General Principles and Record Keeping - Regional Publications

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General Principles and Record Keeping

This section sets out some key requirements relating to the overall reporting and auditing of your ABC claim.

Principles

1. Publication must be eligible to report under the Reporting Standards

2. Copies must comply with the Reporting Standards 

3. Transactions related to the claim must be bona fide ‘arms length’ arrangements

4. Evidence to support the claim must be retained and available for a minimum period

5. There is a designated Audit Issue 

Requirements 

1. Publication must be eligible to report under the Reporting Standards

1. You may apply to register a print or digital publication under the Regional Publication/ROI Newspaper Reporting Standards if it is:

   1. Published in a defined region of the UK (i.e. not one that is available throughout all or most of the UK); or

   2. Published with the majority of its circulation is in the Republic of Ireland.

   3. Clear from the publication name and/or content that it relates to a defined region of the UK or the Republic of Ireland.

2. Copies must comply with the Reporting Standards  

1. Copies claimed must comply with the relevant sections of these Reporting Standards with the following exceptions which you specifically cannot claim:

   1. Free copies to contributors

   2. Free copies to advertisers

   3. Free copies to advertising agencies. 

   4. Free copies to press cutting agencies. 

      Note: Single Free Letterbox Delivery copies to contributors, advertisers, advertising agencies or press cutting agencies can be claimed if they form part of the normal distribution.

   5. File or office copies

   6. Free publisher employee copies

   7. Paid publisher employee copies (unless they qualify under the Paid Employee Copies category or they are purchased as a normal consumer)

3. Transactions related to the claim must be bona fide ‘arms length’ arrangements

1. Transactions or arrangements (such as sales, circulation or distribution services) with your own organisation or Related Parties will initially be deemed as not bona fide ‘arms-length’ for ABC purposes, meaning they cannot be included in your claim. However they can be included if you are able to demonstrate to  the satisfaction of your auditor or ABC that these comply with the Reporting Standards and are bona fide ‘arms length’ arrangements.

2. Related Parties for ABC purposes will include where:

   1. One party has direct or indirect control of the other party; or

   2. The parties are subject to common control from the same source; or

   3. One party has influence over the financial & operating policies of the other party to an extent that the other party might be inhibited from pursuing at all times its own separate interests; or

   4. The parties, in entering a transaction, are subject to influence from the same source to such an extent that one of the parties to the transaction has subordinated its own separate interests.

   5. Transactions between contract publishers and their clients are deemed not to be arms length in relation to a specific publication produced for that client.

This means the following are considered Related Parties for ABC purposes:

1. 1. • The publisher, its subsidiary, parent and fellow undertakings (and Directors of these)

      • Associates and Joint Ventures (and their investors)

4. Evidence to support the claim must be retained and available for a minimum period

1. You must retain and be able to provide all records supporting the claim, including but not limited to: 

   1. An analysis of the claim by issue.

   2. Evidence supporting the number of copies printed for each issue claimed.

   3. Evidence supporting the number of copies distributed for each issue claimed, relevant to its circulation type.

   4. Evidence for each copy supporting the relevant circulation category and geographical region in which it is claimed on an issue by issue basis (i.e. not on a transactional basis). 

   5. A copy of each issue and any Editions claimed.

   6. Financial records.

2. Records supporting the claim must be retained:

   1. If ABC is the auditor, until we have completed the audit of the certificate for the subsequent corresponding Reporting Period. For example the records supporting the July to December 2020 period must be retained until we have completed the audit for July to December 2021.

   2. If you use a non-ABC auditor, until you receive the certificate for the subsequent corresponding Reporting Period.

   3. For monthly Reporting Periods until 3 months after the end of the Reporting Period.

3. Records supporting the claim must be retained and made available to your Auditor or ABC on request, in accordance with the ABC Byelaws.

Guidance Available

5. There is a designated Audit Issue

1. The Audit Issue is a designated issue in the Reporting Period for which the Reporting Standards specify certain information is required to be retained or reported.

2. For 6 or 12 month Reporting Periods ending December the Audit Issue is the last issue dated November and for Reporting Periods ending June the last issue dated May.

3. For monthly Reporting Periods the Audit Issue is the issue distributed nearest to the 21st of the month. Where this issue was either not published or excluded under the exclusion rules then the previous claimed issue will be the Audit Issue.

   1. If two issues are equidistant from this date then you may choose either as the Audit Issue.

4. For any other Reporting Periods the Audit Issue is the issue distributed nearest to the first day of the last month in the Reporting Period, which also falls within the Reporting Period.

   1. If two issues are equidistant from this date then you may choose either as the Audit Issue.

Guidance

G4. Evidence to support the claim must be retained and available for a minimum period

1. In relation to evidence supporting the number of copies distributed for each issue claimed, this must enable identification of the publication name, issue and quantity of copies. This means copies posted using a franking machine will not normally be able to be claimed as the records will not identify what has been posted.

2. In relation to mailed copies there is no need to remove copies from the claim that are returned because they are undeliverable. For example copies returned addressee gone away or not known.

3. In relation to print evidence you will normally provide print invoices and evidence of payment. If printing is carried out in-house or within a Related Party organisation then production records may be required. Other financial records may also be reviewed.

4. In relation to distribution evidence you will normally provide distributors' invoices/despatch notes and evidence of payment. Other financial records may also be reviewed.

5. In relation to publication sales you may need to provide access to financial records including sales ledgers and bank statements on request.

6. The auditor may accept copies of records stored electronically, but we advise you check first.

7. If records are not available or not accepted by your auditor/ABC then this may result in copies being disallowed, certificates being withdrawn or cancellation of the publication's ABC registration.

8. For ease of auditing and to avoid additional costs any mailing list supplied for audit should be presented in a format agreed between you and your auditor. One agreed format is:

   1. One file per publication in a comma-delimited format

   2. One line per addressee

   3. Each addressee coded to identify the circulation category/rate in which it has been claimed

   4. Separate fields for name, job title, company name, address records, circulation code, geographical code, request dates, number of copies etc

9. We offer an optional ‘sealed galley’ service whereby a mailing list tested at an audit can be treated as a valid source record for future audits. This avoids the need to go back to original documentation at a future audit if a record is included on a mailing list previously audited and sealed. Please contact us for further details.