It is clear under international law that restrictions on who may practise journalism, unlike licensing schemes for other professions, are not legitimate. As the UN Human Rights Committee stated in its 2011 General Comment No. 34: Journalism is a function shared by a wide range of actors, including professional full-time reporters and analysts, as well as bloggers and others who engage in forms of self-publication in print, on the internet or elsewhere, and general State systems of registration or licensing of journalists are incompatible with paragraph 3 [of Article 19 o the ICCPR].22 Similarly, the special international mandates on freedom of expression stated in their 2003 Joint Declaration: Individual journalists should not be required to be licensed or to register. There should be no legal restrictions on who may practise journalism.23 The Media Commission’s proposals for amending the Law would also do away with mandatory membership in the JPA for periodicals and foreign media. Article 9 of the Law places stringent conditions on who may work as a correspondent for foreign news media, namely to the effect that they should be approved by the Council of the JPA, with the agreement of the Minister, and that regulations should be adopted to govern this issue. This is simply not legitimate and neither the JPA nor the Minister should play any role in deciding who may work for foreign news media outlets. A number of provisions in the Law place conditions on the holders of certain positions at either publications or Article 15(a) entities, as follows: • Article 16: Article 15(a) entities must have a responsible director who is a Jordanian, who is permanently resident in Jordan, who has not been convicted of “violating honour or morality”, and who has “academic qualifications, expertise, and experience that are appropriate for the work”, in accordance with instructions issued for this purpose by the Minister. • Article 21: Owners of publications must be Jordanians, Jordanian companies or Jordanian political parties, and not have been convicted of “violating honour or morality”. • Article 23: Press publications must have a sole responsible editor-in-chief who is a journalist who has been a member of the JPA for at least four years (this does not apply to political party newspapers), who is a Jordanian who is normally resident in 22 Note 8, para. 44. 23 Note 18. See also the seminal case on this issue decided by the Inter-American Court of Human Rights, Compulsory Membership in an Association Prescribed by Law for the Practice of Journalism, Advisory Opinion OC5/85 of 13 November 1985, Series A, No. 5. Available at: http://www.corteidh.or.cr/docs/opiniones/seriea_05_ing.pdf. Jordan: Analysis of the Press and Publications Law, 1998, as Amended - 14