(November 2014)


The implementation of the MPM2014 for Denmark shows a low/medium risk for media pluralism in the country. According to the results obtained through the implementation of the MPM in Denmark, the risks in the country are divided as follows: 20% (7) of the indicators fall within the zone of high risk; 18% (6) indicate medium risk, and 62% (21) refer to low risk.


Legal Type of Indicators Assessing Risks to Media Pluralism

The overall conclusion of the legal indicators is that they pose relatively low risk. This conclusion is based on the fact that 14 indicators of 20 score low risk, 3 indicators score medium risk (6, 16 and 20), and the remaining 3 indicators assess a high risk (7, 9 and 14).

The system functions based on the arm’s length principle, and it is relatively simple as the rules are adhered to. There is no general media pluralism legislation on ownership, but mergers and acquisitions have to be effectuated in accordance with the general competition rules. The media system is highly influenced by the public service media, especially in radio and television, but also online. This has resulted in recent discussions on competition between public and private media, especially in relation to digital media provisioning. Small markets like the Danish one, with a population of about 5.6 million, will have difficulties in securing the provisioning of sufficient content without some degree of intervention from the state. The Danish model has been one of relatively limited regulation of the private commercial media in terms of content and ownership. However, it has stricter rules on advertising and product placement if compared to the UK, for example. Overall, the system provides an outcome of media pluralism, while taking into account that ownership does not necessarily reduce pluralism of content, but can be necessary to ensure sufficient turnover in order to have a profitable media sector. Nevertheless, potential risks should be explored.

Regarding freedom of information and freedom of speech, the Danish legal system follows the practice of the European court of Human Rights (see also the report from the Mediadem project []). Denmark does not have a Constitutional Court as such, but its Supreme Court can be considered to have the same functions.

There have been no legal cases (litigation) regarding media pluralism, or regarding limitations on media pluralism. There are no specific laws in Denmark regarding media pluralism, for instance, regarding media concentration, but the issue is covered by the general competition regulation. It is also important to note that the Danish laws on public service radio and television demand diverse programming and that all public service media have editorial freedom. Furthermore, there is a media subsidy system (innovation pool and direct subsidies) for editorial content for the written press online and in print, which is based on a perspective on pluralism. The Danish media system has various boards which function independently of the political system and that work as defined in law and following their statutory obligations. Finally, pluralism of the media and of content is a general principle of the media laws, especially concerning public service and media subsidies.

However, there are three indicators that are assessed as high-risk indicators. For all of them it is important to note, that this is the result of a methodology that is comparative and not finely tuned to the Danish media system in particular. The definition of the indicators and the empirical questions does simply not fit policies in Denmark. Therefore, the risk assessment ‘high’ for the three indicators should not be read as a conclusive empirical analysis, but an issue to be examined further.

Indicator 7 Safeguard for access to airtime on PSM by the various cultural and social groups is one of them as the PSM due to the tradition of editorial independence are not limited by law in any way in terms of choosing who should and should not have access to airtime – outside of elections, where there is an obligation. For instance §10 in the Radio and Television act state that “The overall public service activities shall, via television, radio and the Internet or similar, provide 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. 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. Programming shall cover all genres in the production of art and culture and provide programmes that reflect the diversity of cultural interests in Danish society.” ( This is also reflected in the public service contract, valid until end of 2014 (own translation): “DR in its supply of public service must pursue quality, versatility and diversity. When scheduling, the emphasis must firmly be on the need for freedom of information and freedom of speech. For information, emphasis must be placed on objectivity and impartiality.” ( The condition that various cultural and social groups do not have access to airtime per definition should not be necessarily considered a risk indicator. Note that various cultural and social groups are not excluded, but they do not have a right to access airtime directly, nor a right for having their own content distributed on the PSM. Nevertheless, there are provisions for services for different social groups.

Another indicator that demonstrates high risk is indicator 9 Regulatory safeguards and policies for regional and local media. Here, the variables must be considered too unspecific for the Danish case, especially variables 3 on media regulation that prohibit networking arrangements between regional/local media and national media and variable 4 on must carry rules). As such, there are regulatory safeguards and policies for regional and local media in Denmark which include the presence of minorities in community radio and television stations, but the way the indicator are defined makes the risk factor high contrary to actual policy.

The last legal indicator scoring high risk is 14 Regulatory safeguards for transparency of ownership and/or control. In Denmark, there are no separate rules on transparency for media companies. Instead they follow the general rules as stated in the Financial Statements Act ( Private limited and co-operative companies have to state all owners with more than 5 % ownership. All ownership above 20 % of the shares has to be stated in the annual accounts. The fact that media companies follow the general rules does not mean that there is no transparency or that information is not available. Firstly, everyone can access the annual accounts of media companies, although there is a fee at the company register (, and most companies have the accounts on their website. Furthermore, in terms of ownership of media companies, the Danish Agency for Culture from 2014 publishes a report, including information about the ownership of the main media companies. It is also made publicly available. Additionally, there is an ownership register on its way and it should be ready in early 2015.


Economic Type of Indicators Assessing Risks to Media Pluralism

Denmark is a dual media system with strong public service media. The general competition is an oligopoly in radio, television and print. The online environment is also heavily influenced by competition from the legacy platforms, but remains a bit more diverse, albeit dominated by Google and Facebook. Domestically, the strong public service media (DR, TV 2) dominate the market for radio and television, closely followed by their private commercial competitors SBS Discovery Media (radio and television) and MTG (television). The print/news publisher JP/Politikens Hus and Berlingske Media dominate the national news print market (and also have strong hyperlocal weeklies), but there are strong regional competitors for local news. In recent years there have been a set of mergers and acquisitions within commercial media. Furthermore, the existing media have particularly increased the number of television channels and digital offers (i.e., apps, streaming services, and so on).

The public service media system consists of DR (with the following television channels DR1, DR2, DR3, DRK, Ramasjang and DR Ultra, as well as the following radio channels P1, P2, P3, P4, P5, P6 BEAT, P7 MIX, P8 JAZZ, DR RAMASJANG/ULTRA), TV2/Denmark A/S (the public service channel TV 2, TV 2 Zulu, TV 2 Charlie, TV 2 NEWS, TV 2 Fri and TV 2 FILM), eight regional television stations and 24syv, a privately owned public service radio channel.

The principal commercial television stations are SBS Discovery Media (with the television channels Kanal 4, Kanal 5, 6’eren, ID, EUROSPORT 1, EUROSPORT 2, Discovery Channel, Discovery World, Discovery Science, Discovery HD Showcase, TLC, Animal Planet, Animal Planet HD, as well as the following radio channels NOVA, Radio 100, The Voice, myROCK, Radio Soft, as well as a 40 % share in Pop FM) and MTG TV A/S (TV3, TV3+, TV3 PULS, TV3 Sport 1, TV3 Sport 2, MTV og VH1). Note that the private commercial television companies are all registered in the UK, using the country of origin principle in the AVMS directive. Nonetheless, they still purchase Danish productions and thus help to sustain the funding ecosystem for audiovisual productions.

The television market has seen an increase in channels in recent years in both public and private media, through the establishment of numerous new channels. The public service media, while having suffered a loss in their main channels, have managed to diversify their product to more specifically target groups like small children (DR Ramasjang), and children who are a little older (DR Ultra), but also through a specifically cultural channel (DR K). The private media have done something similar, by targeting their channels to specific groups.

The principal print media companies are the duopoly of JP/Politikens Hus and Berlingske Media on the national level, and an oligopoly of media on the local/regional level, with Nordjyske Medier, Sjællandske Medier and Jyske Fynske medier (a current merger between the regional news publishers Fynske medier, Jyske Medier and Syddanske Medier). In recent years there has been a significant increase in online advertising, while print advertising has dwindled. This has left the print press in a dilemma where their turnover from advertising in the print editions has decreased, while that for the digital services has not – yet – to the same degree overtaken the reduction in turnover. Nonetheless, the main revenue for news publishers – for now – still comes from the print editions. The media system is in hasty development, but the development in media use remains evolutionary, rather than being related to a revolutionary introduction and take-up of digital services.

The overall conclusion of the economic indicators is that the risk is generally high. 2 of 6 economic indicators score low risk (indicators 24 Availability and quality of broadband and 26 Centralisation of the national media system), 1 scores medium risk (indicator 25 Minority and community media) and 3 – high risk (indicators 21 Media ownership concentration, 22 Media audience and readership concentration and 23 Number of sectors in which top 8 firms/owners are active).

This result can be explained by two factors: 1) Denmark is a small media market, and 2) the Danish state is a large domestic media owner, owning the two large broadcasting companies as well as 8 regional public service broadcasters (based on license fee funding), with one regional television channel each and regional windows on the largest television channel TV 2, if measured by audience. In regard to the relatively small size of the Danish media market, this is the case for most media commodities and is especially the case for news media and the production of domestic audiovisual content, for instance, high quality drama and content for children. As the population is just above 5.6 million, there is a limited number of consumers to pay for media content. In order to secure pluralism of media content, there is a tradition of broad political support for the existence of strong public service media and some degree of subsidy for editorial content in printed and online news media (a new scheme was implemented on 1st January, 2014) as well as subsidies for community radio and television.

Nevertheless, these indicators should also be examined in combination with other indicators in order to see if the risk to external media pluralism is compensated by the presence of well-safeguarded internal pluralism, which is, in principle, typical of PSM. Regarding the fact that the Danish state is a very large domestic media owner, it is important to stress that the state does not attempt to influence the media or the media content. On the contrary, there is a strong political commitment to the arm’s length principle. The remit defining the role and obligations of the public service media is set in media agreements (usually for a four year period), often such agreements represent most parties, meaning that even after an election the agreement continues to hold.

Furthermore, in regard to ownership concentration, the basis of the oligopoly should be included. In general, oligopolies are the trend, especially in the television and newspaper markets in small countries, although there are exceptions.

Due to the new media environment, with increased competition for advertising from companies like Google and Facebook, but also with increased news provisioning online, which has reduced circulation and subscription revenue, there has been a period of consolidation, especially for printed news companies (especially regional news providers) but also for national radio.

In regard to the economic indicators, we would like to note that the questions regarding minorities seems more suited to a particular media system other than a democratic-corporatist media system. Minorities do have community radio- and television stations, which can receive funding from the State. A new system for community television is being implemented this year (2014), which aims to increase quality and to secure a local connection. The result is a reduced number of local community channels, but with increased airtime and higher subsidy per channel. State advertising is based on clear criteria, and there is no indication of favouritism. The same is the case for advertising from the municipalities.


Socio-political Type of Indicators Assessing Risks to Media Pluralism

The overall conclusion of the socio-political indicators is that they pose a low-medium risk, except for indicator 29 Representation of political views in the media, where the result is a high risk. Other indicators score the following level of risk: 5 of 8 assess a low risk (indicators 27, 30, 31, 32 and 33) and 2 indicators score medium risk (indicators 28 Guarantees for universal coverage of PSM and broadband networks regarding geographic coverage and 34 Independence and ownership of news agencies).

The high risk scoring of indicator 29 however can be attributed to the limited scope of the content analysis conducted as part of the MPM. Additionally, there is a challenge in the sampled and analysed media formats. Neither of the two Danish broadcasters show political talk shows, which is a genre more common in, for instance, the UK and the south of Europe. In Denmark, there are political interviews in relation to general newscasts, and there are soft talk shows where politicians are interviewed on current affairs, but no political talk shows as such. A bigger sample and a more qualitative approach could uncover a different scoring for this indicator of political bias.

In relation to the medium risk scoring of indicator 34 Independence and ownership of news agencies, it is important to note that the largest Danish news agency is owned by the media (or, more precisely, by most of the Danish media, both electronic and print) as this explains the high degree of ownership concentration.