheld. The average upheld complaints ratio for all newspapers is around 21.7per cent and all national newspapers is around 22.2 per cent (see Table 3) whilst the Daily Mail’s is 14 per cent and the Daily Mirror’s is 18 per cent. It is a bold claim to suggest that the highest circulation publications have the best record of complaint rejections since there are other factors at play, as will be identified later on.

Table 4: Adjudications of complaints by type of publication 2014-2023

Table 5: Complaints to 31 December 2023 by type of publication

Complaint overview

Table 6 shows the number of complaints made indexed by code clause to the end of 2023. As identified above we know that 109,967 complaints were received by Ipso up to the end of 2021. However, more complaints were received through 2022 and 2023 probably taking the total complaints received for the period of the study (September 2014 to 31 December 2023) closer to 163,000. Of these, 2,478 were adjudicated. Because many of these complaints concerned two or more alleged code breaches, Ipso dealt with a total of 4,559 separate code clause complaints. Of these complaints, 556 (22.4 per cent of the total) were upheld. Some 421 (17 per cent) were resolved leaving 1,501 (60.5 per cent) found not to breach the code. However, the picture is far more complicated than that as many of the complaints cover several code clauses.

Table 6: Complaints adjudicated to 31 December 2023 (total complaints figures for 2023 are unavailable at time of writing but average complaints per year are 18,579 to 2022 so a likely figure for total complaints to 31 December 2023 is 167,210)

Table 6 lists the total number of complaints made about each code clause. The second column of figures gives the percentage of the total number of complaints for that alleged code breach. This shows that accuracy is by far the most complained about with 2,118 (87 per cent) of all complaints including accuracy as part or all of the complaint. The next column identifies the number of complaints that contain an alleged breach under each individual clause that are upheld. This shows that 513 of the total complaints made are upheld, at least in part, because of a breach in the accuracy clause of the code. This represents 23.7 per cent of the 2,160 accuracy complaints made.

Complaints about accuracy

Accuracy is, of course, an important element of good journalism and it is important that such inaccuracies are picked up. The usual practice would be to contact the editor and seek to put the record straight. Many editors will make those corrections without interference from Ipso. Indeed, Ipso has a breach category where the sanction is action as offered by the publication that was not initially acceptable to the complainant. In other words, the publication has previously offered a form of words to set the record straight and Ipso later agrees to this as a suitable approach.

A substantial number of accuracy complaints are resolved, however, following Ipso mediation where the published response is negotiated by Ipso. A recent example of such a mediated resolution concerns case No. 17676-23 Logan and Logan v. the Daily Mail. The complaint concerned a story headlined ‘Tax scheme firm paid £500,000 to Gabby Logan’. The Daily Mail reported that:

... firms linked to the complainants ‘were paid more than £500,000 to promote major tax avoidance plans to celebrity friends’ and that ‘payments between 2010 and 2013 were apparently made for events such as Royal Ascot – entertaining “wealthy individuals” and introducing them to the venture’. The article went on to report that ‘questions have arisen after a court battle revealed that companies linked to the Logans received £518,405 in commission for introducing customers or potential customers’ ( rulings-and-resolution-statements/ruling/?id=17676-23, accessed on 23 August 2023).

The complainants said they had not received £500,000 to promote tax avoidance schemes, nor had they received payments for attending events with celebrities to introduce them to tax avoidance schemes, nor had they any link to any firm which received commission for introducing potential clients to tax avoidance schemes. The Ipso complaint report went on:

The complainants also said that they had no knowledge of the court hearing referenced in the article as being scheduled for 3 May, or of any ‘court battle’ which had ‘revealed’ that ‘companies linked to the Logans received £518,405 in commission for introducing customers or potential customers’. They said that no company linked to them was involved in any such legal proceedings. They also said that the named company referenced in the article had gone ‘bust’ in 2014, not 2017 as claimed by the article.

Finally, the complainants said that it was ‘grossly misleading’ to report that they had not responded to requests for comment, as the email that was sent to them seeking comment did not contain specific details of the alleged tax avoidance scheme. They also said that – while the article included a statement that had allegedly been made by their lawyers – no one acting on their behalf had made any such statement (ibid).

As the complaint was not resolved through direct correspondence between the parties, Ipso began an investigation. During Ipso’s investigation the Daily Mail offered the following correction that the Logans said would resolve the matter to their satisfaction:

An article on February 28 said that Gabby and Kenny Logan had received £500,000 to promote tax-avoidance schemes to their celebrity friends. In fact, Gabby played no part in the business and earned no income from it. Kenny’s role was solely to introduce clients to companies who promoted legitimate business services rather than tax avoidance schemes. In addition, they did not ‘disguise’ any income from this activity in order to avoid paying tax, as we reported. We apologise for the errors, and are happy to set the record straight (ibid).

It is difficult to see why, if the Daily Mail was willing to accept an error, that they did not put that right after the first contact with the Logans. Looking at the figures in Table 3 and comparing the number of resolutions for the Mail online and the Daily Mail with other newspapers near the top of the league table it is difficult to avoid the thought that Associated Newspapers does its best to deter complainants from pursuing complaints until Ipso is poised to adjudicate against them. All but one of the 30 resolutions of complaints (26.6 per cent of total complaints) against the Daily Mail involved Ipso mediation whilst all of the 58 resolved complaints against the Mail online (29.7 per cent of all their complaints) involved Ipso mediation. Most other newspapers had a much lower rate of resolution involving Ipso of between 10 per cent and 20.5 per cent. Interestingly, it was websites such as (19.1 per cent) and (20.5 per cent) that had the highest rate of Ipso resolutions. Print publications spanned 10 per cent to 15.6 per cent. It’s worth noting that only four complaints were ever resolved directly with the publication.

Privacy and intrusion cases

Although accuracy attracts by far the most complaints and are of considerable concern to the public there are other clauses that can cause more controversy and consternation with the public. The most obvious of those is privacy. We all have a right to privacy under UK law and the European Convention on Human Rights and it is a right that is being regularly developed through the courts (Frost 2019: 153-176) so it is no surprise that it comes second to accuracy in terms of complaint numbers. There are 738 complaints (29.8 per cent of total complaints) up to 31 December 2023 that claim a breach of clause 2 (privacy) as part or all of a specific complaint. Of these complaints concerning privacy 135 are upheld, but only 40 of those are upheld because the article breach clause 2 (privacy) of the code.

Accuracy is the largest number of complaints but privacy and associated complaints such as intrusion into grief, suicide, harassment and complaints concerning children are probably the more concerning for those making the complaints and are often involved with accuracy complaints.

Ipso adjudicates an average 74 complaints about privacy every year and upholds about 15.4 of them but only about four of them specifically concern privacy. The rest are usually deemed to be in breach because they fail the code’s accuracy clause.

Table 7: Upheld privacy complaints

It is not possible to say whether upholding between one and eight privacy complaints a year (see Table 7) is good regulation, in that it suggests that there is either relatively little to worry about in terms of press intrusion, or that Ipso is not being sufficiently firm in its judgements. Examining each privacy complaint and the outcome, even with a jury of several auditors, would almost certainly produce a highly contested view.

However, looking at the source of most of the complaints is instructive.

Table 8: source of complaints

The cases upheld are largely about health, as in injuries or illness (three cases), or identifying victims of sexual assault. The national publications are more likely to cover royalty or celebrities: Princess Beatrice, the Duke of Sussex, the Duke of York, Lily James and MP Nicholas Soames and other similar privacy revelations.

Harassment cases

Table 9: Upheld harassment complaints

Complaints about harassment by journalists either in person or by phone or electronically are very rarely upheld with only one complaint being upheld about harassment. Complaints about suicide coverage are also rare with only 29 complaints submitted and only one of those upheld.

Intrusion into grief and suicide cases

Ipso takes intrusion into private grief and suicide seriously and both attract a significant number of complaints. Ipso points out that a death is a matter of public record and may affect a whole community.

Ipso warns the press should not break the news of a person’s death to the immediate family and should show sensitivity in reporting. It also warns:

in cases where someone has died by suicide, they do not publish too much information about how they died ( press-releases/blog/reporting-on-a-death/, accessed on 26 August 2023).

Further guidance is available concerning funerals and inquests on Ipso’s website.

Table 10: upheld suicide complaints

Table 11: intrusion into grief complaints

Only 11.1 per cent of intrusion into grief complaints are upheld and 1.2 per cent of suicide complaints. This may simply be because bereaved families are understandably particularly sensitive and so less likely to complain because of the additional emotional pain that will introduce. The figures in Table 11 are slightly skewed as in 2021, 18 complaints involved three multiple complaints (one against five publications, one against three publications and one against two publications). None of the multiple complaints was upheld in respect of intrusion. Some of the cases have been mentioned before under the privacy heading as complaints about intrusion into grief and privacy are often made together.

Children cases

Table 12: Ipso upheld complaints concerning children; n.b. there are two upheld complaints concerning child sex cases

There are only 21 complaints concerning children but only 11 of these were upheld. All but complaint 01972-22 were mainly upheld as breaching clause 2 (privacy) of the child. Complaint 01972-22 concerned the social media comments of the sister of a school pupil who committed suicide after alleged bullying, that were used without consent of the parent. Five of the seven upheld complaints in 2023 concerned the same story about two children missing in Pakistan published in the Sunday Mirror,,, Mail Online and (see table 12).

Discrimination cases

Discrimination has long been a major issue in UK press regulation. The PCC and subsequently Ipso will generally only accept a complaint about discrimination from the person involved or their representative.

This ensures that the discrimination relates specifically to a person and not to a group of people whether that concerns race, ethnicity, age or gender. Ipso says:

In general, Clause 12 complaints can only be taken forward from the party directly affected – because the complaint might involve personal and sensitive information about a person, or we might not be able to investigate the complaint properly without their input. In certain cases, where there is a sufficient public interest, Ipso is also able to take complaints from representative groups affected by the alleged breach (, accessed on 24 August 2023).

This, of course, limits complaints about general discrimination against groups such as refugees, those from particular minorities, women and the disabled. It will be no surprise, then, to learn that Ipso has only upheld three clause 12 discrimination complaints although it has upheld 39 complaints that include discrimination as one of the elements. It is worth noting that it discounted 36 of them from being discriminatory.

Table 13: Discrimination complaints

Two of the complaints upheld about discrimination concerned disability and one concerned misogyny (see Table 14). The PCC had a similar poor track record regarding discrimination and campaign groups seeking to fight racism and misogyny and other forms of discrimination were vocal about it to Leveson. Leveson notes early on in his report that:

The Inquiry heard from a number of groups who advanced powerful arguments in favour of greater regulation, in particular for greater balance. Although the Inquiry received much evidence and submission devoted to the issue of the value of a free press in general terms, few came forward to advance the contrary case to that put forward by the groups I have mentioned (Leveson 2012: 661).

Despite this there has been no significant change in the Editors’ Code, largely based around an argument that this could limit free speech. Consequently, very few complaints about discrimination have been upheld and, indeed, most campaign groups no longer attempt to complain under this section of the code but concentrate on accuracy.

Table 14: Complaints upheld concerning discrimination

The first complaint upheld concerned a blind transgender woman hoping to stand for parliament who became the butt of a ‘tasteless’ joke in one of Rod Liddle’s columns in the Sun. The Brighton Argus story concerned a man found guilty of possessing indecent images of children.

In 2022, Jeremy Clarkson sparked anger from thousands by attacking the Duchess of Sussex in his Sun column. Ipso accepted and upheld a complaint from the Fawcett Society and the WILDE Foundation who complained that:

[t]he acts described by the author in his column and the language used is inherently misogynistic and sexualised, pointing to gender- based discrimination ( statements/ruling/?id=18626-22, accessed on 25 August 2023).

Comparison of PCC with Ipso

Ipso took over its complaints role from the Press Complaints Commission in 2014. Until July 2011 when the Leveson Inquiry was set up, the average number of complaints was 2,885 a year. This excludes 2009 when complaints rocketed to an astonishing 37,000 following a Jan Moir article in the Daily Mail concerning the death of Boyzone singer Stephen Gately that attracted more than 25,000 complaints. The Leveson Inquiry brought press regulation into public focus and complaints rose to an average 9,817 for subsequent years. This did not affect the average number of adjudicated complaints, however, or the average number upheld. Adjudications remained relatively static at an average 51 per year (see Figure 2) with an average 21.8 upheld each year.

Figure 2: adjudicated PCC complaints per year

Figure 3: Investigated Ipso complaints per year

In comparison, Ipso takes an average of 18,579 complaints (almost double the PCC), investigates an average 462 per annum (excluding resolved complaints where the complaints committee has not taken a view on whether there has been a breach), approximately four times as many as the PCC and upholds 66 on average each year approximately three times as many.

These figures do not suggest that Ipso is the startling success many would like to claim. It takes more complaints than the PCC year on year and adjudicates four times as many, but it only upholds 14.36 per cent of the complaints it investigates whilst the PCC upheld 42.5 per cent of adjudicated complaints. Neither complaints handler could claim gold standard results. Virtually all upheld complaints by both bodies concern relatively minor accuracy issues.


Publishers set up Ipso claiming it would become a regulator that would uphold the standards of press ethics and practice required by the Leveson report and parliament but constituted Ipso in much the same way as the PCC using much the same Editors’ Code. Ipso takes complaints from those named in stories about which they are complaining and decides if the articles complained of breach a code over which Ipso has no control and is decided solely by those with a vested interest – a committee of editors.

Is Ipso upholding the standards the public expects?

Ipso takes many more complaints than did the PCC but it is impossible to show why this is. Could it be because press standards are now lower than before Ipso took over and therefore there are more complaints? A more likely explanation, supported by the substantial rise in complaints in the PCC’s final years, is that the Leveson Inquiry and the phone hacking scandal have raised readers’ awareness of the issues of press standards and have advertised the ability of readers to make complaints about stories they felt failed to reach those standards.

As is seen in the analyses of complaints above, most of Ipso’s work is about accuracy, complaints that Ipso often resolves. In other words, most complaints concern inaccurate, biased, half-truth stories or misinformation to some degree or another and it is difficult to understand why an Ipso is needed to put such slipshod journalism to rights.

More complaints about issues such as invasion of privacy, intrusion into private grief, dealing with children or discrimination are rarely upheld. Often this is because the publisher plays a long game, dragging out the complaint until the complainant gives up or accepts a limited resolution statement.

Of course, many privacy and intrusion issues are never complained about in the first place as this would just exacerbate and prolong the invasion of their lives. Whilst those with money go to the civil courts to seek justice, allowing publishers to complain bitterly about how the courts are strengthening privacy law, those without money just have to deal as best they can with their shattered lives.

There is zero evidence that Ipso is able to do anything to help those traduced by the national press, and it is the national press that is the demon here. The provincial press and magazines have their problems, but they are mainly to do with inexperienced staff rather than attempts to spice up the news with coverage of the private lives of celebrities and other hallmarks of the nationals (Frost 2012). Very few provincial papers or magazines have more than a couple of complaints over the nine years and few of those are upheld. Most have never had a complaint.

Ipso has failed to be an effective regulator and for the same reasons as the PCC. Ipso seems designed to protect publishers from their readers and to the extent that complaints are shrugged off it succeeds. But it can be argued that it has also failed to protect newspapers in that by colluding with standards that fall below reader expectations this is just another reason why circulations are dropping at 10 per cent or more a year for the past ten years ( and-business-data/media_metrics/most-popular-newspapers-uk-abc- monthly-circulation-figures-2/, accessed on 24 January 2024). At a time of universal social media, trust in news provision is essential if providers are to maintain their markets.

Publishers have claimed that Ipso is an improvement on the PCC and that it maintains high ethical press standards. No evidence has been presented to support that view and readers are voting with their wallets.

Is Ipso upholding the standards it sets for itself?

Ipso measures complaints from the public against the Editors’ Code. This is amended from time to time but has not changed significantly since the early days of the PCC. Leveson recommended that a regulator worthy of support should monitor standards and investigate systemic or serious breaches.

Ipso has monitored standards over the years and starting in 2018 has published details of its activities quarterly on its website. Since then (until September 2022) Ipso has considered 85 cases of complaints concerning:

Table 15: Ipso standards monitoring

Not surprisingly accuracy was the main concern with 27 offerings of advice, followed by suicide and intrusion into grief, privacy and children and their welfare. Vulnerable groups such as disabled people, minority ethnic groups and the victims of crime and domestic abuse made up the other cases.

Ipso says it monitors complaints to:

... monitor trends and, where necessary, to take targeted action to address issues of concern in a proportionate way, ideally at an early stage. The ongoing monitoring of standards themes is vital to ensuring that IPSO remains aware of any potential issues and is able to respond appropriately ( statements/, accessed on 20 October 2023).

Ipso uses this to issue guidance to editors and the public.


Does Ipso match the standards identified by Leveson? Ipso does not provide serious incentives for publishers to join as recommended by Leveson and it has deliberately refused to seek recognition from the Press Recognition Panel. It has an arbitration scheme, but this is only compulsory for a small number of national newspapers. It has not used the powers Leveson recommended of investigation for systemic or serious breaches and, indeed, has deliberately raised the bar to limit the opportunity for its use. There is no evidence that Ipso is matching the standards Leveson sought.

Ipso cannot claim to be a significant improvement on the PCC. Large numbers of publishers are members, but some significant national publications that used to be members of the PCC are not. Opportunities for redress for complainants are no better with Ipso and although the number of complaints are higher, examination of those complaints show little or no evidence that there has been a significant change in newspaper standards. Ipso also does not show a significant improvement on the PCC in upholding complaints. Many of the more serious issues are ignored because they do not directly address the code – something that Ipso identifies itself in its standards monitoring. Ipso upheld only eight complaints concerning children, yet identified 10 issues worthy of monitoring in only four years. It upheld only three complaints regarding discrimination yet identified four separate cases of transgender issues alone that it wished to monitor. Similarly, it only upheld five complaints about intrusion into grief yet identified 19 cases of intrusion into grief or suicide that it felt warranted monitoring. Even by its own standards of concern there is no evidence that it is a successful successor to the PCC in raising standards or even giving satisfactory restitution to complainants.

This leads to the research question of whether Ipso matched the standards it sets itself and the answer has to be no. Ipso is just another complaints handler acting as a smoke screen for the industry that funds it. Moreover, it has failed to raise standards for an industry that is doomed without satisfactory and trustworthy standards.


Frost, Chris (2012) Newspapers on the naughty step: An analysis of the ethical performance of UK publications, Journalism Education: The Journal of the Association for Journalism Education, Vol. 1, No. 1 pp 21-34

Frost, Chris (2016) Journalism ethics and regulation, London, Routledge Frost, Chris (2019) Privacy and the news media, London, Routledge

Hacked Off (2022) Analysis of IPSO rulings 2020. Available online at ipso-2020/

Ipso (2015) Annual reports. Available online at reports

Leveson, Brian L.J. (2012) An inquiry into the culture, practices and ethics of the press, Vol. IV, London, House of Commons

Nordlund, Sven (1991) An address to the Stockholm symposium on press councils and press ethics, June

Ramsay, Gordon and Barnett, Steven (2021) How UK news publishers set up their own regulator to avoid scrutiny, London, CAMRI, University of Westminster

Conflict of interest

The author received no funding for the research involved in this publication, but if you wish to send money to fund future research...

Note on the contributor

Chris Frost is Professor Emeritus of Journalism at Liverpool John Moores University and the former head of journalism there. He has been a journalist, editor and journalism educator for more than 50 years. He is a former National Chair of the Association for Journalism Education, a member of the National Executive Committee of the National Union of Journalists, chair of the union’s Ethics Council and a former President. He is also a former member of the Press Council. He is a co-editor of Journalism Education and sits on the editorial board of Ethical Space as well as several other journals. He was a sub-panel member for the RAE2008 and REF2014. He has written several books on journalism including Journalism ethics and regulation (now in its fourth edition); Reporting for journalists and Privacy and the news media as well as a number of book chapters and papers about journalism ethics and regulation. He has spoken, lectured and worked as a consultant throughout Europe and in much of Eastern Europe, India, Asia and Africa and is a visiting professor at UiTM in Malaysia.

No comments here
Why not start the discussion?