Luxembourg
[LU] Protection of minors: ALIA issues a reprimand to a provider
IRIS 2026-8:1/13
Amélie Lacourt
European Audiovisual Observatory
On 10 February 2026, the Hungarian National Media and Communications Authority (NMHH) forwarded to the Luxembourg Independent Audiovisual Authority (ALIA) a complaint concerning the programme segment Aranykalitka, broadcast on 29 December 2025 by the television service Sorozatklub, which is provided by CLT-UFA S.A., a company established in Luxembourg.
The programme, broadcast during prime time in the early afternoon, was classified as 12+. The complainant considered that both the broadcast time and the rating were inappropriate, citing in particular a scene depicting an interaction between a mother and her daughter in an atmosphere of fear. In this scene, which depicts a memory, the mother reproaches her daughter and threatens to kill them both if she does not put her corset back on. The mother then forces her daughter to take a cold shower, creating an atmosphere of fear and humiliation. The girl, frightened and traumatised, begs her mother to stop, promising that it will never happen again.
As the Sorozatklub television service is primarily aimed at a Hungarian audience, the provider opted to apply the classification and protection system in force in Hungary, in accordance with Article 8 of the amended Grand-Ducal Regulation of 8 January 2015 on the protection of minors in audiovisual media services. In this case, the programme segment was classified as Category III and broadcast with the warning "Not recommended for audiences under the age of 12".
As this case relates to the areas of the protection of minors and incitement to violence, hatred and terrorism, the ALIA Consultative Assembly was consulted. It noted, in particular, that "according to the information gathered, the Sorozatklub television service does not broadcast unencrypted" and considered that Category III, used for content featuring physical or psychological violence likely to disturb children under the age of 12, appeared appropriate.
For its part, the service provider argued, during a meeting with ALIA, that the disputed scene was presented in the form of a flashback and that the two women were alive in the rest of the story. In its view, the threats made therefore constitute nothing more than an emotional exaggeration with no basis in reality. The mother’s behaviour is portrayed as an excessive and dysfunctional parenting method rather than an act of cruelty. Finally, the provider considers that the legal assessment should focus on the series as a whole and not on an isolated scene, as analysing it in isolation would distort the general meaning of the work and its moral conclusion.
In its decision, the ALIA Council first noted that there was nothing in the case file to establish that the Sorozatklub television service is not broadcast unencrypted. The broadcast time therefore remains a relevant factor. It also noted that "the disputed programme segment goes beyond mere content likely to frighten a young audience" and that "such content, characterised by a situation of family conflict resolved through violence, is likely to be harmful to the physical, mental or moral development of minors under the age of 16 and therefore falls within Category IV […]". Furthermore, “the fact that the sequence is presented in the form of a flashback or that the threats made do not subsequently materialise does not affect the potentially harmful nature of the content at the time of its broadcast”.
ALIA therefore concluded that the provider had manifestly, gravely and seriously contravened the provisions of Section 9(4) and (5) of Hungarian Act No. 185-2010 by failing to classify the programme element as Category IV. The fact that it was broadcast in the early afternoon confirms the inadequacy of the classification. ALIA therefore issued a reprimand against the provider.
References
- Décision DEC17/2024-P003/2026 du 22 juin 2026 du Conseil d’administration de l’Autorité luxembourgeoise indépendante de l’audiovisuel concernant une plainte à l’encontre de la société CLT-UFA S.A.
- https://alia.public.lu/wp-content/uploads/2026/07/D017-2026_P003-2026_Sorozatklub_Aranykalitka_ECsite.AC_.pdf
- Decision DEC17/2024-P003/2026 of 22 June 2026 by the Board of Directors of the Luxembourg Independent Audiovisual Authority concerning a complaint against CLT-UFA S.A.
This article has been published in IRIS Legal Observations of the European Audiovisual Observatory.