Media and journalism associations have submitted a new proposal to MIT regarding the amendments to the project co-financing process.

Proposals for amendments to legal acts and specific changes in the project co-financing process are based on the agreed conclusions from internal consultations with representatives of the aforementioned media and journalistic associations and the self-regulatory body, the Press Council.

We hope that these proposals will help to take concrete steps that will address deficiencies and reduce abuses at all levels of government, and that should improve the project co-financing process in the upcoming period.

COMMITTEES – composition, selection, and prevention of concentration of influence

The project evaluation system relies on committees whose selection method favors the concentration of influence among a small number of experts who rotate from cycle to cycle. Journalistic and media associations recommend reforming the Rules to introduce rotation mechanisms, eliminate criteria that reward prior presence in committees instead of expertise, and establish a more proportional scoring scale that values long-standing journalistic experience and the representativeness of associations nominating candidates.

We recommend that:

• The participation of a single media expert in committees be limited to no more than five competitions within a calendar year, regardless of the organ issuing the competition.
• Mandatory rotation of members of evaluation committees be introduced, so that the same person cannot be appointed as a committee member for the same competition in two consecutive years.
• The scoring of professional works and participation in professional events as criteria for selecting members of evaluation committees be abolished, retaining only published works in journals and participation in conferences that are on the valid list of the Ministry of Science as the only recognized form of scientific contribution—thus eliminating the potential for manipulation of the scoring list.
• The scoring of previous project proposal writing and participation in projects as criteria for selecting members of evaluation committees be abolished, as this criterion creates a closed circle between project writers and evaluators.
• The number of points awarded for previous participation in committee work be abolished or significantly reduced, considering that this criterion systematically favors individuals who have already participated and structurally excludes experts who have not had the opportunity so far.
• A significant difference in points between a master's degree and a doctoral degree be established, so that the level of education is proportionately valued in the process of selecting members of evaluation committees.
• The scoring scale for work experience be expanded by introducing separate categories for longer journalistic and media tenure—so that the long-standing practical knowledge of candidates for committee members is adequately valued.
• A criterion of representativeness for associations nominating members of evaluation committees be established— including a minimum number of active members and proof of the active work of the association in the previous year— to ensure that nominations come from organizations that genuinely represent the media community.
• A unified fee tariff for members of evaluation committees be introduced, applicable to all bodies issuing competitions—regardless of the level of government—to eliminate inconsistencies that favor committees with higher fees.

TRANSPARENCY of the decision-making process

A decision made without explanation is not a decision that can be contested—it is a finished fact with no trace of how it was made. Journalistic and media associations recommend that this deficiency be addressed by introducing a mandatory concluding meeting of the committee and an obligation to record and publicly disclose the reasons for each individual decision.

We recommend that:

• A mandatory concluding meeting of all committee members before establishing the ranking list be introduced—at which each member presents their evaluations to others and which is recorded in the minutes—as a minimum that ensures mutual verification of individual evaluations and shared responsibility for the final decision.
• The committee be required to explain its evaluation of each project in the minutes—indicating the key reasons why each individual project was proposed for funding or rejected—and that justifications be made available to submitters upon request and published alongside the ranking list.

CRITERIA for project scoring

Access to public funding must not be a technical formality separated from journalistic standards. Journalistic and media associations recommend that the criteria for project evaluation be reformed in three directions: by introducing disqualification for media that systematically violate the journalistic code, standardizing measurable indicators of audience reach applicable to all types of media, and giving preference to local media that continuously and through their own production report on issues of public importance.

We recommend that:

• It be established that media sanctioned by a regulatory or self-regulatory body for violating professional and ethical standards five or more times within a calendar year cannot participate in competitions—because taxpayer funds must not be available to those who systematically violate the journalistic code.
• Preference in evaluation be given to local media that have their own production and continuously report to the local community on issues of public importance—as a criterion that rewards real journalistic work, not formal registration in a certain area or taking over someone else's content.
• Standardized and verifiable criteria for assessing audience reach be introduced, applicable to all types of media—print, online, radio, and television—so that subjective assessment is replaced by measurable indicators that can be equally applied regardless of the type of media or market in which it operates.

JIS – open data and access to information

Without data that is available, comparable, and searchable, the transparency of the process remains declarative. Journalistic and media associations recommend that data on public co-financing of media—who applies, who receives, how much, and from whom—be published in a machine-readable format and organized into a unified database that encompasses all levels of government, all users, and all sources of public financing, including records of committee members and their engagement through competition cycles.

We recommend that:

• A mechanism for systematically collecting user feedback on issues with the JIS platform be established, and based on this feedback, a publicly disclosed plan for improving the system with specific deadlines for implementation be announced.
• All data on public co-financing of media—including announced competitions, submitted and approved projects, allocated amounts, and reports on implementation—be published in a machine-readable format that allows for downloading, searching, and analyzing data.
• A publicly accessible database of all funded projects be formed, organized by publisher, media, and level of government, with a display of allocated amounts per project and year—so that anyone can determine who receives public money, from whom, and in what amount.
• A database of all members of evaluation committees be established, with information on their name, the association that proposed them, and all committees in which they participated—so that the public can track the frequency and distribution of the same individuals' engagements through competition cycles.
• A unique, publicly searchable database be established, encompassing all public funds received by owners and media from all sources of financing—national, provincial, and local—so that a complete insight into the overall flow of public money to the media sector can be gained.

EVALUATION and monitoring of conducted competitions

The media co-financing system in Serbia has never been subject to independent external evaluation, which means that neither the public nor decision-makers know whether the system rewards media that operate in the interest of the community—nor whether the community benefits in any way from the public money invested in it. Media and journalistic associations demand that this legal obligation finally be fulfilled, along with publicly disclosed criteria, transparent selection of contractors, and mandatory responses from competent authorities to the findings.

It is recommended that:

• Before conducting an external evaluation, the evaluation criteria, criteria for the selection of contractors that exclude conflicts of interest, deadlines for publishing findings, and the obligation of competent authorities to respond to those findings with specific measures be publicly disclosed in a timely manner—because existing annual reports, focused on the technical details of implementation, do not answer the fundamental question of whether the system achieves its goals.

OWNERSHIP STRUCTURE and prevention of conflicts of interest

Without clear insight into the ownership structure of project applicants and consolidated data on all public funds that media receive, it is not possible to determine whether the same ownership group receives public money through multiple media or projects simultaneously—nor in what total amount.

Journalistic and media associations recommend that the Ministry of Information and Telecommunications, in cooperation with the Tax Administration and the Business Registers Agency, consider how existing legal instruments for identifying related parties can be applied within the competition procedures for co-financing media projects—so as to prevent the same ownership or management structure from receiving public funds through multiple formally independent entities.

Proposers:

ANEM (Association of Independent Electronic Media)

UNS (Journalists' Association of Serbia)

PU Local Press

NUNS (Independent Journalists' Association of Serbia)

Media Association

Download the recommendations in the PDF document.

The project of the Association of Independent Electronic Media “Participatory Monitoring of the Implementation of the Project Co-Financing Process” is supported by the Dutch Ministry of Foreign Affairs through the MATRA program. ANEM is solely responsible for the content of the analysis, which does not necessarily reflect the official views of the Kingdom of the Netherlands.