Code 9 – Sponsorship

This Code is from the Community Radio Broadcasting Codes of Practice (2025) and goes into effect on 1 July 2025. For information about the current Codes of Practice visit https://www.cbaa.org.au/community-broadcasting/codes-of-practice-current.

CODE

9.1 Our editorial decisions about the content and style of news and journalistic content, individual programs and overall programming must not be influenced by sponsors and we will avoid or adequately disclose any conflict of interest.

9.2 Sponsorship will not be a factor in deciding who can access broadcasting time.

9.3. Code 4 also applies to sponsorship announcements.

Learn more about Code 9: Sponsorship at CBAA Learning.

OTHER LEGISLATIVE MATTERS

We must broadcast no more than 5 minutes of sponsorship announcements in any one hour.
We must tag each sponsorship announcement to acknowledge the financial or in-kind support of the sponsor.
We broadcast no advertisements. Accidental or incidental broadcasting of material that has an advertising character is permitted if it is not paid for in cash or in-kind.
Community information material or community promotional material is not taken to be the broadcasting of an advertisement.

GUIDANCE NOTE FOR CODE 9.1

General guidance

Sponsorship funding is an important part of many station operations but needs to be managed so the station maintains its integrity and independence. Code 9 ensures that station programming is free from influence from financial supporters and that sponsorship content is suitable for broadcast See also the ACMA’s Community broadcasting sponsorship guidelines.)

How to apply Code 9.1

Code 9.1 requires stations to:

ensure editorial and programming decisions are not influenced by sponsorship; and

avoid or adequately disclose conflicts of interest.

Decisions not based on sponsorship

Station sponsors are not allowed to influence the content and style of news and journalistic content, individual programs and overall programming. A station must reject any attempt by a sponsor to demand that news or other content be covered in particular way in return for their financial support. A station should not, for example, create a music program specifically so that a sponsor can promote themselves around it. For example, a music store sponsoring a music program would be acceptable, or a music venue sponsoring a live music program would be acceptable, but it would not be acceptable for the sponsor to suggest the program.

Managing conflicts of Interest

Conflicts of interest occur when a presenter, member of station management, the board or committee or other decision maker has an interest in or relationship to a sponsor which may (or may be perceived to) affect decisions about that sponsor or about on-air content.

A potential conflict of interest doesn’t mean the station has to reject the sponsorship proposal, but it must manage the conflict of interest appropriately and transparently. Examples of conflicts of interest include:

financial interest in whether a sponsorship proposal is accepted or rejected;

familial or close personal relationship with someone who has a financial interest in a sponsorship proposal; and/or

relationship with a current or potential station sponsor that influences (or could be seen to influence) programming or airtime decisions, whether positive or negative.

In each of these cases, the person with the conflict of interest must declare it, and document on, the station’s Conflict of Interest Register. Station management should ensure that the person with the conflict abstains from discussions and voting around the sponsorship.

The station must be able to demonstrate that decisions were made in the best interests of the station, given the information available, and this can be done by:

having an up-to-date conflict of interest policy such as the Australian Charities and Not-for-profits commission template;

maintaining an up-to-date conflict of interest register available for inspection on reasonable request (in line with station policy); and

detailing in Board or Committee meeting minutes if anyone abstained on a resolution and what else was done to manage the conflict.

On-air conflict of interests

Potential conflicts can arise when on-air presenters look to interview station sponsors or others with whom they have a personal or financial relationship.

It can be appropriate to invite station sponsors who are knowledgeable on a topic to talk about it in an on-air interview if there is no advertising or promoting of a product, service or event offered by the sponsor, but their business interest in the topic should be disclosed to listeners.

This applies whether the interview guest has a sponsorship package with the station, or not, but stations should take special care as an interview is more likely to risk breaching the Code (and possibly a licence condition) if a sponsorship agreement is in place.

If a station volunteer has a personal relationship or financial or other connection with the guest (e.g as an employee), the volunteer must declare this relationship on-air.

GUIDANCE NOTE FOR CODE 9.2

General guidance

Sponsorship funding is an important part of many station operations but needs to be managed so the station maintains its integrity and independence. Code 9 ensures that station programming is free from influence from financial supporters and that sponsorship content is suitable for broadcast. See also the ACMA’s Community broadcasting sponsorship guidelines.

How to apply Code 9.2

Code 9.2 obliges stations to make sure that decisions about who can access broadcasting time take into account the needs of audiences not the wishes of sponsors. This helps build audience trust that the station will not put commercial decisions ahead of its community.

Sponsors of a station must not have a say in what goes to air. The station cannot make programming decisions which prioritise the preferences of their sponsors over the needs of their listeners. Sponsors are also not permitted to influence the access that community members have to airtime or broadcast facilities. For example, a music venue sponsor cannot set conditions in their sponsorship agreement preventing a competitor from being interviewed about music.

The station must have suitable controls in place to ensure that all programming decisions are made in the best interests of listeners, members and the community of interest, without regard for the preference of sponsors. This could be done, for example, by establishing a programming sub-committee and having well-documented decisions.

Under this Code, a station must reject the following:

A sponsor’s requests that a presenter be dismissed or a program moved to another timeslot due to the sponsor’s opinion of the program.

A sponsor expectation to be interviewed on a topic aligned with their business without an invitation from the station or makes an interview a condition of the sponsorship.

A third party pays a station to play a program with embedded sponsorship announcements where the content would not be of interest to the station if it was not paid for the broadcast.

GUIDANCE NOTE FOR CODE 9.3

Code 9 generally

Sponsorship funding is an important part of many station operations but needs to be managed so the station maintains its integrity and independence. Code 9 ensures that station programming is free from influence from financial supporters and that sponsorship content is suitable for broadcast. See also the ACMA’s Community broadcasting sponsorship guidelines.

Code 9.3

Code 4: Material Not Suitable for Broadcast, contains restrictions on content that doesn’t meet community expectations due to its potential harm or unreasonable offence to listeners, or because it is against the law (e.g., promoting tobacco).

Code 9.3 requires stations to apply the same standards to sponsorship announcements. Community broadcasters, including their management and boards, are responsible for all material broadcast by the station, whether the sponsorship content is created by the station or produced externally (including where airtime has been sold or outsourced to external content creators).

It is important to have systems in place to ensure all sponsorships that go to air have been vetted against Code 4. For example:

A sponsor provides the station with the text of a proposed announcement containing material that uses racist or sexist stereotypes. The station will need to work with the sponsor to change the wording so that it complies with Code 4.1(h).

A sponsor asks for a gambling ad to be run immediately before sporting commentary. The station can’t accept this because it will be in breach of Code 4.1(d), but it can run the sponsorship announcement at another time if it otherwise complies with Codes 4.1(c) and (d).

For more details on how to work out what’s not suitable under Code 4, see the Guidance Materials for Code 4.