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Transparency of State Advertising in the proposal for a European Media Freedom Act (EMFA)


In recent years, state advertising of media has been a popular way of ensuring support for media service providers, who are dealing with the outflow of investors to digital platforms and the consequences of the COVID-19 pandemic. However, the public has limited options to find out which media receive these funds and what are the amounts allocated. 22 out of 27 countries in the European Union do not have legislation that contains transparent rules on the allocation of state advertising to media.

Transparency of the State, including its allocation of resources, enables civil society and media to act as watchdogs of the government and its operations. While we welcome the European Media Freedom Act (EMFA) proposal, more transparency is needed for the proposal to be truly effective and for the watchdogs to be able to fulfil their much-needed role.

Therefore, we recommend:

  • Removing the ‘1 million inhabitants’ threshold for state advertising transparency;
  • Establishing an EU-wide database of state advertising provided to media service providers;
  • Determining regular mandatory reporting obligations applicable to state advertising;
  • Ensuring public authorities publicly disclose information regarding exchange of goods or services other than state advertising with media service providers;
  • Shortening the frequency with which public authorities must publish data on resources allocated to media service providers to at least once in three months;
  • Including the obligation for public authorities to make data available in an electronic and user friendly manner;
  • Including a list of concrete procedures and safeguards for awarding media service providers with state advertising;
  • Introduce monitoring of state advertising and state aid allocation; and
  • Including emergency messages in the definition of state advertising.