During the last decade of the twentieth century, discussions in Europe focused on how to guarantee pluralism in the traditional media (press, radio and television). As a result, four different systems to safeguard and promote pluralism in the media sector can now be identified in Europe:

1 through subsidies, programme prescriptions, quality requirements, frequency distribution, maintenance of public broadcasting systems, etc.;

2 restrictions on media ownership and control; 3 restrictions on audience reach (in the UK: ‘share of voice’), i.e. the audience share

which a single owner or controller of media outlets is allowed to control with all its media outlets in a relevant audience market;

4 restrictions linked to the control by media undertakings over essential resources (such as financial means or infrastructure).1