Judgment No. CCZ 9/2016 40 Const. Application No. CCZ 316/2012 abandoned the funding model of a licence fee based on ownership of television and radio sets did so, not for the reason that the model of funding violated the fundamental right to freedom of expression. Germany did so upon the realization that reliance on ownership of television and radio sets limited the source of funding for the public broadcasters as people now used other appliances to watch and record television programmes. The other reason for abandoning the funding model based on ownership of television and radio sets, was that the costs of enforcement of the law against evaders who had increased in numbers, was too high. The law governing public broadcasting service in Germany, now requires every household to pay a fixed licence fee annually, regardless of whether the household owns an appliance capable of receiving broadcasting service or not. The example of the funding method adopted by Germany shows that, whatever model is adopted for funding public broadcasting service, it must ensure that the funding is protected against arbitrary governmental interference. Institutional and editorial independence of a public broadcaster such as the ZBC is not likely to be effectively guaranteed if government can exert pressure on its programming through control of the financial resources. The example of the model of funding adopted by Germany helps to show that public financial support is a sine qua non of a public broadcasting service system. There is a close link between the funding model adopted and the type of broadcasting service to be supported. It is often argued that the mechanism of funding adopted by the State is critical in determining the nature of a broadcasting institution with fears that

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