CRA's board includes executives from 2DAYFM owner Southern Cross Australia, Grant Broadcasters Group, Macquarie Media, HT&E's KIIS 106.5 broadcaster Australian Radio Network, Capital Radio Network, Super Radio Network and Lachlan Murdoch's NOVA Entertainment.

Nine Entertainment Co, owner of this masthead, has a 54 per cent stake in 3AW and 2GB owner Maquarie and is looking to buy 100 per cent of the radio broadcaster.

Facebook and Google do have relationships with digital advertising verification services in Australia, however the radio group argued that without an independent intermediary who could collect and analyse the data with a consistent methodology the "potential for the distortion of advertising metrics will remain".

"The mere existence of companies able to provide digital audience measurement services does not assist in creating consistency, accuracy and transparency and will allow misleading claims to continue to flourish," the 15-page report said.

The submission said that different suppliers use a range of methodologies, making it hard to compare results, with the methods often not as transparent as required with no external auditing process. No data is gathered by third parties, with Facebook and Google controlling the access, CRA said.

"The current mechanisms – under which the digital platforms gather and control their own data without third party oversight – does not enable transparency or accuracy of measurement."

A Google spokeswoman said the search giant had "accurate, reliable measurement solutions, which follow industry standards and are subject to independent accreditation and audit through the Media Ratings Council".

A Facebook spokeswoman said the social media platform had worked with third-party measurement companies since 2008 and now had more than 40 partners including respected groups like Nielsen and Quantium and was also audited through the Media Ratings Council.

“We’re now working with MRC to achieve accreditation across viewability, or how long an ad appears on a screen, through third-party vendors ... and have rolled out a new buying system that uses the MRC’s definition of viewability," she said.

The radio lobby group also suggested that any attempts to automate journalism or aggregate it have regulatory oversight into audience measurement verification and compensation for the owners of the content.

Another major concern for the radio collective was copyright infringement. A statement from CRA chief executive Joan Warner said that radio broadcasters were increasingly focusing on getting their content and intellectual property removed from third-party aggregation sites and mobile applications.

"Typically, such sites provide ‘listen live’ links to station broadcasts or enable consumers to access stations’ podcasts. This diverts traffic – and ultimately advertising revenue - away from the stations’ own websites,” Ms Warner said.

“We urge the Commission to address this issue in the proposed Mandatory Standard, by requiring digital platforms to remove hyper-links to copyright protected content at the request of the rights holder,” she said.

CRA suggested "immediate action" be taken on regulatory imbalances between broadcasters and digital platforms. The ACCC's preliminary report in December suggested a review should take place, but the radio lobby group argued this was likely to "take several years to complete and implement".

Of particular concern for broadcasters is the election blackout period imposed on radio stations and free-to-air television but not on digital platforms, requiring no political advertisements to be shown for a few days before the polling day, as well as content quotas. Commercial free-to-air lobby group FreeTV has also called for these issues to be reviewed immediately.