Consultation on Article 18 of the European Media Freedom Act
Commission seeks feedback on protecting media service providers on online platforms
The European Commission is currently developing guidelines for the implementation of Article 18 of the European Media Freedom Act (EMFA), which aims to protect media providers from the unjustified removal or restriction of their content by Very Large Online Platforms (VLOPs)—platforms with over 45 million monthly users in the EU.
These guidelines will help VLOPs implement safeguards required under the EMFA, including transparency obligations and protections for editorially independent media providers.
What’s Changing Under Article 18 of the EMFA?
Starting August 2025, VLOPs will be required to:
Notify media providers before taking action to remove or restrict their content.
Provide a clear explanation for the proposed moderation decision.
Offer media providers 24 hours to respond before the platform proceeds with the action, unless there are urgent risks to public safety.
To support the implementation of these new rules, the European Commission launched a targeted consultation in July 2025, seeking input from media stakeholders, platforms, and civil society. Members of the EU Media Advocacy Group coordinated their responses to promote a robust, transparent, and rights-based approach to enforcement.
Submissions from the EU Media Advocacy Group
Members of the EU Media Advocacy Group, submitted responses to the consultation. The submissions reflect a shared concern that the guidelines must safeguard editorial independence, prevent abuse by state-aligned actors, and provide transparency and accountability in how platforms apply moderation decisions. Below is a selection of submissions by group members:
European Federation of Journalists
Highlighted key priorities for EFJ affiliates including the promotion of self-regulatory mechanisms, requesting an easily accessible process for self-declaration, strong enforcement and accountability, among others. Read the full submission here: https://europeanjournalists.org/blog/2025/07/28/efj-urges-commission-to-promptly-draft-clear-guidelines-on-digital-platforms-content-moderation-obligations-emfa-article-18/
European Centre for Press and Media Freedom (ECPMF):
Supported the introduction of a robust and accessible self-declaration mechanism for media service providers as a necessary tool to protect the media sector from arbitrary decisions by Very Large Online Platforms (VLOPs), shadow-banning, and the growing influence of AI-generated content that undermines original journalism. Read the full submission here: https://www.ecpmf.eu/ecpmf-urges-for-a-strong-and-accessible-implementation-of-the-emfa-self-declaration-mechanism/
Liberties
Highlighted the importance of ensuring that all media outlets that operate online are able to enjoy the protections set out in the European Media Freedom Act. Read the full submission here: https://www.liberties.eu/en/stories/ec-submission-emfa-art18/45465
European Broadcasting Union
Urged strong safeguards against unfair content moderation by large online platforms. Their priorities include a simple self-declaration process, unified account recognition, and expert media contacts. Read the full submission here: https://www.ebu.ch/news/2025/07/ebu-contributes-to-commission-consultation-on-article-18-emfa-guidelines-meta-co-new-obligations-are-non-negotiable
The Global Forum for Media Development
Developed in collaboration with Prof. Joan Barata and members of the EU Media Advocacy Group, GFMD’s submission calls for greater transparency, clear validation criteria, and remedies for media organisations affected by wrongful moderation.
Read the full submission here:
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