The 130-page document, entitled 'Building Public Value', was published yesterday (Tuesday). It puts forward the case for the BBC to play a leading role in providing digital content across traditional TV and radio as well as new media.
It argues that the BBC's public service broadcasting (PSB) commitment means it is uniquely placed to provide free digital services to the full population.
The submission is likely to anger both advertisers and rival publishers, which have accused the BBC of straying beyond its remit both online and in digital TV. The result of a government inquiry into the BBC's online services, chaired by Philip Graf, was originally expected in the spring, but has seemingly been put on hold.
The submission, the BBC's first response to Ofcom's PSB review, comes two weeks after submissions made by the Incorporated Society of British Advertisers and other broadcasters.
Commercial operators must wait until the conclusion of a review launched by new director-general Mark Thompson to discover the BBC's long-term strategy on commercial activities, including those of BBC Worldwide and BBC Ventures.
As part of a management restructure, Thompson has announced a pared-down executive board and the creation of three boards covering creative, journalism and commercial activities. Top marketer Andy Duncan will sit on the creative, commercial and executive boards.