polling centres, advertising agencies and even translation businesses and research centres. All of these bodies need to obtain licences from the government to operate (see, for example, Articles 12 and 15) and are subjected to various other rules. This is unnecessary and engages, in addition to the right to freedom of expression, the right to freedom of association. In addition to issues relating to the role of the government (on which see below under Independent Regulation), there is simply no need to subject all of these types of activities to special licensing or even registration regimes. While international law does accept some limited forms of registration in relation to the traditional print media, even that is subject to strict conditions and, where it is extended to so many different types of entities, cannot pass muster as a restriction on freedom of expression and freedom of association. Recommendation: Ø The scope of the Law in terms of the number of different types of entities it subjects to regulatory measures should be reviewed and this should be limited to entities in relation to which such regulation can be justified as a restriction on freedom of expression and freedom of association by virtue of the clear benefits it creates. 2. Independent Regulation The need for bodies which exercise regulatory powers over the media to be independent of the government is well-rooted in both international standards and the practice of democratic States. The reason for this is clear: if the government controls regulatory actions, there will inevitably be a bias, or at the very least a risk of bias, towards regulatory decisions which favour the government rather than the wider public interest. This clearly undermines respect for freedom of expression. Numerous authoritative international statements have been made along these lines. Many of these statements focus on broadcast or telecommunications regulators, because most democracies do not have official bodies that regulate the print media or journalists. The 2003 Joint Declaration of the special international mandates on freedom of expression includes the following, broad statement about independence: All public authorities which exercise formal regulatory powers over the media should be protected against interference, particularly of a political or economic nature, including by an Jordan: Analysis of the Press and Publications Law, 1998, as Amended - 6

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