The organisational and operational model – understood here as the organisation of the administration of the news media subsidy system – constitutes an initial and relevant dimension in assessing institutional distance from executive and legislative authorities. It represents one of the most visible manifestations of the arm’s length principle: Without institutional independence in the day-to-day administration of either the system itself or the decision-making body, policy outcomes risk being perceived as instances of cronyism or political patronage.
This also explains why this dimension is given comparatively extensive attention, as well as the inclusion of some historical retrospectives and accounts of the design of the subsidy schemes. However, already at a glance, it is clear that operational models vary with respect to this dimension across the Nordic countries.
3.1.1 A competence-based board in Denmark
In the Danish context, much of the framework for media policy is normally established through political media agreements negotiated between the government and one or more parties in the Danish Parliament. In short, a majority of the members of parliament must support the agreement. The current media policy agreement, presented in June 2023, covers the period 2023–2026 (Kulturministeriet, 2023).
The existing subsidy scheme was introduced in 2014, replacing an earlier distribution subsidy for printed newspapers. The subsidy scheme was amended in 2024 to facilitate a greater redistribution of support towards local and regional news media. In addition, content consisting of audio and audiovisual services can now qualify for support to a greater extent. Prior to this reform, all schemes within the media subsidy framework had been directed at traditional news media; from 2024 onwards, however, the editorial production subsidy may also be granted to two additional categories of media: magazines and weekly freesheets (ugeaviser). Most of the funding nevertheless remains within the principal editorial production scheme (Nordicom, 2026: 58–59).
The acts regulating these subsidies in force are the Act on Media Subsidies (Lov nr. 1604 af 26/12/2013) and the associated Ordinance (BEK nr. 127 af 05/02/2024). Under this legislative framework, the relevant support schemes are administered by a Media Board (Medienævnet). The Board consists of seven members, one of whom serves as chair. All members are formally appointed by the Minister for Culture, although one member is nominated by the industry association Danish Media and another by the Danish Union of Journalists. The chair is required to hold legal qualifications. All appointments are made for four-year terms. Collectively, the Board is expected to possess expertise in areas such as news production, media markets, the democratic role of the media, and related fields (Kammer & Blach-Ørsten, 2025: 11).
Although the emphasis is clearly placed on competence-based requirements, neither the Act nor the Ordinance contains explicit provisions that would preclude individuals with political affiliations from serving as members of the Board (Lov nr. 1604 af 26/12/2013). These possibilities are, nevertheless, constrained by the Public Administration Act’s rules on disqualification. These rules specify the circumstances under which a person is disqualified from participating in the processing or decision-making of an administrative case, including situations involving personal or financial interests or other factors likely to give rise to doubts about impartiality (LBK nr. 433 af 22/04/2014).
In addition to appointing the Board’s members, the Minister for Culture is also responsible for shaping its rules of procedure, which set out how the body conducts its work and makes decisions. Administrative support for the Board is in turn provided by the Danish Agency for Culture and Palaces (Lov nr. 1604 af 26/12/2013; BEK nr. 127 af 05/02/2024). The Agency is a government authority under the Ministry of Culture and contributes to the implementation of the government’s cultural policy objectives.
In the autumn of 2025, a government-appointed committee presented a proposal for a modernised media subsidy system. In brief, the proposal advocated coordinating the existing support schemes into a single unified system. However, it contained no new recommendations concerning the administration or organisation of the support system itself (Udvalg om fremtidens mediestøtte, 2025: 10).
3.1.2 Two separate subsidy systems in Finland
Unlike its neighbouring Scandinavian countries, Finland does not currently operate a comprehensive system of media subsidies. The former Finnish press subsidy scheme was largely dismantled over a period of approximately two decades from the early 1990s onwards. The process was driven by deregulation pressures from the Finnish Ministry of Finance and the European Commission, combined with a progressively constrained fiscal environment. The subsidy previously directed at smaller party-affiliated newspapers, which was formally abolished in 2008 (2007 was the last year the subsidy was in use), was instead incorporated into the general system of party funding as support for political parties’ information activities (Ds 2022:14, 2022: 128). The fact that Finland practically abandoned direct press subsidies and the traditional dual Nordic subsidy model (i.e., with both indirect and direct subsidies) in the 1990s has made it somewhat of an outlier in the context of the Nordic media welfare states (Grönlund et al., 2024).
At the beginning of 2026, two targeted and selective subsidy schemes were in place: a temporary distribution subsidy for printed newspapers, the larger of the two, and a smaller scheme aimed at supporting news media published in Finland’s minority languages.
The former scheme is intended for distribution companies that commit to delivering printed news media in sparsely populated areas of the country. It was introduced in response to amendments to the Postal Act that reduced postal delivery from five to three days per week. Accordingly, in 2022, the government proposed a new, time-limited state aid measure to ensure five-day newspaper delivery until 31 December 2027.
The distribution subsidy is administered by the Finnish Transport and Communications Agency (Traficom), which is also responsible for decisions on the allocation of support. No dedicated advisory or decision-making committee has been established within or outside the agency for this purpose. The scheme is instead managed within Traficom’s ordinary organisational structure in accordance with the Government Decree on Temporary State Aid for Newspaper Distribution (FFS 820/2023). Traficom operates under the Ministry of Transport and Communications.
The latter scheme, regulated by the Government Decree on Support for Newspapers (FFS 389/2008), is intended to support newspapers and online publications published in Karelian, Romani, Sámi, and Swedish, as well as publications in sign language. It also covers the production and publication of Karelian- or Sámi-language content in connection with newspapers published in Finnish or Swedish, in addition to Swedish-language news services.
The subsidy scheme is administered by the Ministry of Education and Culture (OKM). Preparatory work is carried out within the ministry by civil servants in the Ministry’s department for cultural and arts policy, while the formal decisions are taken by the Finnish government at its plenary session (FFS 389/2008).
The fact that the scheme falls under the Ministry of Education and Culture – a ministry responsible for matters relating to the national languages, minority languages, and cultural and language policy – indicates that the support is primarily conceived as a language- and culture-policy instrument rather than as part of a broader news media market support framework. This institutional positioning also largely explains why this form of support is administered separately from other media-related subsidies and why the associated decision-making processes differ.
3.1.3 Iceland, a newcomer to direct subsidies
As already noted, Iceland’s media system stands out in several respects in a Nordic comparison. Until recently, the state has been far less active in the Icelandic media market than in the other Nordic countries, and practices characteristic of the Nordic media welfare state model have, for all practical purposes, been absent. Consequently, private media in Iceland have been among the less regulated in Europe. One indication of this distinctive position within the Nordic context is that direct media subsidies – albeit temporary – were first introduced only in the early 2020s, with the aim of strengthening Icelandic media and ensuring public access to news and information in a digital and platform-dominated media environment. Prior to 2020, Iceland had no system of direct media subsidies (Guðmundsson & Jóhannsdóttir, 2024: 156–157).
Iceland’s temporary media subsidy scheme for private news media, both local and national, was extended to remain in force throughout 2025. The statutory basis for this temporary regime expired on 1 January 2026 (Lög um breytingu á lögum um fjölmiðla, nr. 38/2011 [stuðningur við einkarekna fjölmiðla]). Although a more permanent scheme has been announced, it had not yet entered into force at the time of writing (Icelandic Review, 2025; ESA, 2025). Iceland therefore constitutes a methodological exception to the report’s general early-2026 cut-off and is analysed based on the most recently applicable framework, namely the 2025 temporary regime.
Under that framework, Iceland established a three-member Allocation Committee (Úthlutunarnefnd) to be responsible for granting support to privately owned media. The members are formally appointed by the Minister of Culture, Innovation and Higher Education: one nominated by the Supreme Court of Iceland, one by a university collaboration committee, and one by the Icelandic National Audit Office. This last nominee must be an authorised public accountant. Alternate members are appointed in the same manner.
The Minister appoints the chair from among the members of the Committee. The chair must in turn meet the qualifications required for appointment as a district court judge. The other members and their alternates are required to possess specialist knowledge of media matters, as well as relevant professional experience and education (Lög um breytingu á lögum um fjölmiðla, nr. 38/2011 [stuðningur við einkarekna fjölmiðla]).
There is no provision in the media subsidy legislation explicitly stating that individuals with political affiliations may not serve on the Committee. However, as in Denmark, such possibilities are constrained by the rules on disqualification and requirements of impartiality set out in the Administrative Procedure Act (Stjórnsýslulög nr. 37/1993).
3.1.4 Administrative decision-making in Norway
Norway was the first of the Nordic countries to introduce direct subsidies for newspapers, doing so as early as 1969 (Bjerke & Halvorsen, 2023: 39). Over time, the principal subsidy scheme has been expanded to encompass both print and online news and current affairs media. As in Denmark, the production subsidy for news and current affairs media constitutes Norway’s largest form of direct media support. This scheme, together with the innovation and development grants, support for local broadcasting, and the subsidy for Sámi newspapers, is administered by the Norwegian Media Authority (Medietilsynet). The Media Authority operates under the auspices of the Ministry of Culture and Equality.
Until 2023, the Media Authority was supported in the preparation of decisions on production subsidies by a dedicated advisory committee (Tilskuddsutvalget), consisting of five members and an equal number of deputy members. All members were appointed by the Ministry for four-year terms. The committee’s primary task was to assess new applications for production subsidies and to submit recommendations for decision-making (Medietilsynet, 2021: 164).
Following this administrative change, decisions in this area are now made solely by the Media Authority. An advisory support structure nevertheless remains in place for innovation and development subsidies and subsidies for local audio and audiovisual news media. In this context, funding decisions are formally adopted by the Media Authority based on recommendations from specialist advisory committees, which are appointed by the Authority.
The Advisory Committee (Fagutvalget) for innovation and development subsidies comprises a chair, four members, and three deputy members, all appointed for terms of up to three years. Collectively, the members are required to possess broad and complementary expertise, including competence in media and media economics, innovation, technical and digital development, and local media. In the event of a tie, the chair holds a casting vote (FOR-2018-06-26-1033). The committee for local audio and audiovisual news media is organised in a broadly similar manner and performs comparable functions (FOR-2016-02-19-166).
Beyond the mentioned formal arrangements, the composition of these committees is further shaped by wider administrative norms. Accordingly, although the relevant regulatory framework does not explicitly prohibit political representatives from serving as members, Norwegian administrative practice – comparable to that in Denmark – together with the rules on disqualification, imposes constraints on such appointments (LOV-1967-02-10).
In this context, it should be noted that discussions have been held in Norway with regard to establishing a media subsidy council (mediestøtteråd). According to a proposal put forward by the Norwegian government in the late 2010s, the proposed subsidy council would determine the allocation of media support between different platforms and categories of publishers, while the industry itself would not be represented. The proposed body was envisaged as strengthening the principle of arm’s length distance, deciding the allocation of funds between support schemes, and formulating the regulatory framework governing them. The council was, among other things, intended to “counteract suspicions that political interests improperly influence the distribution of media subsidy” (Meld. St. 17, 2018/19, 2018–2019: 60; author’s translation). The proposal met with criticism, not least from significant sections of the media industry, and was never implemented (Bjerke & Halvorsen, 2023: 224–226).
In November 2025, the Norwegian Media Authority published a review assessing potential modernisation of the existing media subsidy system. The review did not propose changes to the organisational structure of the support scheme, focusing instead on specific issues concerning selected subsidy categories and target audiences. The review aims to provide a foundation for the development of the four-year policy framework governing direct media support for the period 2027–2030 (Medietilsynet, 2025: 2).
3.1.5 No politicians in Sweden’s reformed subsidy council
In Sweden, direct press subsidies were introduced in 1971 with the aim of supporting newspapers in vulnerable market positions. With only limited modifications, this system remained largely intact for several decades. The core component of the former system, the operational subsidy, primarily targeted printed newspapers and so-called secondary newspapers, the smaller title in a local market (Ds 2022:14, 2022: 111–113).
In 2023, the Swedish media subsidy system underwent a comprehensive reform, and the restructured scheme was implemented for the first time in 2024. The current news media subsidy framework comprises four forms of support: a general editorial subsidy, an extended editorial subsidy, a transitional subsidy for newspapers that received operational support in 2023, and a newspaper distribution subsidy. The new system is platform-neutral and may be granted to general news media irrespective of distribution technology. It places a clear emphasis on local news provision and on areas with limited media coverage (Nordicom, 2026: 62).
Decisions on the allocation of subsidies are taken by the Media Subsidy Council (Mediestödsnämnden), a separate decision-making body operating within the Swedish Agency for the Media (Mediemyndigheten). The Agency is an independent administrative authority operating under the Ministry of Culture.
The Media Subsidy Council consists of a chair and between four and seven additional members. A corresponding number of deputy members is appointed, as determined by the government, which also formally appoints all individual members of the Council. At least one member or deputy member serves as vice-chair. Both the chair and the vice-chair are required to be, or to have previously served as, judges.
Individuals who are members of parliament, government ministers, or employees of the Parliamentary Administration or the Government Offices are ineligible to serve on the Council. The same restriction applies to individuals holding full-time or substantial part-time elected offices at the municipal or regional level (SFS 2023:664).
Under the previous subsidy system, the council included, among others, representatives of political parties. Their participation reflected an established practice whereby the government provided political parties with the opportunity to nominate members. That said, this took place at a time when the structure of the support scheme meant that allocation decisions were predominantly, though not invariably, formal (Ds 2022:14, 2022: 189).
3.1.6 Comparison of dimension one
Direct and selective news media subsidies are administered and organised differently across the Nordic countries (see Table 3.1). One key difference concerns institutional responsibility: In Finland, responsibility for direct subsidies is divided between two organisations, whereas in the other Nordic countries the schemes are administered by a single body. Nonetheless, one of the Finnish subsidies is primarily regarded as a language and cultural support rather than as a form of media subsidy.