Media Registry and Enhancement of Transparency: Proposal within the OGP Process

Written by: Tanja Maksić, Program Coordinator, BIRN Serbia

What is the Media Register and why is it important?

The Media Register maintained by the Agency for Business Registers is designed as an open database of domestic media. In theory, the Register is intended as a key tool for transparency, providing insight into data about ultimate owners, publishers, editors, and state funding for media.

Thanks to the Register, citizens, researchers, journalists, and other interested parties can find out, for example, who is behind the most influential media in the country or how much state money a particular media outlet has received through public competitions.

In a broader social context, the Register is also a tool for media literacy as it enables citizens to critically assess the impartiality and quality of the information that media outlets disseminate, taking into account ownership relations and their connection to the state.

In practice, however, the Media Register still does not fully serve its function due to numerous structural weaknesses. Firstly, the Register is difficult to search (currently, the only search options are by media name or registration number, while searches based on ownership, for example, are absent); the ownership data is textual and can only be accessed by reading the document in the Published Documents section; data on state grants pertains only to public competitions, while data on other state funding (for example, through public procurement or other marketing contracts with institutions) is missing; questions arise regarding the timeliness of the data and the dynamics with which it is registered; the data is not available in a machine-readable format, and so on.

In addition to these issues, it is important to note that media data is "scattered" across several open online databases which do not communicate with each other. Firstly, there is the Public Procurement Portal where data on public procurement for state advertising received by certain media is published; the Unique Information System is a database managed by the Ministry of Information and Telecommunications (MIT) and is used solely for monitoring public competitions for media; the Regulatory Body for Electronic Media maintains its own database of broadcasting licenses for radio and TV programs, etc.

Thus, while the minimum requirements for publishing data are met, essential transparency is lacking.

The Media Register and the Potential of the OGP Advocacy Platform

OGP (Open Government Partnership) is an international initiative in which, alongside Serbia, 70 other countries participate. The goal of this initiative is an open and citizen-oriented government. Serbia's commitments under this initiative have focused specifically on using technology to improve the quality and accessibility of public services, as well as publishing large sets of open data, so in this context, enhancing the Media Register represents one of the most concrete and feasible activities. For example, through this process, the Unique Information System of the MIT was established a few years ago, and improving the Register would be the next logical step.

BIRN Serbia, together with other civil society organizations participating in the OGP process, proposed amending the Register as one of the points to supplement the existing OGP Action Plan. However, this proposal was not accepted, missing yet another opportunity for enhancing transparency, modernization, and further reforms.

What needs to change?

The specific proposal from civil society was to follow three sets of activities to achieve an improved Register. First, a comparative analysis of media registers in EU countries with a similar media system to Serbia should be conducted. One possible example of good practice would be the register "Ownership and Methods of Media Financing" maintained by the Croatian Agency for Electronic Media (available here: https://vsif.aem.hr/). The second step would involve aligning legal and sub-legal acts with the new functionalities of the Register, while the third would be technical enhancement.

This proposed sequence of steps should lead to a more functional, data-rich, and easily searchable Register. Furthermore, this proposal should encourage essential institutional changes that view this register not just as a database, but as an instrument for public policy. A well-organized register, for example, would more easily signal the risk of concentration (when one publisher owns a large number of media outlets) or if a certain media outlet is predominantly funded from the budget.

Additionally, the importance of establishing a functional Media Register is highlighted by the new EU media legislation coming with the EMFA (European Media Freedom Act), with which Serbia plans to align. The EMFA discusses the need to publish ownership data in the context of editorial independence, as well as in the context of recognizing the specific position of media on social media platforms, for which registers will be the main source of information.

From a technological perspective, especially regarding the development of artificial intelligence (AI), quality and verified data held by institutions, including media data, will be crucial as they can reduce the number of errors and hallucinations in AI systems.

Where did the problem arise?

Improving the Media Register has not been accepted as a measure in the enhanced OGP Action Plan for the last two years of its implementation. There are two main reasons for this outcome.

One, of a technical nature, concerns the misaligned deadlines for implementing the OGP plan and the work plan of the Ministry of Information and Telecommunications on the new media strategy and aligning domestic legislation with the EMFA.

The second, a fundamental problem, is the lack of participation and an almost broken dialogue between the relevant ministry and some media organizations and journalistic associations. Independent organizations gathered around the Coalition for Media Freedom (which includes BIRN) decided at the end of 2025 to suspend all negotiations with state bodies as a way to support the demands of student and civic protests, but also to draw attention to the deteriorating position of independent media, systematic suppression of media freedoms, and the dramatic increase in attacks on journalists.

Moreover, members of the Coalition for Media Freedom did not want to participate in working groups of the Ministry of Information and Telecommunications where the issue of improving the Media Register could be discussed in connection with the new media strategy and legislative amendments, as its members oppose the instrumentalization of working groups often involving so-called GONGO (government-organized non-governmental) organizations to simulate the participation of the broader media sector.

Therefore, the improvement of the Media Register should not be viewed as an isolated technical intervention, but as part of a broader reform of the state's approach to transparency and public data. Without a functional, open, and reliable register, any discussion about media pluralism, financial accountability, and the state's influence on the media remains incomplete.

Source: Partners Serbia