I suppose it is technically true that we don't call commercial television "free television" but TV broadcasters don't really establish any terms and conditions. Informally, I think they say they are a free service in PR interactions from time to time.

Shouldn't it really be more significant when a company takes payment but continues to also monetize ads. I.e. not disclosing the money made from product placements in a movie in a ticket purchase is a specific fraud relating to a transaction with a measurable cost.