BBC
TELEVISION LICENSING
NO LICENCE NEEDED POLICY
Note: Appendices I-IV of this document have been redacted as the information is
exempt under sections 31(1)(a), (b), (d) and (g) and (2)(a) of the Freedom of
Information Act 2000 which relate to law enforcement, specifically that disclosure
would, or would be likely to, prejudice the prevention or detection of crime, the
apprehension or prosecution of offenders, the collection of the licence fee and
the BBC’s ability to discharge its public functions in respect of such matters.
This is because they contain information which could be useful to people
attempting to evade the licence fee.
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Index
1. Purpose ........................................................................................................... 5
2. Scope............................................................................................................... 5
3. Definitions ........................................................................................................ 5
4 General Principles ........................................................................................... 6
5. Processing declarations ................................................................................... 7
6. Visiting addresses ............................................................................................ 7
7. Guards ............................................................................................................. 7
8. Changes in No Licence Needed Claims Status (including transfer of No Licence
Needed Claim to a new address) ............................................................................ 8
9. Detection and Search Warrant Procedures ..................................................... 9
Appendix I – [Redacted]
Appendix II – [Redacted]
Appendix III – [Redacted]
Appendix IV – [Redacted]
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1. Purpose
1.1 To state the BBC’s policy with respect to those places, occupied as residential
accommodation and non-residential premises, whose occupier has declared that there
is no television receiving equipment being used at the address (known as making a No
Licence Needed claim).
1.2 Note that ‘television receiving equipment’ refers to any apparatus used or installed for
licensable activity (see para 3.0).
2. Scope
2.1 This policy sets out the procedure for:
processing and maintaining No Licence Needed claims
contacting addresses which have made a No Licence Needed claim and
visiting addresses which have made a No Licence Needed claim
2.2 This policy applies to premises being used for the purposes of both residential
accommodation and non-residential arrangements.
3. Definitions
3.0 Licensable activity – under the Communications Act 2003 and Communications
(Television Licensing) Regulations 2004 (as amended) licensable activity broadly means
using or installing any device to:
a) watch or record any television programme service;
b) watch or record any television programme at the same time (or virtually at the
same time) as it is being shown on any television programme service; or
c) (as of 1st September 2016) watch or download any BBC programme on demand
on BBC iPlayer, even if it is accessed through another provider, such as Sky,
Virgin Media, Freeview or BT.
Licensable activity does not include:
a) watching programmes by means of pre-recorded media such as DVD and Blu-
ray;
b) downloading or watching S4C TV on demand on BBC iPlayer or listening to radio
programmes on BBC iPlayer.
c) downloading or watching on demand programmes from other providers, such as:
ITV Hub, All 4 or Demand 5
BT Vision, Virgin Media or Sky Go
Netflix or Now TV
BBC TELEVISION LICENSING NO LICENCE NEEDED POLICY [BBC001] v4.7 Page 5 of 10
Apple, Roku or Amazon
3.1 NLC – a residential address is categorised as No Licence Needed Claim (NLC) when
TV Licensing receives an oral or written (including email) declaration that television
receiving equipment at the address is not being used for licensable activity.
3.2 NLCC – a residential address is categorised as No Licence Needed Claim Confirmed
(NLCC) following a visit where the visiting officer has verified that television receiving
equipment at the address is not used for licensable activity.
3.3 NLSG – a residential address is categorised as No Licence Needed Claim Short Guard
(NLSG) when TV Licensing receives a No Licence Needed claim and is informed that
the individual or occupier intends not to use television receiving equipment for licensable
1
activity at the address for a period of time less than one year .
3.4 BNLC – a non-residential address is categorised as Business No Licence Needed Claim
(BNLC) when TV Licensing receives an oral or written (including e mail) declaration that
television receiving equipment at the address is not being used for licensable activity.
3.5 BNLCC – a non-residential address is categorised as Business No Licence Needed
Claim Confirmed (BNLCC) following a visit where the visiting officer has verified that
television receiving equipment at the address is not used for licensable activity.
3.6 NLE – an address (residential or non-residential) is categorised as No Licence Needed
Expired when a No Licence Needed Claim (or No Licence Needed Claim Confirmed)
has expired. This is an internal classification designed only to provide a full history of
the address for the TV Licensing Field Operations team.
3.7 Place – refers to a licensable place, as defined by the BBC’s Licensable Places Policy.
3.8 Occupier – incorporates both domestic residents and non-residential premises
representatives (e.g. the manager of a business).
4 General Principles
4.1 Addresses which claim No Licence Needed shall be dealt with in accordance with the
principles set out in this policy. The BBC has an obligation under the Communications
Act 2003 to enforce the TV Licensing system. Consequently, the rationale behind TV
Licensing’s monitoring of residential No Licence Needed Claims is based on the fact
that figures from the Broadcasters’ Audience Research Board (BARB) show that the
2
percentage of households in the UK with a television is around 96% .
4.2 In line with the obligations outlined above, TV Licensing reserves the right to visit
addresses which have claimed No Licence Needed. This is because, although the
majority of No Licence Needed claims received by TV Licensing are genuine, latest
figures3 show that one in six such addresses are found to need a licence when TV
Licensing makes contact with them.
1
Note that this circumstance only applies to residential addresses and not to non-residential addresses.
In practice, it is most likely to apply to student accommodation.
2
More information on BARB can be found on their website at http://www.barb.co.uk/
3
As at March 2018
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4.3 This policy will be reviewed regularly and may be adapted on receipt of suitable
evidence for change.
5. Processing declarations
5.1 TV Licensing’s policy process for dealing with No Licence Needed claims is outlined at
Appendix I.
5.2 After an individual has made a No Licence Needed claim to TV Licensing, written
acknowledgement and an explanation of the NLC process will be sent to the individual.
The address will be given NLC status, mailings to the address will cease for a specified
period of time and the premises will become available for visiting in order to confirm that
a licence is not needed.
6. Visiting addresses
6.1 TV Licensing will visit a sample of NLC addresses to confirm that a licence is not
needed. A methodology will be used to determine which addresses will make up the
sample for visiting. This methodology is outlined in Appendix II4.
6.2 However, in some circumstances NLC addresses will be specifically excluded from the
sample for visiting, in the interests of fairness. These circumstances are set out in
5
Appendix III . In these circumstances, any confirmation on expiry of the NLC guard
that the relevant circumstances remain unchanged will result simply in the maintenance
of its NLC guard and the address will remain within the exceptions from visiting.
6.3 A No Licence Needed visit may have a variety of outcomes. A list of these outcomes is
6
set out in Appendix IV .
7. Guards
7.1 The relevant residential guard lengths are as follows:
NLC Approximately7 two years from the date the claim was recorded.
NLCC Approximately8 two years from the date the visit took place.
NLSG Any length up to approximately9 one year from the date the claim
was recorded
7.2 When a NLCC guard expires, confirmation that the circumstances remain unchanged
will lead to the address returning to NLC status and becoming available for a further
visit. When any guard expires, TV Licensing will maintain a “No Licence Needed
Expired” category on its database in order to provide a full history for the TV Licensing
Field Operations team.
4
This methodology is confidential. It is not for release into the public domain, since any disclosure would
in itself undermine the deterrent effect of TV Licensing’s enforcement strategy.
5
As per footnote 3 above
6
As per footnote 3 above
7
We say ‘approximately’ because we write to check the licensing status at an address a little earlier, to
allow time for the customer to respond.
8
As per footnote 7 above.
9
As per footnote 7 above.
BBC TELEVISION LICENSING NO LICENCE NEEDED POLICY [BBC001] v4.7 Page 7 of 10
7.3 It is the BBC’s view that two years is a reasonable length of time for residential guards,
given that residential circumstances frequently change. For example, occupiers may
move house or change their viewing habits such that a licence is required. As noted
above, latest figures10 show that one in six such addresses are found to need a licence
when TV Licensing makes contact with them, hence it is important to ensure TV
Licensing’s data is accurate in order to assist in the efficient use of the licence fee.
7.4 The relevant non-residential guard lengths are as follows:
BNLC Approximately11 three years from the date the claim was
recorded.
BNLCC Approximately12 three years from the date the visit took place.
7.5 It is the BBC’s view that non-residential addresses should have longer guards because
they are likely to change their status regarding receiving television programmes less
often than residential addresses. TV Licensing is also more likely to receive regular
external data for non-residential addresses which informs them of a change of status13.
Hence where this has not occurred, an assumption can more easily be made that there
has been no change of status regarding receiving television programmes.
7.6 The relevant short guard lengths are as follows:
Student addresses Nine months
Non-student addresses Dependent on information volunteered by
Occupant, up to one year.
7.7 It is anticipated that the majority of short guards shall relate to student addresses. They
shall only be applied to non-student addresses where the occupant has informed TV
Licensing that they intend to occupy the property for less than one year.
8. Changes in No Licence Needed Claims Status (including transfer of No
Licence Needed Claim to a new address)
8.1 The status of a NSC address may change or be re-checked with customers in the
following circumstances:
10
As at March 2016.
11
As per footnote 7 above.
12
As per footnote 7 above.
13
For example, when a business changes name and the Postal Address File linked to it changes
correspondingly; TV Licensing will be informed of this circumstance.
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Trigger Change
Visit See Appendix IV.
Purchase of TV Licence Address loses NLC/NLCC status and returns
14
to standard mailing cycles.
Notification received of new occupant at Address either:
address which has previously been given
15 (a) loses NLC/NLCC status and returns to
NLC/NLCC status
standard mailing cycles (or to start of NLC
cycle if new occupant claims NLC).
OR
(b) Receives a request to reconfirm NLN
status from the existing occupant or new
NLN claim from the new occupant.
Customer change of address NLN status (guard length) is reaffirmed which
re-starts the NLN process (see 8.3).
BBC or third party data received, indicating to Address receives a request (from TVL) to re-
TV Licensing a change of licensing affirm the NLN status (if the occupant is the
requirements same) or confirm their licensing requirements if
a new occupant.
Customer notification of change of licensing NLN removed – note this will only happen if the
requirements (now requires licence) customer has the same name.
Change to what constitutes licensable activity. Address receives contact from TV Licensing
before the end of the usual guard period.
8.2 In such cases, TV Licensing will maintain a “No Licence Needed Expired” category on its
database in order to provide a full history for the TV Licensing Field Operations team.
8.3 In the event that the occupant(s) of premises notifies TV Licensing that they have
moved, an existing No Licence Needed Claim will be transferred to the new address.
This is equally true for both residential and business premises. For practical reasons,
the guard will be reset, thereby guarding the new address from further mailings for a full
period of either two or three years, as applicable (depending upon whether the premises
concerned is residential or business).
8.4 In the case of those premises listed as NLCC or BNLCC on the TV Licensing database
(i.e. where a visit has confirmed the veracity of the No Licence Needed Claim), that
status will be retained at the new address, and the occupant(s) will therefore continue to
be protected from the possibility of a further visit as well as from mailings until their
status reverts to NLC or BNLC at the end of the guard period (i.e. in two or three years
respectively from the move to the new address).
9. Detection and Search Warrant Procedures
9.1 Detection and search warrants will be used as a means of last resort.
14
As at Sept 2016. There may be exceptions to this depending on circumstances.
15
Examples of such notifications will include (but not be limited to): contact with a new occupant, receipt
of a “returned post undeliverable” or confirmation from another third party source such as the edited
electoral roll.
BBC TELEVISION LICENSING NO LICENCE NEEDED POLICY [BBC001] v4.7 Page 9 of 10
9.2 Detection will be carried out in accordance with the BBC Policy on the Authorisation and
Operation of Detection Equipment under the Regulation of Investigatory Powers Act
2000. Search warrants will be executed in accordance with the Capita search warrant
policy.
Note: Appendices I-IV of this document have been redacted as the
information is exempt under sections NOTE
31(1)(a), (b), (d) and (g) and (2)(a) of
theThe BBC considers
Freedom much ofAct
of Information the2000
material
whichin the following
relate to lawappendices to be
enforcement,
CONFIDENTIAL.
specifically that disclosure would, or would be likely to, prejudice the
prevention or detection of crime, the apprehension or prosecution of
offenders, the collection of the licence fee and the BBC’s ability to
discharge its public functions in respect of such matters. This is because
they contain information which could be useful to people attempting to
evade the licence fee.
BBC TELEVISION LICENSING NO LICENCE NEEDED POLICY [BBC001] v4.7 Page 10 of 10
