Transparent media markets are a cornerstone of media pluralism. Yet, prior to the entry into force of the EMFA, there was no harmonised EU framework to guarantee fair, transparent, and comparable audience metrics across platforms and media types. Audience measurement data and methodologies have often been proprietary and accessible only through paid services. This limited transparency has created asymmetries between large and small media actors. Without reliable audience data, news media, especially smaller media service providers, cannot effectively demonstrate their audience value and monetise advertising. In addition, the digitalisation of media created new asymmetries, with the growing dominance of online platforms and device operators which provide proprietary measurements, based on a huge amount of data, but without independent verification, nor transparency of their methodology. This has further distorted competition. Article 24 therefore comes as a response to these market distortions.

According to Article 24 EMFA, providers of audience measurement systems shall ensure that their measurements comply with the principles of transparency, impartiality, inclusiveness, proportionality, non-discrimination, comparability and verifiability (para 1). These should also provide to media service providers, advertisers and authorised third parties accurate, detailed, comprehensive, intelligible and up-to-date information on their methodology without undue delay and free of charge (para 2). Methodologies should be subject to independent audits on a yearly basis. Furthermore, national regulatory authorities or bodies should encourage these providers to elaborate, together with media service providers, providers of online platforms, their representative organisations and any other interested parties, codes of conduct and, eventually, encourage compliance (para 3). The Commission, assisted by the European Board of Media Services (EBMS), may issue guidelines on the practical application of paragraphs (para 4) and the Board should foster the exchange of best practices related to the deployment of audience measurement systems through a regular dialogue (para 5).

Various stakeholders including the Audience Measurement Coalition (AMC), and the Joint Industry Committees (JICs) and Media Owner Committees (MOCs) together, have issued position papers that raise critical challenges. Generally, it is urged the Commission to translate these EMFA’s high-level principles into concrete practice, clarifying how transparency, impartiality, and inclusiveness should be operationalised; it is requested to outline mechanisms for data sharing between such providers and media service operators; and it is asked to define what constitutes a proprietary audience measurement provider to include other operators providing access to media services (e.g. Google, Android, and Apple TV). In particular, industry stakeholders underline that audience measurement must evolve towards hybrid models combining traditional panels and digital census data, ensuring cross-platform comparability and avoiding dominance by a few gatekeepers controlling access to audience metrics.

At the same time, the Italian Communications Authority (AGCOM) — appointed by the EBMS to lead the Working Group focusing on "media business environment", which has as key priority the audience measurement related activities (see the 2025 Media Board Work Programme) — has stressed the need for a coherent and systemic European approach (DELIBERA N. 199/25/CONS). The Authority has also highlighted that major online platforms have so far refrained from joining third-party measurement initiatives by independent bodies such as Joint Industry Committees, relying instead on proprietary and uncertified metrics. This increases the risk of fragmented, non-comparable data entering the market. AGCOM has therefore emphasised the importance of developing common, transparent and verifiable methodologies, ensuring that audience measurement is conducted by independent entities representative of the entire sector.

The 'EMFA Talks' are sessions organised by the Centre for Media Pluralism and Media Freedom under its Observatory on the European Media Freedom Act to analyse the Act’s impact, its implementation, and to discuss related challenges with legal experts, journalists, media professionals, and policymakers.