Historically, state advertising has played a pivotal role in disseminating critical public interest information to citizens. As a tool for government communication, it has served various functions, from public information campaigns to fostering national identity and crisis management. The EMFA defines it as the placement, promotion, publication or dissemination, in any media service or online platform, of a promotional or self-promotional message or a public announcement or an information campaign, normally in return for payment or for any other consideration, by, for or on behalf of a public authority or entity. While potentially beneficial to support media pluralism, its allocation raises concerns in terms of  political influence, media dependence, and market distortion. One of the central challenges of state advertising is indeed its potential use as a means for indirect government control over the media. According to the Media Pluralism Monitor (2023), half of the European countries score the maximum risk score in the subindicator on the distribution of state advertising. In some countries, in fact, state advertising has been disproportionately directed towards media outlets that exhibit political loyalty, thereby undermining pluralism and distorting market competition. Moreover, a considerable lack of transparency in its allocation further exacerbates concerns of clientelism and non-competitive practices that threaten media outlets not aligned with the political establishment and smaller (especially local and regional) media. Furthermore, digital advertising exacerbates financial vulnerabilities for independent news organizations, as a significant portion of state advertising budgets is now funneled into large online platforms rather than national media outlets.

Article 25 of the European Media Freedom Act seeks to address some of these issues, requiring more transparency, fairness, and accountability in state advertising allocation. According to the article, public funds by public authorities for state advertising shall be awarded in accordance with transparent, objective, proportionate and non-discriminatory criteria, made publicly available in advance by electronic and user-friendly means, and by means of open, proportionate and non-discriminatory procedures. (Art.25 para 1). The provision thus mandates public disclosure of expenditure, including data on beneficiaries and allocation criteria (para 2) and that public authorities shall monitor and report annually on the allocation of state advertising expenditure (para 3). By requiring competitive and non-discriminatory allocation processes, Article 25 seeks to level the playing field for all media actors (see Recital 48). Effective enforcement of the provision will depend on national implementation and monitoring mechanisms, which may vary across EU member states.

This EMFA discussion will feature expert presentations offering thought-provoking perspectives and insights on how to effectively enforce Article 25 EMFA. The presenter is Kati Cseres, University of Amsterdam. Expert commentators are Gábor Polyák,  Eötvös Loránd University, Oliver Money-Kyrle, International Press Institute, and Renate Schroeder, European Federation of Journalists. Tijana Blagojev, Research Associate at the CMPF, will moderate the discussion.