On July 23, the European Centre for Press and Media Freedom (ECPMF) submitted input to the targeted consultation on Article 18 of EMFA. We strongly support the introduction of a robust and accessible self-declaration mechanism for media service providers as a necessary tool to protect the media sector from arbitrary decisions by Very Large Online Platforms (VLOPs), shadow-banning, and the growing influence of AI-generated content that undermines original journalism.
“Article 18 of EMFA is an important complement to the Digital Services Act (DSA), which does not have similar provisions. Moreover, the enforcement up to date has not ensured meaningful accountability from platforms. Self-declaration can serve as a strong instrument to safeguard editorial independence and ethical journalism without imposing disproportionate regulatory burdens.” said Ena Bavčić, ECPMF’s EU Advocacy Officer.
In this context, ECPMF advocates for a mechanism that:
- Strengthens and promotes co- and self-regulation in line with ethical journalism standards.
- Allows media actors to choose a single reference body, ensuring flexibility while avoiding exclusion of legitimate media outlets.
- Ensures non-discriminatory access to self-declaration for all media professionals by avoiding a two-tier system that favours large institutional media.
- Is inclusive of freelance, independent, and exiled journalists, who often face significant barriers to joining formal regulatory bodies.
- Provides alternative validation through references from credible media or civil society organisations, where formal affiliation is not feasible.
We call on the European Commission to create the guidelines that obligate VLOPs to create a simple, free of charge, and user-friendly self-declaration system. This system should be based on clear terms, transparent procedures, and human-led communication.
To ensure compliance and accountability, we call for a strong oversight mechanism involving media organisations, rights-based civil society, the research community, and the European Board for Media Services.
For more information please check the document here.















