Media service provider reporting obligations
The European Media Freedom Act (EMFA) is an EU regulation that puts in place new rules to protect media pluralism and independence and seeks to ensure that media can operate more easily across borders in the EU.
As part of the transparency obligations required under EMFA, media service providers will have certain reporting obligations.
From 8 August 2025, media service providers have an obligation to make easily and directly accessible to the recipients of their services up-to-date information on their:
- Company identity and contacts
- Ownership structure
- Beneficial ownership
- Revenue from government advertising
Once the Media Regulation Bill is enacted, as proposed by the General Scheme of the Media Regulation Bill, media service providers will also have a specific duty:
- to inform Coimisiún na Meán whenever the ownership and state advertising information required under Article 6(1) of EMFA is made available or updated on their platforms to facilitate the maintenance of a national media ownership database.
The following information is intended to assist media service providers by providing them with the key information they will need in order to ensure compliance. It does not constitute legal advice.
Obligations from 8 August 2025
The European Media Freedom Act introduces new transparency requirements for media service providers operating in the EU, effective from August 8, 2025. Under these rules, media service providers must make four key pieces of information easily accessible to their audiences:
Company identity and contacts
Media service providers must clearly display their official legal name and how to reach them.
Ownership structure
Media service providers must identify the name or names of their direct or indirect owner, including any shareholders in a position to influence how the company operates or makes strategic decisions. This includes if they are owned by government entities or public authorities.
Beneficial ownership
Media service providers must identify their beneficial owners, following EU anti-money laundering definitions.
Revenue from government advertising
Media service providers must detail the total annual amount of how much public money received annually from government advertising and any advertising revenue from foreign government sources or entities.
These transparency measures are designed to help the public understand who controls and funds their media sources. The goal is to protect media diversity and ensure audiences can make informed decisions about the news and content they consume.
Article 6 of EMFA
The relevant section of Article 6 of the European Media Freedom Act is set out below:
Duties of media service providers
1. Media service providers shall make easily and directly accessible to the recipients of their services up-to-date information on:
- their legal name or names and contact details;
- the name or names of their direct or indirect owner or owners with shareholdings enabling them to exercise influence on the operation and strategic decision making, including direct or indirect ownership by a state or by a public authority or entity;
- the name or names of their beneficial owner or owners as defined in Article 3, point (6), of Directive (EU) 2015/849;
- the total annual amount of public funds for state advertising allocated to them and the total annual amount of advertising revenues received from third-country public authorities or entities.
2. Member States shall entrust national regulatory authorities or bodies or other competent authorities or bodies with the development of national media ownership databases containing the information set out in paragraph 1.
Future reporting requirements under Irish law and the role of Coimisiún na Meán
The General Scheme of the Media Regulation Bill was approved by Government in July 2025 and seeks to implement the European Media Freedom Act (EMFA) in Ireland. The relevant provisions from Head 19 of this General Scheme outline the domestic legislative framework that will implement key aspects of EMFA relating to media ownership transparency and reporting obligations.
We currently operate two media ownership databases developed in cooperation with Dublin City University’s School of Communications:
It is proposed the Media Regulation Bill will include a provision on the development of a media ownership database that incorporates the information specified in EMFA.
Of relevance to media service providers is the proposed subsection (4b), which will require media service providers to notify Coimisiún na Meán whenever the ownership information required under Article 6(1) of EMFA is made available or updated on their platforms. This means that while media service providers must already ensure this information is “directly and easily accessible” to their service recipients under EMFA from 8 August 2025, once this domestic legislation is enacted, they will also have a specific duty to inform Coimisiún na Meán of any changes or updates to facilitate the maintenance of a national media ownership database.
Understanding these upcoming requirements will help media service providers to prepare appropriate systems and processes to ensure compliance when the legislation comes into force.
Key terms
Under Article 2 of the European Media Freedom Act, the following relevant definitions apply:
‘Media service’ means a service as defined by Articles 56 and 57 TFEU, where the principal purpose of the service or a dissociable section thereof consists in providing programmes or press publications, under the editorial responsibility of a media service provider, to the general public, by any means, in order to inform, entertain or educate.
Media service provider’ means a natural or legal person whose professional activity is to provide a media service and who has editorial responsibility for the choice of the content of the media service and determines the manner in which it is organised.
Contact
For queries regarding media service provider reporting obligations or implementation under EMFA, please contact us at [email protected].