20. 03. 2013
REMARKS AND SUGGESTIONS FOR AMENDING THE DRAFT LAW ON FEES
In the period from February 20 to March 20, 2013, the Ministry of Finance and Economy conducted a public debate on the Draft Law on Fees for Use of Public Goods. As the issue of fees of regulatory bodies, as well as fees for public service broadcasting were also included in this Draft Law, ANEM took active part in the debate, produced written comments and suggestions for amending the Draft Law and submitted them to the Ministry on March 20, 2013, on behalf of the association and other members of the Media Coalition (NUNS, UNS, NDNV, Local Press), with their full support.
In a letter to the Ministry, ANEM stated its position that the matter of fees charged by regulatory bodies, as well as fees paid for public service broadcasting should, however, be fully regulated by the laws governing the sector (Broadcasting Law, the Law on Electronic Media, which is under development, as well as the Law on Electronic Communications). This particularly because certain solutions provided in the Draft Law are in direct contradiction to these laws, but also because of the respect for the constitutional principle of unity of the legal order and the obligations arising from the EU Stabilization and Accession Agreement. Explaining its stand, ANEM listed a number of arguments supporting such stand and hence proposed deletion of Article 142 and 143 of the Draft Law that were stepping into the domain of fees for regulatory bodies and fees for public service broadcasting.
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