AER views on the consultation on the new European Democracy Action Plan

Commercial radio provides significant social and public value. Radio reaches large audiences for long periods of time with a mix of music, news, entertainment and talks; an input that is highly-valued by audiences with radio found to be the most trusted medium in Europe. Given its influential role toward public opinion, radio is tightly regulated at national level thanks to a framework implemented by State-independent regulators. Commercial radio’s independence is crucial and must be supported. It depends on one side on media freedom and freedom of expression but also on its competitiveness. The latest should not be undermined by large public service broadcasters or tech giants that are becoming increasingly dominant in advertising and content distribution.

AER welcomes the Commission’s European Democracy Action Plan in its aim “to tackle some of the key challenges for the European democracy” including “external interference and manipulation in elections, media freedom and pluralism and the fight against disinformation”. We call on the Commission to support radio’s independence and consider its significant role in safeguarding media freedom and pluralism.



Radio is not only the most trusted medium in Europe (according to the EC Eurobarometer survey), it is also extremely popular: 85% of Europeans listen to radio at least once a week, the average daily usage is 2 hours 22 minutes. Radio programmes are generally local, regional or national.

Radio complies with strict local rules and journalistic standards. Thanks to its journalists, radio contributes to safeguarding democracy by reporting reliable news, therefore protecting their listeners from harmful content and combating disinformation.

Because most radio content is produced for linear broadcast, listeners are offered journalistic content they were not expecting nor looking for previously. Radio’s content provision to listeners does not depend on previous listening or browsing history, so it is impervious to filter bubbles.

In case of natural or manmade disasters, listeners rely on radio as a most immediate and most trusted source of information, which is available on broadcast platforms even if other networks (e.g. mobile networks) have collapsed or become unreliable.  

Radio is tightly regulated at national level and overseen by independent regulators, but free of state control or interference. In contrast, large online platforms evolve in an environment that is largely unchecked and unregulated.

Commercial radio relies almost entirely on advertising to fund its content, operations and news output. This business model has become increasingly challenged in recent years with a significant shift in advertising spend to large online platforms. Alongside these changes, serious questions have been raised regarding the accountability, transparency and market power of these platforms, as well as concerns regarding the spread of inappropriate or illegal content online.

For news content providers such as radio and newspapers, which produce valuable public service content and journalism funded by advertising, this poses fundamental questions regarding the impact of online platforms and aggregators on society. If a growing number of trusted news content businesses become unviable due to the dominance of the online platforms, then this has very serious implications for democracy.


Election integrity and how to ensure electoral systems are free and fair

Political advertising on commercial radio is strictly regulated. According to the Council of Europe, this is reflected by the following:

  • Radio broadcast licence requirements impose impartiality in relation to political issues. This entails that radio stations apply specific regulation that closely consider election and referendum periods;
  • Radio broadcasters are required to restrain from “the publication of opinion poll findings and enforce quiet periods prior to election day”;
  • Political advertising on radio is regulated in relation to its transparency, advertising time and cost, paid political advertising and differs from one radio to another, especially considering the commercial or public nature of the radio. Some European countries, for instance the United Kingdom, impose a blanket ban on political advertising on radio.

In comparison, no regulatory measures are imposed onto online platforms. This observation was also drawn by the 2020 Media Pluralism Monitor Report which laments deprived national regulatory frameworks for political advertising in the online sphere.

In a world where there is an increased access to media content online, a strict regulation of political advertising on radio is out of place if no level-playing-filed is ensured with online platforms.


Strengthening media freedom and media pluralism

Media freedom and pluralism are crucial for European democracy. However, there are currently a number of challenges which can potentially restrict journalistic freedom and reduce pluralism, including digital transformation and the surge of level playing field where new online players have a much bigger role to play but remain highly unchecked and unregulated

The COVID-19 crisis has shown how important broadcasters and the media sector are to counterbalance disinformation spreading exponentially online. Throughout these challenging times, commercial radios have produced quality content and continued to comply with strict ethical and regulatory rules. Radios, with their content of music, news, entertainment and talk, are still today the most widely consumed medium worldwide, as they are accessible to a wide variety of listeners on a local and national level. As content creators and trustworthy news providers, they are unique companions to Europeans who constantly identify radio as the most trusted medium in Europe. They bring added value to both the economy and society, and are key in supporting media pluralism.

Their content is not a content like any other and cannot be treated as a mere commodity. It should rely on a specific protective framework. The framework of the European Democracy Action Plan should reflect the central role played by commercial radios as independent media. Against the background of fragmented information landscapes, they are paramount in the production, dissemination and verification of information and make an essential contribution to political discourse through the broadcast of trustworthy news.

Further initiatives aimed at strengthening media freedom and pluralism are not only welcome but necessary, including the European Commission’s Action Plan for Media and Audiovisual sector. Today, in the context of the COVID-19 crisis and its recovery, such an Action Plan taking into consideration the needs of the sector, further supporting digital transformation and competitiveness of the audio-visual and media sector, as well as stimulating access to quality content and media pluralism, is needed more than ever.


Tackling disinformation

Radio is the one of the best tools against disinformation.

Commercial radio plays a key role in providing trustworthy information to European listeners, by analogue, digital and online means. Due to its nature of a one-to-many medium, radio is impervious to filter bubbles or echo chambers. Commercial radio stood out during the COVID-19 crisis by reaching even more listeners than before and by remaining robust, dedicating more airtime to news updates and helping the local community. In fact, the COVID-19 pandemic has confirmed the systemic issue surrounding the spread of disinformation online, and the life and death impact this can have on users. It also confirmed the importance of radio as trustworthy medium that follows strict journalistic standards.

This demonstrates that the fight against online disinformation cannot be left to self-regulation adopted by online platform alone and that a sensible co-regulatory framework must complement these private efforts.