Journalists’ and media associations and trade unions point to serious shortcomings in the manner in which the Ministry of Information and Telecommunications launched public consultations on required media content. They call on the Ministry to make available to the public, without delay, all data and documents serving as the basis for the analysis prescribed by Article 28 of the Law on Public Information and Media.
On 1 September, the Ministry opened public consultations, which will run until 2 October 2026, inviting the professional community and the general public to submit proposals concerning the media content required to serve the public interest in the field of public information.
Conducting public consultations is a legal obligation and an important part of the process of preparing the analysis of required media content. However, public consultations are not, and cannot be, a substitute for the analysis itself, as prescribed by Article 28 of the Law on Public Information and Media.
The Law clearly stipulates that the analysis of required media content must be based on several different sources and elements. Among other things, it should include reports on previously conducted calls for proposals, internal and external evaluations of implemented projects, an analysis of reports produced by journalists’ and media associations and trade unions and other relevant materials, the results of public consultations, as well as proposals concerning thematic areas, genre diversity, target groups and the amount of funding to be allocated for future calls for proposals.
Public consultations are therefore only one element of this process.
We consequently consider it problematic that the Ministry launched the consultations without simultaneously presenting the public with the analytical and documentary basis on which the future analysis will be based.
The consultation form itself creates additional ambiguity.
The form is entitled “Proposal on Required Media Content Serving the Public Interest”. However, the questions that follow are predominantly framed as comments and proposals “regarding the preparation of the analysis” and “for the preparation of the analysis”, while the document to which the suggestions are to be submitted is referred to as “Preparation of the Analysis of Required Media Content”.
This inconsistency is also present in the form prescribed by the Rulebook on Conducting the Analysis of Required Media Content and makes it even more difficult to understand what is expected of participants in the consultations: whether they are expected to identify specific media content that is lacking or to submit proposals on how the Ministry should prepare the analysis.
It is particularly problematic that the public has not been presented with any draft analysis, methodology or other initial document to which comments concerning the “preparation of the analysis” could refer.
The public consultation programme also fails to explain how the submitted proposals will be processed and evaluated. The Ministry states that it will analyse them and prepare a report, but it remains unclear which criteria will be used to consider the proposals, how they will be cross-referenced with the results of previous calls for proposals, evaluations and other data, or how the overall process will lead to conclusions about citizens’ actual needs for media content.
This is particularly important because the results of the analysis should directly influence future calls for the co-financing of media projects and decisions concerning the topics, genres, target groups and amounts of funding to be financed with public money.
We believe that compliance with Article 28 of the Law cannot be reduced to fulfilling a single formal obligation—publishing an invitation and allowing a period of at least 30 days for the submission of proposals.
The essence of this legal provision is that the state should determine which media content is lacking and how public funds should be directed to better serve the public interest, based on experience gained through previous project co-financing, evaluation results, relevant research and consultations with the professional community and the general public.
We therefore call on the Ministry of Information and Telecommunications to take the following steps without delay:
- publish information on the activities it has undertaken to date in preparing the analysis of required media content;
- publish reports on previously conducted calls for proposals that will serve as the basis for preparing the analysis;
- publish all available internal and external evaluations of the implementation of projects referred to in Article 27 of the Law covering the relevant period;
- publish data on the thematic and genre structure of supported projects, target groups, geographical distribution and other relevant indicators;
- clearly explain how proposals submitted by the professional community and the general public will be considered and how they will influence the final analysis;
- eliminate terminological and procedural ambiguities in the documents accompanying the consultations.
The analysis of required media content must not become an administrative formality, nor can its implementation be reduced to merely collecting proposals from the public.
It should answer several key questions: What has been financed with public money to date? What results has that funding produced? Which types of content and target groups have been neglected? How can future project co-financing better respond to citizens’ actual needs?
Only a transparent, methodologically clear and data-driven process can ensure that the analysis prescribed by Article 28 fulfils its purpose and that the future allocation of public funds for media content is genuinely directed towards serving the public interest.
Signatories:
Association of Independent Electronic Media (ANEM)
Association of Media
Association of Online Media (AOM)
Branch Trade Union of Culture, Arts and Media “Independence”
Independent Journalists’ Association of Serbia (IJAS)
Independent Journalists’ Association of Vojvodina (IJAV)
Journalists’ Association of Serbia (JAS)
Local Press – Business Association of Local and Independent Media
Slavko Ćuruvija Foundation
