Handling IMPRESS Complaints as a UK Editor

What IMPRESS is and who it regulates

IMPRESS (the Independent Monitor for the Press) is the only press regulator in the UK currently approved by the Press Recognition Panel (PRP) under the Royal Charter on the Self-Regulation of the Press. Established in 2016, it primarily regulates independent, regional, and online news publishers rather than the major national newspapers, most of which are members of the rival regulator IPSO.

Membership of IMPRESS is voluntary, but carries significant legal consequences under the Crime and Courts Act 2013. Publishers that join a PRP-approved regulator gain cost protections in defamation and privacy litigation that are unavailable to unregulated publishers or those belonging to non-approved bodies. This framework was a direct response to the recommendations of the Leveson Inquiry.

For editors at IMPRESS-regulated publications, understanding the complaints process is not merely a matter of good practice — it is a contractual obligation under the IMPRESS membership agreement and, in some respects, a legal one under the framework created by the Crime and Courts Act 2013.

The IMPRESS Standards Code

The IMPRESS Standards Code sets out the professional and ethical standards that member publications must uphold. It covers accuracy, privacy, harassment, discrimination, children, crime reporting, public interest, and payment to sources and criminals. The Code was developed following extensive consultation and is regularly reviewed.

Editors should be particularly familiar with the following Code provisions in the context of complaints:

• 1Accuracy (clause 1): Publications must take reasonable steps to ensure content is accurate, fair, and not misleading. Where an error is made, a correction must be published promptly and with due prominence.
• 2Privacy (clause 3): The Code recognises a right to privacy but sets out public interest exceptions. Editors must be able to justify any intrusion into private life by reference to a legitimate public interest.
• 3Harassment (clause 4): Publications must not engage in persistent pursuit of an individual against their wishes, and must not direct others to do so.
• 4Discrimination (clause 7): Publications must not publish content that discriminates against individuals on protected characteristics unless there is a clear public interest justification.
• 5Children (clause 8): Special protections apply to the reporting of children, including restrictions on interviewing or photographing children about personal matters without parental consent.
• 6Public interest (clause 5): The Code defines public interest broadly but requires that the public interest served by publication outweighs any harm caused, and that the least intrusive approach was taken.

The IMPRESS complaints process — step by step

The complaints process under IMPRESS is structured in two main stages: an internal stage handled by the publication itself, followed — if unresolved — by formal consideration by IMPRESS. Editors must ensure their publication has a published, accessible complaints procedure that meets IMPRESS requirements.

The IMPRESS arbitration scheme

One of the most significant practical differences between IMPRESS and IPSO is that IMPRESS operates a low-cost, binding arbitration scheme. All IMPRESS members are contractually required to offer arbitration to any person who has a civil law claim against the publication arising from the publication's journalistic activities, provided the claim falls within the scope of the scheme.

The arbitration scheme covers civil claims in defamation, privacy, breach of confidence, malicious falsehood, and harassment. It does not cover criminal matters or claims that do not arise from the journalistic activities of the publication.

Under the scheme, arbitration is conducted by an independent arbitrator appointed by an approved arbitration body. The process is designed to be faster and less costly than court proceedings. Awards made by the arbitrator are binding on both parties and enforceable as if they were court judgments.

Recognised regulator status under the Crime and Courts Act 2013

The Crime and Courts Act 2013 created a legal framework designed to incentivise publishers to join a PRP-approved regulator. The key provisions are found in sections 34 to 42, which deal with exemplary damages and costs in civil proceedings for defamation, privacy, and harassment.

For editors at IMPRESS-regulated publications, the most important protections are as follows:

These provisions only apply to publishers that are members of a body approved by the PRP. As of 2026, IMPRESS is the only such approved body. IPSO is not PRP-approved, which means IPSO members do not benefit from these statutory cost protections.

How IMPRESS differs from IPSO in practice

Editors moving between IMPRESS and IPSO-regulated publications, or those considering which regulator to join, should be aware of the key practical differences between the two bodies.

Editor obligations and best practice

Editors at IMPRESS-regulated publications bear personal responsibility for ensuring their publication's compliance with the Standards Code and membership obligations. The following practices are essential:

• Maintain a published, accessible complaints procedure that meets IMPRESS requirements — this must be easy for members of the public to find on your website.
• Acknowledge complaints promptly and respond substantively within the required timeframe (typically 28 days).
• Keep records of all complaints received, the publication's response, and the outcome — these records may be required by IMPRESS.
• Ensure all staff and contributors are aware of their obligations under the Standards Code, particularly on accuracy, privacy, and discrimination.
• When a breach of the Code is identified — whether through a complaint or internal review — act promptly to publish a correction with appropriate prominence.
• Be familiar with the IMPRESS arbitration scheme so that you can respond appropriately when a civil law claim is raised — including making a timely offer of arbitration where appropriate.
• Review editorial decisions against the public interest provisions of the Code before publication, not only after a complaint is received.
• Maintain membership in good standing — a lapse in membership removes your Crime and Courts Act 2013 protections.

Common pitfalls for IMPRESS-regulated editors

• ⚠Failing to publish a complaints procedure — IMPRESS requires members to have a clear, accessible process. Absence of a visible procedure is itself a compliance failure.
• ⚠Treating the regulatory complaint and a potential civil law claim as the same process — they are separate tracks with different outcomes and different timescales.
• ⚠Refusing or ignoring an arbitration request without legal advice — refusing arbitration offered by a claimant can trigger adverse cost consequences under the Crime and Courts Act 2013.
• ⚠Publishing a correction without adequate prominence — a correction buried in a footer or without a link back to the original article may not satisfy the Code.
• ⚠Assuming IMPRESS membership protects against all costs in litigation — the protections are conditional on maintaining membership and offering arbitration where required.
• ⚠Not keeping records of the complaints process — if IMPRESS investigates and you cannot demonstrate what steps were taken, the absence of records will count against the publication.
• ⚠Confusing the Standards Code with the IPSO Editors' Code — they differ in structure and emphasis. Do not rely on IPSO guidance when you are regulated by IMPRESS.

Frequently asked questions