Broadcasting and Citizens
by Anja Herzog
1. TV VIEWERS PARTICIPATION IN DENMARK
The TV landscape1 in Denmark consists of a dominant public service and a smaller private sector: Until 1988
broadcasting comprised just the public service company Denmarks Radio, which today provides two national TV
channels. In 1988 the second national television company TV2 was established, which also receives a certain
(much smaller) amount of the licence fee. TV2 is the market leader with 35 % of market share regarding total
population in 2002, 31 % in satellite households (DR1: 28 %, 25 %). The other important players especially in
satellite broadcasting on the Danish TV market are Kinnevik’s TV3 and the second channel 3+, broadcasting from
London, and Tv Danmark, a network of local stations relying on SBS investments. Market shares of the
commercial channels regarding satellite households were in 2002 for TV3: 9 %, 3+: 5 %, TvDanmark 1: 3 %
and TvDanmark 25 %.
In Denmark quite a complex system of accountability and participation does exist, there are different institutions
and panels dealing with supervision/control, self-regulation, quality of TV programmes etc.
1.1 National Institutions and Government bodies
The political responsibility for the broadcasting sector is taken by the Ministry for Culture. The most important
institution under the Ministry for Culture for our question is the Media Secretariat2, an independent institution that
administers the licence funds as well as government grants. Apart from this it hosts the Radio and Television
Board. This is „the independent authority in a range of mediamatters. The Board has seven members, who must
have expertise in the legal, media, business and cultural fields. They are appointed by the Minister of Culture for
four years. The decisions of the Board can not be appealed to the Ministry“. The tasks of the Board are to take
decisions concerning licences for national and regional programme services (terrestrial analogue broadcasting), to
supervise programme services, to register enterprises providing services via satellite, communal aerial
installations (exceeding one local area), terrestrial digital television broadcasting frequencies, short-wave
broadcasting frequencies; to protest infringement of Broadcasting Act and provisions pursuant to it and to take
decisions concerning withdrawal or lapse of licences. The Board is dealing with complaints, but does no
monitoring at all. Normally it deals with violations of the law on the basis of complaints and sometimes because
there is a debate in the public.
The interests of parents and their children are represented by the Medierådet for Børn og Unge (Media Council
for Children and Young People). It aims among others in classifying films for the protection of minors. The
members of the Council are appointed by the Ministry of Culture. (See 3.3).
The Consumer Ombudsman deals with everything concerning the interests of consumers, it provides advice
concerning prices and quality of all kinds of goods. People can complain about the prices of goods as well as
problems with contracts for products or misleading advertisement. Appointed by the Minister for Trade the
Ombudsman regulates advertising under the Marketing Act/Consumer Law, particularly those areas in which
offences against the law often occur, or in which they are of particular harm to consumers, or where they may
otherwise be of great practical importance. The difference between complaints on misleading advertisement at the
Ombudsman and the Radio & TV Board is in the addressee: Through the Ombudsman the complaint is addressed
to the advertisers, through the Radio & TV Board to the broadcasters. The website3 of the Consumer Ombudsman
gives an comprehensive overview on the field of consumer interests and clear advice, how to complain.
In Denmark the Press Council (Pressnaevnet, established pursuant to the Danish Media Liability Act4) is an
independent, public tribunal which deals with complaints about the mass media. The press ethical rules are the
guidelines according to which the Council determines if media have acted contrary to them. Guidelines how to
file a complaint are available via Internet. The Council is composed of a Chairman, a Vice-Chairman and six
members. The Chairman and Vice-Chairman are appointed by the Minister of Justice on the recommendation of
the President of the Supreme Court, while the members are appointed on the recommendation of organisations of
the press. (See 3.2)
As an institutions of self-regulation the ReklameForum5 (Association of Danish Advertisers) tasks are “to respond
to competitive complaints about comparative advertising from member advertisers or agencies, to produce and
implement Codes and Guidelines about comparative advertising for the industry, on which it also advises the
Consumer Ombudsman”. It uses the ICC Code (last updated in 1997). The RF does not have or seek statutory
powers and its decisions are not legally binding; it has not been the subject of litigation. “Executive Order
protects children and young people against misleading TV advertising on toys, prices, foods; children under 14
can appear in TV advertising under restricted conditions, but cannot provide testimonials”6:
Advertisements directed at children and young people must not have a mentally or morally detrimental effect on
such persons and must not exploit children and young people’s natural credulity or loyalty, or their special
confidence in parents, teachers or others.
Advertisements should be presented in such a way that they do not affect the safety of children and young people
by showing them in unnecessarily dangerous situations or areas or using dangerous products.
Social values may not be undermined by conveying the impression that the possession, use or consumption of a
product in itself will give children or young people physical, social or psychological advantages. It is not
permitted for advertisements to be designed to give children and young people the impression that their failure to
own, use or consume the relevant product will expose them to contempt or ridicule.
Advertisements may not directly appeal to children and young people with the effect to persuade others to buy a
product, or promise prizes as a reward for winning new purchasers.
In relation to young people and children the general provisions on misleading marketing are interpreted so that
advertisements may not mislead children and young people as to the size, value, type, durability, performance or
the degree of skill required to use the product. Statements of price may not give children and young people an
unrealistic idea of the value of the products.
Advertisements for chocolate, sweets, soft drinks, snacks etc may not indicate that the product may replace regular
meals. Figures, puppets and similar which are important and regular elements in children’s programmes may not
appear in advertisements for products of particular interest to children. Persons affiliated with children’s
programmes may not advertise products of particular interest to children.”
The Danish public service broadcaster DR provides an interesting feature in the context of accountability and
online participation: The research department in addition to the quantitative audience research installed an online
panel DR/Panelet, in which the viewers (actually 30.000 members of the panel) can give a feedback to special TV
programmes via a questionnaire (15-20 questions). At the website there are also different forms for comments,
ideas, questions etc. on the programmes of the different DR channels7. Apart from this DR has a 24-hour
complaints department, that the viewers can contact via telephone, mail or e-mail. In Denmark every broadcaster
has such a department although some are not as active as the others. (See 3.4)
Broadcasting and Citizens
1.3 Other Organisations
In Denmark several viewers’ organisations do work very actively and with different perspectives on the media,
some are focussing on Christian tasks, some on the public service function of the media and some on protection
of minors. There is an organisation, the Cooperative Forum of Danish Listeners and Viewers Associations, which
bundles the interests of the organisations.
One very active organisation in Denmark is the Arbejdernes Radio- og Fjernsynsforbund (ARF)8, which aims to
increase the democratic dialogue in the media. (See 3.1) There are two Christian viewers’ organisations in
Denmark: KLF, Kirke og Medier and the Kirkeligt Medieforum for Unge (KMU - Christian Association for Youth
and Media), these are voluntary organisations with the main focus on the protection of minors and the increase of
children’s media competence.
The Consumer Council (Forbruger Radet9) is a consumer organisation including 32 member organisations dealing
with a big range of topics (e.g. Danish Animal Welfare Society, Danish Association of Senior Citizens, Family and
Community, Green Families, etc.). The aims of the council are “to work for the protection of consumer health and
safety, for consumer rights and economic interests and for the consumer rights to information and education; to
advance consumer views vis-à-vis Parliament, public authorities, the business community, etc.; to effect that the
consumer interest is represented in councils and commissions and on boards and committees etc. dealing with
consumer relevant issues; to carry on test, investigation and information activities within the scope of our
mission; to work for the advancement of consumer education in primary and lower secondary school and
elsewhere in the education system.”
The Council is involved in a wide range of consumer issues: food quality, environmental protection, health
services, financial and legal services and issues connected with media, telecommunications, universal services,
etc. It publishes a journal with results of tests and other information. On the website a guide how to complain can
be found, as well as a lot of information on consumer issues and a link to the journal of the organisation.
Local and Open Channels are another possibility for the TV viewer to participate. An interesting example is TV
STOP, “a small local television station, with approx. 100.000 regular viewers, based in Copenhagen. TV STOP
has been broadcasting since April 1990. […] TV STOP was founded in the squatters movement and the left wing
scene in 1987. The idea was to produce television that was committed, unpredictable and free of any commercial
interests; to produce programs that dared to have a political point of view.” The ultimate aim of the organisation
is to stop people from watching TV and to activate and mobilise the viewers.
2. TV VIEWERS RIGHTS : THE REGULATORY FRAMEWORK
2.1 Sector (TV) specific regulation
The TV sector is regulated basically by the Danish Radio and Television Broadcasting Act (17.12.2002)10. The Act
differentiates five types of broadcasting licences: DR, TV 2, local radio and TV-stations, national cable and
satellite broadcasting, terrestrial broadcasting.
Apart from the Broadcasting Act political agreements valid for four years (latest from 2002 – 2006) are the second
constituent of TV regulation in Denmark. The latest political agreement states that DR and TV 2 are to invest in
domestic productions. In the agreement the license fee is determined; a part of the licence fee is allocated to
establish digital radio and TV-stations. It is planned to auction the fifth and the sixth national analogue radio
Further regulations can be found in the Consumer Law (The Ministry of Culture’s Executive Order No. 489 of
June 11, 1997, Executive Order concerning Radio and Television Advertising and Programme Sponsorship) which
contains special rules on the protection of children and young people under the age of 18 as well as in the Media
Liability Act (9.2.1992) which regulates all media and establishes who is liable with respect to criminal law and
law of tort, it contains Press Ethical Rules.
Decisions concerning licences for national and regional programme services and the supervision of programme
services are under the responsibility of the Ministry of Culture, where the Mediesekretariet (see 1.1) deals with
An interesting feature of the Danish legal framework is the Charter for Interaction between Volunteer
Denmark/Associations -Denmark and the Public Sector by the Ministry of Culture. The purpose is “to provide the
individual citizen with the best conceivable framework for participating actively in community coalitions and to
strengthen the forces of social cohesion; to help build respect for the diversity of goals and forms of organisation
in Volunteer Denmark/Associations Denmark; to strengthen and develop the interaction between Volunteer
Denmark/Associations Denmark and the public sector while respecting their differences; to maintain and develop
the efforts of Volunteer Denmark/Associations Denmark to promote the development of society, the welfare of
community coalitions, and the individual’s quality of life; to promote volunteer efforts and make them more
2.2 Regulatory practices for positive and negative content regulation
The licences of DR and TV2 commit the broadcasters to have their programmes well-balanced, targeting all
possible groups, including minorities. Advertisement must be broadcast in blocks, and not take more than 15 %
of total time. Promoting tobacco, economic or religious groups as well as political parties is prohibited. Denmark
implemented the regulation concerning protection of minors and protection against programme contents that
fosters hatred according to the EU directive.
In general, Mrs. Fieve from the Radio & TV Board states, that the regulating tradition in Denmark is much more
tolerant than in other (even Scandinavian) states, e.g. pornography is not forbidden in Denmark and through this
there is no big problem with it as there are only some small local broadcasters that offer it in the night. There is
from time to time a discussion on this issue.
2.3 Instruments established by law
The Radio & TV Board (Mediesekretariatet) is engaged in all three dimensions of viewers’ interests: Viewers
protection is the main area of activities of the Radio & TV Board, relatively often it deals with the protection of
minors, the protection against programme contents that fosters hatred etc. The right of privacy is normally dealt
with by the Press Council. Consumers interests: Concerning advertisement the Board has some obligations laid
down in the Broadcasting Act, but the public service broadcasters have specific obligations and their own rules,
which are more strict, for which the Board is not in charge. Some of the consumer interests are dealt with by the
Consumer Ombudsman, especially questions of advertising that are falling under the Marketing Act and directed
to the advertisers, not to the TV channels. Questions of poor services are not in the frame the Board deals with.
Citizen enhancement: As one task of the Board is to licence and supervise the broadcasters the general
requirements for mass media and especially for public service broadcasting (diversity etc.) are in its focus. The
Board is dealing with complaints, but does no monitoring at all.
2.4 Complaint procedures (established by law)
As mentioned above there are several institutions a viewer can file a complaint to, if he or she has got a problem
with the media. The Radio & TV Board is dealing with all kinds of violations of the law. The Consumer
Broadcasting and Citizens
Ombudsman in the field of media deals with complaints against advertisers. The Press Council can be appealed
to for violations of the Press Ethical Rules and if the right of reply is concerned. For problems with TV programme
content the viewer can directly appeal to the TV broadcasters. (See 3.4)
The Radio & TV Board in most of the cases deals with violations of the law on the basis of complaints, but in
some cases a debate in the public caused the Board to intervene. The number of complaints is relatively low, e.g.
on youth protection there are under 10 complaints per year. In general, there are not many complaints on contents,
but mostly on advertisements. Complaints are directed to the Board from all parts of society, by normal people.
The Board can rule violations of the law by warnings or by withdrawal of the licence. It can not impose fines. The
only possibility to impose a financial penalty is that the police takes up the case and brings it to the court, but this
is quite rare. This is a point the Board is not content with. Compared with the overall number of complaints filed
to the Consumer Ombudsman (e.g. in 2003: 2.580 complaints), the number of complaints on media issues
respectively advertisements is very low.
The complaints procedure of the Press Council is described on its website. This means rules like the need to
complain within 4 weeks, that the concerned party must be mentioned, depicted or in other ways be identifiable
etc. The Press Council decides within 70 days and publishes the decisions.
The Press Council may also try a case of its own accord where essential. The Council has no right to impose fines
on a media or award an offended party any kind of compensation. Instead of filing a complaint with the Press
Council, an offended party can choose to take the matter to court: therefor provisions of the Danish Penal Code
must be violated and the Press Ethical Rules should be regarded.
3. VIEWERS’ ORGANISATIONS SOCIAL IMPACT
3.1 Case Study 1: Arbejdernes Radio og Fjernsynsforbund, Kirke og Medier, SLS
ARF has got 33.000 members and is organised in approximately 150 local clubs. The aims of ARF are to secure
and increase the democratic dialogue in the media and to abet the public service in its functions (quality, diversity,
etc.). One important feature is that ARF argues against broadcasting of commercials in public service
programmes, because they should not get influence on the programme. Another important theme is the technical
reach of television, e.g. DR2 is not available for 20 % of the Danish people and ARF claims that public service
programmes should be available for every citizen.
To follow these aims ARF does a lot of networking with the different broadcasters, with media politicians and
with other civil society associations dealing with the media. It takes part in public discussions, provides
information in its journal and on its website12. The site provides newest information as well as a contact list for
the local clubs, a newsletter, the articles of the ARF journal “Radio & TV Nygt” and a quick poll on current media
ARF has several contacts to viewers’ and other organisations in different European countries e.g. VLV (in UK),
Kölner Initiativkreis zur Förderung des Öffentlichen Rundfunks, Familie & Medier in Norway, Finland.
Beneath ARF there is another big viewers’ organisation in Denmark: Kirke & Medier (KLF) with 40.000 members
and with the special focus on representation of Christian topics in the programmes and on ethic questions. KLF
like ARF is organised in local organisations and represents viewers’ interests in the local forums of DR. On its
website13 KLF provides a radio & TV guide with recommendations on the current programmes of the different
Danish broadcasters. Apart from this there is a form for complaints on programmes at the website as well as
general statements on questions like media ethics and report on qualitative analysis of viewers reception of special
The KMU is another Christian viewers organisation of Catholics with similar aims, it is smaller with 5.000
members organised in eight regions. Another small organisation argues against EU membership and focuses on
these themes in the media. All of these organisations provide information and newsletters on their websites.
All viewers organisations are in the cooperation organisation SLS, which has got the right to be heard in issues
the Ministry of Culture raises for discussion or for regulation. Through this a constant dialogue is installed.
Another institution dealing with TV programmes on a national level is the Programme Council. This Council does
not have any formal influence on the broadcasters, but it is a regular dialogue in meetings twice a year with the
directors and chief editors of DR and TV2. For this meeting the viewers’ organisations can choose representatives
as well as employees, unions, etc. may send representatives. DR in an analogue way installed regional dialogue
forums with representatives of the viewers and with the local chief editors.
3.2 Case Study 2: Press Council
The Press Council consists of 8 members, on the one hand appointed by the Ministry of Justice and on the other
hand they are representatives for the journalists, for the media and for the citizens. The Council is dealing with
complaints from people, companies, associations etc. concerning denunciation in all kinds of media. The Council
does no monitoring and therefore does not rise cases on its own. Although it (the chairman) may pick up issues,
this was just once the case with an article dealing with Prince Frederik, because the royal family could not take
the initiative itself.
The Press Council as an institution in general is efficient, as viewers as well as the media seem to be content with
its work, both sides are represented and by this can take influence in the decisions. The media see that the working
conditions of the journalists are taken into account. The efficiency of the system can also be seen in the short
period a complaint is dealt with in the Council, it comes to a decision within 70 days the longest.
At present in the public the establishment of an Ombudsman is discussed, who should do a monitoring of the press
and by this be able to take up cases on his own. For example the publication of dying children in Beslan in the
newspapers could be such a case, which the Press Council would not deal with, although it probably should be
dealt with. Different opinions are expressed in the public on this issue and in the Press Council this theme is
discussed as well. Another argument for an Ombudsman is that it possibly could make faster decision. Mr. Grubbe
doubts this as the basis of a decision has to be correct and differentiated information of both sides, which takes its
3.3 Case Study 3: Media Council for Children and Young People
The Media Council for Children and Young People14 consists of a chairperson and 6 members all appointed by the
Minister of Culture. Three members are experts on children, two have a thorough knowledge of the film industry,
one represents the areas of culture, media and research. At least two members must have a pedagogical or
psychological education or through their work have acquired special knowledge concerning problems related to
children and young people. The chairperson and the experts on children form the Media Council’s Classification
Board along with a number of substitutes with the equivalent thorough knowledge of children and young people.
The members are appointed for a period of three years with the possibility of one reappointment.
The main tasks of the Media Council today are: “to lay down criteria for classification of films, to provide
guidance and information regarding films, to take initiatives concerning the suitability of films, to assist the
Minister of Culture in issues concerning regulations related to electronic games, children and the new media in
general, to establish contact and dialog with TV stations etc., to participate in Nordic co-operations, to monitor
international development. The Media Council’s most important messages are: Young children should be
protected against vast amounts of raw violence. Children should learn to reflect on the content of what they spend
time on. Parents, teachers and others should actively participate in developing children’s media competence, and
Broadcasting and Citizens
provide them with the relevant information to participate safely in our multimediated society. Media competence
is developed not through prohibition but through knowledge and education. Users should have the opportunity to
choose films and games based on a labelling system of guidelines rather than prohibitions.”
3.4 Case Study 4: DR research & complaints
Besides quantitative research DR installed an online panel (DR Panelet) at its website with today 30.000
members/participants, who regularly answer to short questionnaires (15-20 questions) on certain TV programmes.
For example, in the last half year the people focused on two serials, which they watched regularly and than
answered the questionnaire. Questions are for example “Did you like the programme?” and are dealing with the
studio design, with the hosts performance etc. When people enter the panel they can tell themselves which
programmes they watch regularly.
Another feature of viewers participation in DR is the possibility to complain. DR has got a special department for
this contact to listeners and viewers. There are different ways to complain – via telephone, by mail or e-mail. The
telephone contact is working 24 hours a day. The feedback DR gets here is rather manifold, some do complain on
the content and some just like to have more repeats of a programme or a airing time as they missed a special
programme or they want to have a video copy (which is not possible for copy right reasons). The frequency of
these “complaints” is very different sometimes in one hour 500-1.000 statements are registered and sometimes
very few. The complaints are put together in a report every day and distributed to the executives of DR. All types
of people do contact DR this way, while the public debate is often dominated by “opinionised”, more academic
people. Sometimes DR has contacts with the viewers organisations in Denmark, which are regionally organised
and meet maybe once a year in a “Programme Council”.
There is some overspill with other organisations like unions and parties. In the opinion of our contact person from
DR the viewers organisations are very present in the public, organise meetings etc. In the boards of DR are no
viewers organisations represented, but representatives of political parties.
4. BEST AND INNOVATIVE PRACTICES
Viewers’ interests in Denmark are taken into account on different levels by different institutions and because of
this the accountability system as well as the participation of viewers organisations could be taken as a model for
a well-running accountability system.
The viewers can individually file their complaints to different institutions (the broadcasters, the Consumer
Ombudsman, the Press Council, the Radio & TV Board) and by this different kinds of complaints, different
interests are taken into account (consumers, citizens and groups, that should be protected). The viewers
organisations are very active civil society groups taking part in the public discussion on media development and
Very interesting and important features are the different discussion forums established at the regional as well as
the national level. For example. at the Programme Council meetings representatives of the public service
broadcasters take part as well as members of the viewers’ organisations. The meetings have counterparts at the
regional level. The viewers organisations do have regular meetings in the framework of their cooperative
organisation SLS. And there was a Council at the national level with participation of media politicians and
officials, which was closed down by the government.
These features illustrate the general awareness of the need for viewers’ participation and that a good step towards
institutionalisation of participation in Denmark has been already done.
1: The Danish Radio and Television Broadcasting Act
(ACT No. 1052 of 17 December 2002)
Chapter 1 - Provision of programme services
1. The following enterprises shall have the right to provide programme services as stated in Section 2.
1) Danmarks Radio, cf. Chapter 4.
2) TV 2/DANMARK, cf. Chapter 5.
3) The regional TV 2 stations, cf. Chapter 6.
4) Enterprises having been licensed under Chapter 8 to provide national or regional programme services on the
basis of a special licence, or which can, under Section 47, provide programme services without a licence.
Chapter 3 - Public service activities
10. The overall public service activities shall provide, via television, radio and Internet or similar, the Danish
population with a wide selection of programmes and services comprising news coverage, general information,
education, art and entertainment. Quality, versatility and diversity must be aimed at in the range of programmes
provided. In the planning of programmes freedom of information and of expression shall be a primary concern.
Objectivity and impartiality must be sought in the information coverage. The programming shall ensure that the
general public has access to important information on society and debate. Furthermore, particular emphasis shall
be placed on Danish language and culture. The programming shall cover all genres in the production of art and
culture and provide programmes which reflect the diversity of cultural interests in Danish society.
11. Public service programmes are provided by Danmarks Radio, TV 2/DANMARK and the regional TV 2
stations pursuant to the provisions of Chapters 4-6.
(2) Furthermore, the programme services on the fourth FM radio channel and the news coverage on the fifth FM
radio channel, cf. subsections (3) and (4), form part of the general public service activities. Licences to provide
such programme services shall be granted pursuant to the provisions of Chapter 8.
(3) The fourth FM radio channel shall be a varied public service-oriented channel providing classical music –
supplemented with the presentation of rhythmic music, jazz and Danish music – cultural programmes and
programmes of social interest and debate, etc.
(4) Programming for the fifth FM radio channel shall include news programmes from the whole country. The
programming may not be regionalised. A licence to provide such programmes may not be granted to Danmarks
(5) The public services of Danmarks Radio shall be financed through Danmarks Radio’s share of licence fees and
via income from other services, cf. Section 15 (2). The public services of TV 2/DANMARK shall be financed
through TV 2/DANMARK’s share of licence fees, via income from advertising on TV 2/DANMARK and via
other income, cf. Section 25 (2). The public services of the regional TV 2 stations shall be financed through the
stations’ share of licence fees and via income from other services, cf. Section 35. The public services of the fourth
and fifth FM radio channels shall be financed by the licensees.
Chapter 7 - The Radio and Television Board
Broadcasting and Citizens
39. The Minister for Culture shall set up a Board, the Radio and Television Board. The Board shall consist of
seven members and shall together represent expertise in legal, financial/administrative, business and
media/cultural affairs. Each term of office shall be four years.
(2) Having obtained an opinion from the Board, the Minister may lay down its rules of procedure. In the rules of
procedure provisions may be laid down for the Board to set up subcommittees that shall finally decide cases on
behalf of the Board.
(3) The Minister may lay down rules concerning fees payable for licences to provide programme services, etc. and
registration of programme services, to help to cover expenses related to the activities of the Radio and Television
(4) Local radio and television boards, cf. Section 64, and radio and television enterprises, etc. covered by the
activities of the Radio and Television Board, shall be under an obligation to provide the Board with the
information and documents, etc. requested by the Board. The Board may set a deadline for the provision of
(5) The Radio and Television Board may request written statements from local radio and television boards and
from radio and television enterprises, etc. covered by the activities of the Radio and Television Board. The Board
may set a deadline for the provision of such information, etc.
Chapter 11 - Advertising and programme sponsorship
72. Advertisements must be clearly identifiable as such, their content and presentation distinguishing them from
73. Advertisements on television shall be transmitted only in blocks to be inserted between the programmes. This
shall not apply to teletext advertisements.
(2) Advertisement blocks may, however, interrupt sports programmes where breaks occur, or programmes which
are transmissions of performances or events where there are intervals for the audience. Scheduling of such
advertisement blocks shall take into account the programme’s natural breaks, duration and nature in such a way
that the integrity and value of the programme shall not be compromised nor the owner’s rights infringed.
74. Radio advertisements may be scheduled at any time during the programme service.
75. Advertisements may occupy maximum 15 per cent of the individual licensee’s daily broadcasting time, and
maximum 12 minutes per hour.
(2) Subsection (1) shall not apply to teletext advertisements.
76. Advertisements for tobacco products and for articles mainly used in connection with the smoking of tobacco
are not allowed, cf. the Act on Prohibition of Tobacco Advertisements, etc.
(2) Advertisements for pharmaceutical products and healthcare services are permitted subject to the provisions of
the Pharmaceuticals Act and the Act on Advertisement of Healthcare Services.
(3) Advertisements for employers’ organisations or trade unions or for religious movements or political parties are
not allowed on television.
77. The Minister for Culture may lay down detailed rules concerning the inclusion of advertisements in
programme services, including rules for the identification, scheduling, content and extent of radio and television
78. Complaints concerning advertisements and programme sponsorship, cf. Section 44, shall be lodged with the
Radio and Television Board within four weeks of the broadcasting of the advertisement or programme concerned.
(2) The Radio and Television Board may decide to take up cases at its own initiative.
(3) The Minister for Culture may lay down rules on the lodging of complaints concerning other matters relating
to advertisements and programme sponsorship. Programme sponsorship
79. Programme sponsorship shall mean any contribution, direct or indirect, to the financing of radio or television
programmes, including teletext pages, from a natural or legal person not engaged in the broadcasting or
production of radio or television programmes, films, phonogrammes, etc., with a view to promoting the name,
trademark (logo), image, activities or products of that person.
80. Sponsored programmes shall be clearly identifiable as such by appropriate credits appearing at the beginning
or end, or both, of the programme, showing the sponsor’s name or trademark (logo). Such credits may not appear
in the programme itself. On teletext the sponsor’s name or trademark (logo) shall appear on the individual pages
(2) Identification of sponsorship from enterprises the activities of which include production or sale of
pharmaceuticals may not be in the form of promotion of specific pharmaceuticals which are prescription drugs
under the Pharmaceuticals Act.
81. The content and scheduling of a sponsored programme shall not be influenced by the sponsor in such a way
as to affect the responsibility and editorial integrity of the radio or television enterprise.
82. No sponsored programme may encourage the sale of the sponsor’s or a third party’s goods or services or
promote the goods or services thereof.
83. Programmes may not be sponsored by enterprises whose principal activity is to produce or sell tobacco
products or other goods primarily used in connection with smoking.
(2) No radio programmes forming part of the overall public services, cf. Section 11, and no television programmes
may be sponsored by employers’ organisations or trade unions or by political parties or religious movements.
84. No sponsored news and current affairs television programmes may be broadcast.
(2) News and current affairs radio programmes which do not form part of the overall public services, cf. Section
11, may be sponsored.
85. The Minister for Culture may lay down detailed rules for programme sponsorship and for how programmes
for which broadcasting time has been paid may be included in the programme services.
2: Contact persons:
- Jette Fieve, Radio & TV Board
- Preben Sörensen, ARF
- Niels Grubbe, Press Council
- DR research (contact person left DR)
The general information are based on the following articles: Ole Prehn (2004): Medien in Dänemark, in: Hans-
Bredow-Institut (ed.): Internationales Handbuch Medien 2004/2005, Baden-Baden, pp. 234-245. Per Jauert/Ole
Prehn (2000): The Danish media landscape, available at: http://www.ejc.nl/jr/emland/denmark.html.
Broadcasting and Citizens
Documented on the website of the Ministry of culture: http://www.kum.dk/sw4498.asp
DENMARK - Overview of institutions dealing with viewers' interests