Coalition for Media Freedom: Why is the APR media database still not in compliance with the law?

Reviewing the Register, it is clear that public authorities do not submit, and the Registrar does not register, data regarding the funds allocated to citizens that are given to the media on other grounds.

We remind you that the Law on Journalistic and Media Integrity obliges public authorities to submit, or register with the Business Registers Agency (APR), not only data about financial resources allocated through competitive co-financing of the public interest in the field of public information, or in the name of state aid but also all other public funds that are forwarded to the media in the form of donations, gifts, sponsorships, market and economic research services, public opinion polling services, campaign, advertising and marketing services, promotional services, media services based on the application of regulations in the field of public procurement, or other services provided by the media.

According to the letter of the law, it is the duty of state authorities, authorities of territorial autonomy, local self-government units, organizations entrusted with the exercise of public powers, as well as legal entities wholly or predominantly funded or established by the Republic of Serbia, autonomous provinces, or local self-government units, and commercial companies in which a significant share of the capital is held by a public authority to submit these complete data to the Registrar.

The Ministry of Information and Telecommunications has also done nothing to encourage the media to adopt and submit internal ethical documents to the Registrar, which represent the internal self-regulatory framework for the improvement of professional standards.

The registration of internal documents is also stipulated by the Law on Public Information and Media, and they should contain measures and procedures for protecting the media's editorial policy, ensuring a safe environment for journalists and media workers, enhancing the position of persons with disabilities, and achieving gender equality.

Upon reviewing the APR database, we found that an extremely small percentage of media outlets have fulfilled their legal obligation, primarily prompted by journalistic and media associations.

This is also a consequence of the fact that the Ministry of Information and Telecommunications, in its Regulation, only specifies the starting date for submitting internal documents (from January 1 of last year) but does not set a deadline by which the documents must be registered at the latest.

On the other hand, media outlets that are just registering must submit these documents. In other words, they will not be registered if they do not submit (i) internal documents.

This obligation is also not detailed or elaborated on the APR website; it can even be said that it is very confusingly defined. No precise instructions for document registration have been provided.

We remind you that last year, the Coalition of Journalistic and Media Associations published and presented a Set of Internal Acts that media can use to fulfill their obligation to the APR, in an effort to assist them in this process.

However, we emphasize that the Set of Internal Acts should be adapted by the media to their needs and specificities. We believe that our common goal should be for these not to remain "dead letters on paper," but to be genuinely implemented.

We call on the Ministry of Information and Telecommunications and the Business Registers Agency to rectify the mentioned shortcomings and to become more actively involved in encouraging public authorities to submit the necessary data and media to create and register internal acts.

Coalition for Media Freedom

The Coalition for Media Freedom consists of: Media Association, Association of Online Media (AOM), Independent Journalists' Association of Vojvodina (NDNV), Independent Journalists' Association of Serbia (NUNS), Business Association of Local and Independent Media "Local Press," Slavko Ćuruvija Foundation, and the Branch Trade Union of Culture, Arts, and Media "Independence"