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Report by the OSCE Representative on Freedom of the Media, Ambassador Jan Braathu

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1 Regular Report to the Permanent Council For the period from 28 November 2025 – 23 April 2026 Organization for Security and Co-operation in Europe The Representative on Freedom of the Media Jan Braathu FOM.GAL/2/26/Rev.1 24 April 2026 ENGLISH only

2 Mr. Chairperson, Excellencies, Distinguished delegates, Today, I present my third report to the Permanent Council, covering the period from 28 November 2025 to today. This report is grounded in the core of my mandate: to address the gap between our shared commitments on media freedom and freedom of expression, and the realities observed across the OSCE region. Since my previous address, I have engaged closely with participating States, journalists, and civil society across the OSCE region, including through more than 70 meetings with government officials, media, and civil society representatives, and with over 100 diplomatic and public communications 1 . These engagements have reaffirmed a fundamental point: media freedom is not a by-product of democracy; it is one of its foundations. And far from threatening security, it is one of the conditions that makes peace and security possible. This is particularly evident in the context of the Russian Federation’s aggression against Ukraine, where the information environment, including the safety of journalists, is a central dimension of the war, with direct consequences for media freedom and access to information. In my November report to this Council, I warned that the information environment was undergoing a profound transformation, one that was already reshaping public discourse, weakening trust, and testing the resilience of free and independent media across the OSCE region. At that time, these developments could still be described as early signals; indicators of a deeper shift that was beginning to take shape. Today, that is no longer the case. We are no longer observing a transformation. We are living within it. What we are witnessing is not simply a change in technology, nor a temporary disruption in media systems. It is a structural shift in which control over information has become a central source of power, shaping how societies understand reality, how citizens form opinions, and ultimately how legitimacy itself is constructed. This transformation is not driven by a single factor. It is the result of political, technological, and societal changes converging at once. And importantly, it is not confined to traditionally authoritarian settings. 1 An overview of public and diplomatic engagements, and activities during the reporting period is reflected in the annex to this report.

3 As highlighted in recent analysis by The Economist 2 , some of the most pronounced declines in media freedom are now taking place in countries that continue to present themselves as democratic. The methods may differ from those seen in more overtly repressive systems, but the effect is comparable: pressure on independent journalism is applied through legal constraints, economic leverage, and sustained rhetorical attacks. This is a critical point. Democracy, in and of itself, is not a guarantee of media freedom. And where media freedom weakens, the consequences extend far beyond the media sector. Indeed, freedom of expression more broadly, not only media freedom, is also under increasing pressure across the region. Freedom of expression and the free flow of information remain foundational to open societies, enabling democratic participation, accountability, innovation, and economic growth. Yet these principles are increasingly contested, with growing polarisation around the scope and limits of permissible speech. Importantly, freedom of expression extends beyond speech that is widely accepted or considered agreeable. It also protects the expression of dissenting, controversial, or uncomfortable views, which are essential to pluralistic debate and democratic resilience. Safeguarding this broader understanding of freedom of expression is therefore critical to ensuring that public discourse remains open, diverse, and capable of accommodating disagreement. Over-restrictive legal frameworks risk creating a chilling effect on public debate and critical discourse. At the same time, freedom of expression is not only shaped by formal legal frameworks, but also by the broader information environment in which speech circulates. The ability to seek, receive, and impart information depends increasingly on how information is distributed, prioritised, and mediated. The way people encounter news is changing. Research 3 by the Reuters Institute for the Study of Journalism shows that trust in news remains uneven and is often lower among younger audiences, while news avoidance is increasing in many countries. And this raises a fundamental question, not about where people access news, but whether they are consistently engaging with reliable, independent information in ways that support informed participation in democratic processes. 2 The Economist, How democracies are using autocratic tools to muzzle journalism 3 University of Oxford, Reuters Institute for the Study of Journalism, Understanding Young News Audiences at a Time of Rapid Change

4 These developments confirm a broader point: access to reliable and independent information is not peripheral to democratic life; it is one of its essential conditions. In this sense, media freedom is not only an outcome of democratic systems. It is one of their core foundations. The importance of cross-border access to information is equally critical. The Helsinki Final Act affirms the principle of the free flow of information and the need to facilitate the work of journalists across borders. Yet this principle is increasingly under strain. Restrictions on foreign correspondents, limitations on media access, and barriers to cross-border journalism are becoming more frequent, limiting the ability of societies to access independent information beyond their own national contexts. Taken together, these developments point to something deeper than a series of isolated challenges. They reflect a transformation in the very structures that sustain our comprehensive security architecture. In this context, the role of diverse, independent, and ethical media becomes even more central. Without it, citizens cannot exercise informed political choice, institutions cannot be held accountable. This is not simply a policy concern. It goes to the core of what participating States have committed themselves to uphold. As reaffirmed in Budapest in 1994, “freedom of expression is a fundamental human right and a basic component of a democratic society,” and “independent and pluralistic media are essential to a free and open society and accountable systems of government.” From the outset, participating States also recognised a central challenge that remains highly relevant today: the gap between these commitments and their implementation in practice. As noted in the first ever report of the Representative on Freedom of the Media to the Permanent Council in 1998 4 , the role of this Institution is to address precisely “the difference that might occur between our written convictions on freedom of the media and the day-to-day reality.” Nearly three decades later, this gap has not disappeared, it has widened. 4 1998 Report by the First Representative on Freedom of the Media to the Permanent Council, on 15 January 1998

5 And it is this mandate that continues to guide the work, through direct engagement with participating States, national authorities, media, and civil society actors across the region. Against this backdrop, my report today focuses on several areas where the gap between commitments and reality appears most pronounced. Each of these areas is outlined in the subsequent parts of this report, and they all reflect a different dimension of the same underlying challenge. Safety of Journalists The safety of journalists is a fundamental condition for the exercise of freedom of expression and media freedom. Without it, independent reporting cannot function, and the public’s right to information is directly undermined. The Council of Europe Platform on the Safety of Journalists has reported 280 alerts of incidents of violence, imprisonment, harassment, or intimidation against journalists in 2025 alone, and 71 alerts in 2026, to date 5 . This does not even cover the entire OSCE region. Participating States themselves recognized in Budapest in 1994 6 , that they “condemn all attacks on and harassment of journalists.” They also acknowledged in the 2018 Ministerial Council Decision on Safety of Journalists 7 the need to create an environment in which journalists can work freely and safely. Nowhere is the importance of this commitment more evident than in Ukraine, where Russia’s aggression has created extreme conditions for journalism in the OSCE region. Journalists continue to report under the constant threat of shelling, missile and drone attacks, and violence, often at great personal risk. Media infrastructure has been damaged or destroyed, newsrooms displaced, and reporters forced to operate in conditions of prolonged insecurity and trauma. Once again, I reiterate that journalists and media outlets enjoy protection under International Humanitarian Law and must not be targeted or attacked. I also reiterate my call for the release of the 26 Ukrainian journalists who continue to be arbitrarily detained by the Russian Federation. At the same time, journalists in Ukraine continue to fulfil their essential role: documenting the reality of war, informing the public, and ensuring that the facts are not obscured. These conditions place sustained pressure not only on the safety of journalists, but on the resilience and functioning of the entire media environment. 5 Council of Europe Platform on Safety of Journalists 6 1994, CSCE Budapest Document: Towards a genuine partnership in a new era 7 2018 OSCE Ministerial Council Decision 3/18 on the Safety of Journalists

6 Across the OSCE region more broadly, journalists face a range of threats that can be broadly grouped into three categories: physical violence, legal pressure, and digital harassment. Violence against journalists, particularly in the context of protest coverage, remains a persistent concern. Journalists have been injured, attacked, or obstructed while reporting from public demonstrations across several participating States. Trends observed in recent years, in countries including France, Germany, Serbia, United Kingdom, and the United States, illustrate the risks associated with reporting from public gatherings, where journalists have been physically attacked, detained, or prevented from carrying out their work despite clearly identifying themselves as media. Such incidents highlight a broader concern: the growing risks associated with covering events of public interest in open civic spaces. This is an ongoing issue, which I particularly highlighted in my previous report to this Permanent Council 8 . I urge participating States to ensure safety of journalists covering public events, drawing on good practices such as in Austria, the Netherlands, Germany, and the United Kingdom, of structured co- operation between law enforcement and media, including liaison officers, protection mechanisms, and targeted police training. Legal pressures are also increasingly affecting journalists’ ability to operate freely. Across the region, criminal proceedings, arrests, and pre-trial detention have been used in cases involving reporting on matters of public interest. In some participating States, including Azerbaijan 9 , Belarus 10 , and the Russian Federation 11 , journalists face imprisonment, and media outlets and social network accounts are banned under broadly framed provisions such as “false information,” extremism, or the use of national security-related offences beyond their legitimate scope of protecting “a country’s existence or its territorial integrity against the use or threat of force” 12 . In particular, the use of vague or overly broad legislative provisions, including laws criminalising the dissemination of so-called “false information,” risks creating a chilling effect on public debate and critical discourse and should be avoided. 8 2025 Report by the OSCE Representative on Freedom of the Media, Ambassador Jan Braathu 9 Barometer | RSF 10 Barometer | RSF 11 Barometer | RSF 12 Article 19, The Johannesburg principles on national security, freedom of expression and access to information

7 Some restrictions may be justified in the name of public order or security. But when they lack clarity, precision, or proportionality, they risk undermining the very freedoms they claim to protect. Also in Armenia, Georgia, Kazakhstan, Kyrgyzstan, and Türkiye, journalists and other media actors are facing prosecution, ongoing criminal proceedings, pre-trial detention, and other forms of legal pressure. In addition, law enforcement measures may affect core journalistic protections, including the confidentiality of sources. Recent cases, including searches of journalists’ electronic devices and restrictions on access to information, raise concerns about the erosion of safeguards essential for investigative reporting and the public interest. There are mounting concerns related to surveillance, including the monitoring of journalists. Such practices stand in direct tension with OSCE commitments. In Ministerial Council Decision No. 3/18, participating States committed to “refrain from arbitrary or unlawful interference with journalists’ use of encryption and anonymity technologies” and to refrain from employing “unlawful or arbitrary surveillance techniques.” At the same time, online violence and harassment is increasing in scale and severity. Journalists across the region are increasingly exposed to online harassment, intimidation, and abuse. These attacks are often coordinated and targeted, and disproportionately affect women journalists, who face gender-based violence, including misogynistic hate speech, doxing, and sustained online harassment. Such practices are not isolated incidents but form part of a broader pattern of intimidation aimed at discouraging critical reporting and limiting participation in public discourse. Taken together, these developments point to a wider pattern of pressure on journalists across the OSCE region. Physical attacks, legal constraints, and digital harassment increasingly intersect and reinforce one another, creating a more hostile environment for independent journalism. Where such threats are not effectively prevented, investigated, and prosecuted, a climate of impunity can emerge. This not only endangers individual journalists but weakens the democratic conditions under which journalism can function. Ensuring the safety of journalists is therefore not only a matter of protection, but a core requirement for safeguarding freedom of expression, media freedom, and democratic resilience across the OSCE region.

8 Hostile and Stigmatising Rhetoric by Public Officials Against the Media Across the OSCE region, hostile and stigmatising rhetoric by public officials against journalists is becoming both more visible and more consequential. Ministerial Council Decision No. 3/18 “urges political leaders, public officials and/or authorities to refrain from intimidating, threatening or condoning – and to unequivocally condemn – violence against journalists, in order to reduce the risks or threats that journalists may face and avoid undermining trust in the credibility of journalists as well as respect for the importance of independent journalism.” And yet, among the milder derogatory statements, here are just some of the terms that have been used during this reporting period alone: “traitor”, “pure terrorist”, “fascist”, “evil”, “paedophile”, “garbage,” “dumb journalist”, “a disgrace”, “enemy of the state”, “piggy”, “rotten”, “ugly, both inside and out”, “stupid person”, “stupid woman”, “fake news”, and “mercenary”. Such rhetoric is not merely symbolic. When public officials portray the media as adversaries, enemies, or traitors, it erodes public trust, legitimises harassment, and increases the risk of physical harm. These dynamics are not abstract: across the region, stigmatising rhetoric continues to translate into a more hostile environment for journalists, normalising harassment and making independent reporting more vulnerable to intimidation and attack. Where such rhetoric goes unchecked, it not only damages trust in the media, but also weakens the democratic conditions under which journalism can function and contributes to a broader degradation of the information environment, reinforcing fragmentation and polarisation. This dynamic is particularly visible in the targeting of women journalists across the region, who are disproportionately exposed to higher levels of abuse, including misogynistic hate speech, doxing, and coordinated online harassment campaigns, reinforcing structural barriers to participation in public discourse. While public officials are fully entitled to criticise the media, this is not without limits. OSCE participating States have committed, including in Ministerial Council Decision No. 3/18 on the Safety of Journalists 13 , to foster a safe and enabling environment for journalists and urged “political leaders, public officials and/or authorities to refrain from intimidating, threatening or condoning violence against journalists.” In addition, the international freedom of expression mandate holders have emphasised that public officials bear a heightened responsibility in this regard. In the 2021 Joint Declaration on Politicians and Public Officials and Freedom of Expression 14 , they stress 13 2018 OSCE Ministerial Council Decision 3/18 on the Safety of Journalists 14 2021 Joint Declaration on Politicians and Public Officials and Freedom of Expression

9 that, while robust debate is essential in a democracy, officials should avoid making statements that undermine the safety of journalists or erode trust in independent media, given the influence of their position and the potential impact of their words. Against this backdrop, criticism by public officials must not cross into intimidation, incitement to violence, or systematic denigration. Words spoken from positions of power shape the conditions in which journalists operate and can either reinforce or erode, their safety and independence. Political leadership carries heightened responsibility: words spoken from positions of power shape the conditions in which journalists operate. Words matter. Reversing this trend requires clear and consistent political signalling. Public officials should actively reaffirm the legitimacy of independent journalism, refrain from stigmatising language, and promptly condemn attacks against the media. In the current information environment, safeguarding media freedom begins not only with laws and institutions, but with the tone set by those who hold public office. Judicial and Structural Pressures on Independent Media Legal and regulatory frameworks play a defining role in shaping the environment in which independent media operate. Where such frameworks are overly restrictive, vague, or misused, they can create systemic pressures that constrain journalism and limit freedom of expression. Among the most pressing concerns is the continued and growing use of strategic lawsuits against public participation (SLAPPs). While it is recognised that not all lawsuits against the media fall into this category, SLAPPs are vexatious lawsuits which are specifically designed to intimidate journalists and silence investigative reporting. Recent evidence confirms that SLAPPs are a widespread phenomenon across Europe, a trend that increasingly affects the wider OSCE region. According to the 2025 Annual SLAPPs Report 15 by the Coalition Against SLAPPs in Europe (CASE) and the Daphne Caruana Galizia Foundation, the number of documented SLAPPs has risen again, with 167 new abusive lawsuits initiated in 2024, bringing the total number of identified cases since 2010 to at least 1,303. In 2024, a notable number of SLAPPs were filed in Italy (21), Germany (20), Serbia (13), Hungary (12) Türkiye (10), and Ukraine (10). SLAPPs have now been recorded in 43 countries, with Montenegro and Andorra added to the map in 2024, illustrating the expansion of the phenomenon into new jurisdictions. While SLAPPs often arise under traditional defamation laws, the 2025 report notes that powerful actors are 15 A 2025 Report on SLAPPs in Europe: Democracy in the Dock

10 increasingly diversifying legal strategies by bringing claims based on data protection, intellectual property or other areas of law to bypass established public-interest defences, increasing the complexity and cost of defence for journalists and outlets. Cases of this kind can impose debilitating financial and reputational harm, even where they lack merit, contributing to self-censorship and a chilling effect on public interest reporting. While SLAPPs often arise under defamation laws, they are increasingly pursued through other legal avenues, including data protection and intellectual property claims, in order to bypass established public-interest safeguards. Such cases impose significant financial and reputational burdens, even where they lack merit, contributing to self-censorship and a chilling effect on public interest reporting. At the same time, responses to this challenge are emerging, though unevenly. At the European level, the adoption of the EU Anti-SLAPP Directive 2024 represents an important step in addressing cross-border cases. In the United Kingdom, courts have begun applying limited anti-SLAPP provisions under existing legislation, including in a landmark 2026 case dismissing an abusive libel claim; however, these protections remain narrowly scoped, and civil society organisations continue to call for more comprehensive safeguards. Despite these positive steps, significant gaps remain. Out of all the SLAPPs cases recorded by CASE between 2010 and 2024, only 8.5% were cross-border cases, illustrating that the overwhelming majority of SLAPPs occur in a domestic context. As such, many cases fall outside the scope of existing protections, and journalists, particularly at the local level, continue to face costly and lengthy legal proceedings without adequate support. I continue to advocate for the adoption of domestic anti-SLAPP legislation in all OSCE participating States, in line with recommendations set out in my Office’s Special Report on Legal Harassment and Abuse of the Judicial System against the Media 16 , and based on practical guidance by UNESCO, the Council of Europe, and the European Commission. Closely linked to this issue is the continued use of criminal defamation and insult laws. I join my predecessors in our continued call for the full decriminalisation of defamation across the OSCE region. Criminal sanctions for defamation are inherently disproportionate and incompatible with international standards on freedom of expression. They carry a high risk of abuse, create a chilling effect on public interest reporting, and can be used to silence critical voices. 16 Office of the OSCE Representative on Freedom of the Media, Special Report on Legal Harassment and Abuse of the Judicial System against the Media, 2021

11 While some participating States have taken steps towards decriminalisation, including partial reforms, significant gaps remain. Ensuring that defamation is addressed through civil law, in line with international human rights standards, remains an essential priority. Beyond SLAPPs and defamation, a broader range of legal and structural pressures continues to affect independent media across the region. In several participating States, criminal provisions related to “false information,” national security, or other broadly defined offences continue to be applied in ways that raise concerns regarding legal certainty and proportionality. Such provisions may be used to restrict reporting on matters of public interest and create an environment of legal risk for journalists. Recent developments across the region illustrate these dynamics in practice. In Albania and North Macedonia, legal frameworks related to defamation continue to raise concerns regarding their impact on investigative reporting. In Kazakhstan and Türkiye, criminal proceedings under broadly framed provisions have affected journalists reporting on matters of public interest. In Georgia and Kyrgyzstan, legislative developments and ongoing court cases highlight concerns regarding legal pressure, procedural safeguards, and the broader environment for independent media. Taken together, these developments point to a broader pattern. Legal mechanisms, whether through abusive litigation, criminal provisions, or regulatory frameworks, are increasingly shaping the conditions under which journalists operate. Ensuring that these frameworks remain transparent, proportionate, and fully aligned with international human rights standards is essential to safeguarding independent media and the exercise of freedom of expression across the OSCE region. I appreciate the reply by the delegation of Kazakhstan, on 20 April, on a specific case that I raised, and I look forward to our continued dialogue. My Office remains actively engaged with all the above-mentioned participating States to address these concerns and support adherence to OSCE commitments. This continued engagement underscores the importance of sustained dialogue and its potential to advance reforms in line with OSCE commitments and international standards. Media Freedom and National Security In an international environment marked by accelerating geopolitical tensions, new technologies, and complex hybrid threats, it is particularly crucial to build a resilience information ecosystem. One that maintains diverse, independent and ethical media, and its core functions, including providing early warning of emerging risks, countering disinformation, and sustaining trust in the democratic institutions on which peaceful and secure societies depend.

12 Strengthening media freedom is therefore a strategic requirement for comprehensive security. Yet, the relationship between media freedom and national security is often framed as a tension, and while many restrictions introduced in the name of security may weaken the very resilience they seek to protect, certain laws and practices across the OSCE region still build on that misconstrued tension. A multiplying number of participating States have introduced legislative frameworks addressing so-called “foreign influence” or “foreign agents.” Such measures exist, in different forms, in countries including Canada, Georgia, Kyrgyzstan, the Russian Federation, the United Kingdom, and the United States. While transparency is a legitimate requirement, in many places legislation tends to include provisions disproportionately limiting activities of media organisations and applying designations that stigmatise media, thereby contributing to a climate of censorship. When formulated in vague or overbroad terms, or when lacking clear and narrow definitions of key concepts such as “political activity” or “foreign influence,” these laws create legal uncertainty and open the door to selective or politically motivated enforcement. Such laws often also include disproportionate sanctions, including administrative or criminal penalties, which may lead to the suspension or closure of media organisations, or imprisonment of journalists. In this context, I welcome the recent ruling of the Constitutional Court of the Slovak Republic, published in February 2026, which declared key provision of amendments to the Act on Non-Governmental Organisations as unconstitutional, removing related obligations and sanctions, and reinforcing the need for such laws to remain aligned with constitutional provisions and international standards. Any such laws and their application should be informed by Article 19 of the International Covenant on Civil and Political Rights (ICCPR), which requires that restrictions on freedom of expression be evaluated under the three-part test of legality, legitimacy, and necessity and proportionality. In some cases, the impact of such measures extends beyond national borders, including through the designation of journalists and media outlets as “foreign agents” or through criminal proceedings targeting journalists in absentia, with a chilling effect on independent reporting, even from abroad. Recent cases illustrate how such frameworks are applied in practice. For instance, during this reporting period, in the Russian Federation, several independent and exiled media professionals have been labelled “foreign agents” or handed down prison sentences in absentia on charges ranging from participation in “undesirable organisations” to the dissemination of “knowingly false information” and actions aimed at “discrediting” the

13 armed forces. In practice, the application of the latter has resulted in the effective criminalisation of reporting that diverges from official narratives. International human rights standards are explicit in this regard: laws must not confer unfettered discretion on authorities, nor be used to suppress criticism of public institutions, including the military. The use of such provisions to prosecute journalists or restrict reporting on matters of public interest is therefore incompatible with these standards and risks creating a chilling effect on independent journalism. Another area of expanding policy responses is on foreign information manipulation and interference (FIMI). While foreign agent laws focus on a person or entity acting on behalf of a foreign power, FIMI refers specifically to the behaviour and tactics used to distort the information space. In this context, it is crucial to build into any counter-FIMI strategy the need to invest in media freedom, as core infrastructure for societal resilience to foreign (and domestic) disinformation. To this end, I would like to mention two national examples in the OSCE region, Ireland and Norway. Norway’s National Strategy for Strengthening Resilience to Disinformation 17 relies on a coordinated, multi-agency approach rather than a single specialized entity, and includes media trust and literacy initiatives. Ireland’s National Counter Disinformation Strategy 18 is aimed at strengthening societal resilience through media literacy, research, and collaborative regulation. It focuses on empowering citizens to identify disinformation, rather than government censorship. I call on all participating States to consult with your Irish and Norwegian colleagues before enacting any such laws. Moreover, in the European Union, the European Democracy Shield, aimed at protecting European democratic processes from foreign information manipulation, cyberattacks, and hybrid threats introduces specific support and safeguards for media freedom. Initiatives supporting media literacy and public awareness are crucial for empowering citizens to critically assess information while reinforcing the role of independent media. In this context, my Office has also been advancing its Structured Dialogues on media freedom and security, bringing together a broad range of stakeholders from across sectors and disciplines. Building on this work, we will be launching a forthcoming publication, “Strategies against Disinformation,” which aims to provide practical guidance on how to effectively counter disinformation, including foreign and domestic information manipulation and interference. 17 Norway’s Strategy for Strengthening Resilience to Disinformation 18 Ireland’s National_Counter_Disinformation_Strategy

14 The publication will place particular emphasis on coordinated, cross-sectoral and interdisciplinary approaches, recognising that effective responses require collaboration between public authorities, independent media, civil society, academia, and the private sector. It highlights that strengthening societal resilience to disinformation is not only a matter of content moderation or regulatory intervention, but also of reinforcing the broader information ecosystem, including through support for independent journalism, media literacy, and institutional transparency. The Helsinki Final Act and the Free Flow of Information Across Borders The principle of the free flow of information across borders remains a foundational commitment of the OSCE. In the Helsinki Final Act, participating States committed to “facilitate the freer and wider dissemination of information of all kinds” and to “improve the conditions under which journalists from one participating State exercise their profession in another participating State.” This commitment was reaffirmed in the 1999 OSCE Charter for European Security 19 , which emphasises the importance of “free and independent media and unimpeded transborder and intra-State flow of information.” At its core, this principle reflects that openness in the exchange of information, including the ability of journalists to work freely across borders, contributes to transparency, mutual understanding, and stability among States. Importantly, this commitment was adopted in full awareness that propaganda and information manipulation already existed. In 1975, despite the presence of state-controlled narratives and competing information systems, participating States understood the power of openness rather than restriction. Today, this principle is increasingly under strain. Across the OSCE region, restrictions on the work of foreign correspondents, including difficulties in obtaining accreditation, visa limitations, and barriers to media distribution, are becoming more frequent. The Helsinki Final Act encourages facilitating mutual access and the free exchange of information. In contrast, we see increasing examples of bans, sanctions, and restrictions. Blocking or restricting media has in some cases become a default response to contested or disfavoured speech. 19 Adopted at the 6th OSCE Summit of Heads of State or Government in Istanbul, as part of the Istanbul Document 1999

15 In practice, these developments manifest across several interrelated areas. First, restrictions on foreign correspondents and cross-border reporting are increasing. These include difficulties in obtaining accreditation, visa limitations, denial of entry, and barriers to media distribution. Such challenges have been observed across a number of participating States in recent years, including a British journalist deported from Türkiye, a Georgian media crew being barred from entering Moldova, and multiple foreign journalists (including Czech, Belarusian, Swiss, British, and French) being denied entry into Georgia. Moreover, the European Federation of Journalists 20 have recently raised concerns about visa restrictions affecting Turkish journalists travelling to the European Union. Second, broader restrictions on access to foreign media and digital platforms continue to limit information diversity. In the Russian Federation, in recent years, some foreign media outlets and international journalism organisations have been designated as “undesirable” or otherwise restricted, while access to major digital platforms, including social media and communication services, has been limited or blocked, constraining audiences’ ability to access independent reporting across borders. At the same time, according to official data 21 , 104 foreign correspondents continue to be accredited in the Russian Federation. Participating States face complex questions regarding state-controlled media that may function as instruments of information manipulation. The decision in 2022 by the European Union to suspend the distribution of outlets such as RT and Sputnik followed the full-scale invasion of Ukraine by the Russian Federation, has since been maintained and further expanded through subsequent listings and updates under the EU’s sanctions framework, including during the present reporting period. As confirmed by the Court of Justice of the European Union, these measures are based on evidence that the outlets actively supported and justified the Russian Federation’s military aggression, including through content capable of posing a direct threat to public order and security, as stipulated in Article 19.3 of the ICCPR 22 . These restrictions were subject to judicial scrutiny and upheld as lawful, necessary, and proportionate, considering the exceptional circumstances. While upheld in this context, such measures still raise important questions for media freedom. Restrictions targeting entire media outlets, even when justified in exceptional contexts, risk setting broader precedents for limiting media pluralism, including through 20 Joint letter to the EU: Current visa policies obstruct Turkish journalists’ mobility – European Federation of Journalists 21 Official data from the Ministry of Foreign Affairs of the Russian Federation: Список аккредитованных шеф-корреспондентов - Министерство иностранных дел Российской Федерации 22 International Covenant on Civil and Political Rights | OHCHR

16 retaliatory blocking measures. There is a general presumption in international law against prior restraint of freedom of expression as unnecessary and disproportionate, on the grounds that it has a chilling effect on the enjoyment of this right. Therefore, ensuring that such measures remain exceptional, narrowly tailored, and subject to review is essential to prevent their normalisation beyond the circumstances that justified them. As one of my predecessors, Dunja Mijatovic, pointed out,” The best and most effective mechanism to neutralize the impact of propaganda is the existence of an open, diverse and dynamic media environment.” The right to seek, receive, and impart information across borders is firmly rooted in OSCE commitments and international human rights law. While restrictions may be acceptable in certain circumstances, they must meet strict requirements of legality, legitimacy, necessity, and proportionality. Measures taken for political purposes, or that arbitrarily hinder legitimate journalistic activity, run counter to both the letter and spirit of OSCE commitments 23 . Technology, Artificial Intelligence, and the Information Environment Artificial intelligence and digital platforms are fundamentally reshaping the information ecosystem across the OSCE region. They increasingly determine how information is produced, distributed, and prioritised, shaping what is visible, amplified, or marginalised. At the same time, generative AI is lowering the barriers to producing large volumes of synthetic and potentially misleading content at scale. While these developments create opportunities for innovation and access to information, they also introduce systemic risks, including the amplification of disinformation, reduced transparency in content curation, and growing challenges for editorial accountability. In a platform-driven environment, the visibility of news media is increasingly dependent on opaque systems that are not subject to meaningful public oversight. Already in 2018, Elon Musk warned that AI’s development will outpace our ability to manage it in a safe way and urged for regulation and oversight 24 . He said, “mark my words: AI is far more dangerous than nukes. Far. So why do we have no regulatory oversight? This is insane.” He also said, “AI is a rare case where I think we need to be 23 2021 OSCE RFOM Communique on the right of the media to freely collect, report and disseminate information, news and opinions, regardless of frontiers 24 https://www.cnbc.com/2018/03/13/elon-musk-at-sxsw-a-i-is-more-dangerous-than-nuclear- weapons.html

17 proactive in regulation than be reactive.” AI poses systemic risks that require guardrails to ensure safeguards, transparency, and accountability. Earlier this year, Elon Musk published the algorithm driving X, and, as some commentators have stated, it reveals “the mathematical engine driving our political divide,” or, more simply, the mathematical equations determining what we see on our social media feeds. The basic equation is “reaction x weighting” so that, for example, in terms of engagement weighting, it appears that disagreement is weighted 27 times higher than consensual interaction. It is laudable that the algorithm is now public, as is the stated commitment to update and improve the algorithm on a regular basis. However, the fundamental business model continues to be based on engagement. In other words, conflict drives profits. This underscores the need for a human rights-centred approach to platform governance. Transparency, while essential, should not be seen as an end in itself, but as a means to ensure accountability, enable meaningful oversight, and safeguard the integrity of the information environment. Recent legal and regulatory developments increasingly recognise that these risks are not only content-related, but structural – linked to platform design, algorithmic systems, and underlying economic incentives. In the United States, recent judicial decisions 25 have begun to address platform design, including cases examining compulsive-use features, the protection of minors, and the role of algorithmic recommendation systems in amplifying harmful content. In the European Union, enforcement under the Digital Services Act has similarly focused on systemic risks linked to platform architecture. Preliminary findings 26 in 2026 indicate that certain design features, including algorithmic amplification and engagement-driven design, may breach regulatory obligations due to their potential harm to users. In addition, the current Big Tech economy has, in many cases, systematically redirected advertising revenues away from news media, creating structural disadvantages for those producing independent, verifiable, and public-interest journalism. Recent legal developments reflect this imbalance. For instance, in Spain 27 , a 2025 court ruling ordered a major platform to pay approximately €479 million in damages to media outlets for unfair competition linked to the use of personal data in targeted advertising. In France, a coalition of more than 200 media organisations has initiated legal proceedings 28 raising similar concerns, alleging that unlawful data practices and targeted advertising have 25 i.e. Jury verdict in K.G.M. v. Meta and Court of Appeals verdict in Anderson v. TikTok 26 Commission preliminarily finds TikTok's addictive design in breach of the Digital Services Act 27 Madrid's Commercial Court ruling 28 200 French media organizations sue Meta for 'illegal practices'

18 diverted substantial advertising revenues away from news media. In Canada 29 , ongoing abuse-of-dominance proceedings in the online advertising market highlights how dominant platforms may entrench their position, inhibit competition, inflate advertising costs, and reduce publishers’ revenues. Without sustainable financing for news media, there is a clear risk that the information space will be increasingly shaped not by ethical and verified news and information, but by opinion, and unverified content. Protecting children in the digital environment has become an increasingly urgent priority. A growing number of participating States, including Austria, Denmark, France, Italy, Germany, Greece, Norway, Poland, Portugal, Slovenia, Spain, United Kingdom, and Türkiye, are introducing or considering age-based restrictions on access to social media. While these initiatives reflect legitimate concerns regarding the impact of platform design on children’s well-being, what is required are effective safeguards, age-appropriate design, and accountability mechanisms that protect children while preserving their rights to freedom of expression and access to information. At the same time, some responses have gone further, including proposals or decisions to restrict or ban entire platforms. In Albania, for example, a year-long ban on TikTok, imposed last year and expired this February, raised concerns among media freedom organisations, including the European Federation of Journalists 30 , which warned that such measures risk undermining freedom of expression and access to information. The ban was subsequently found unconstitutional by the Constitutional Court of Albania 31 , which held that it violated freedom of expression and press freedom and that the authorities had not demonstrated that a general blocking of the platform was necessary or proportionate. Such cases illustrate the broader challenge: while the harms associated with digital platforms are real and require action, responses must remain necessary, proportionate, and grounded in human rights standards. While these initiatives reflect legitimate concerns regarding the impact of platform design on children’s well-being, what is actually needed are effective safeguards, age- appropriate design, and accountability mechanisms that protect children while preserving their rights to freedom of expression and access to information. 29 Competition Bureau sues Google for anti-competitive conduct in online advertising in Canada 30 Albania: TikTok ban threatens freedom of expression ahead of general elections – European Federation of Journalists 31 Decision Note of the Constitutional Court of the Republic of Albania

19 Similarly, there are also efforts to develop more proportionate and rights-based responses. At the European Union level, the Commission has announced 32 that a privacy- preserving age verification application is now technically ready, designed to allow users to prove their age without disclosing additional personal data. This initiative, developed in the context of the Digital Services Act and linked to the future European Digital Identity framework, aims to provide a harmonised and interoperable solution across Member States. Such approaches illustrate that it is possible to address legitimate concerns related to child protection through targeted, privacy-respecting, and scalable solutions, rather than through broad restrictions on access to information. In this context, I would also like to note that the protection of children in the digital environment will be the focus of the 2026 Joint Declaration by the international freedom of expression mandate holders 33 , which is currently under development. This reflects a growing recognition at the international level of both the urgency and the complexity of this issue, and the need to ensure that responses are firmly grounded in human rights, including the protection of freedom of expression and access to information. Approaches to platform governance continue to diverge across the OSCE region. This divergence is increasingly difficult to reconcile with the cross-border nature of digital information ecosystems. Disparate regulatory approaches to what is inherently a global, cross-border information environment risk creating fragmentation, legal uncertainty, and uneven protection of fundamental rights. This underscores the need for stronger international co-operation, including consideration of a shared framework or global compact on the governance of artificial intelligence and digital platforms. In this context, my Office has consistently emphasised that these challenges must be addressed at the structural level, including through our latest policy manual on Safeguarding Media Freedom in the Age of Big Tech and Artificial Intelligence. I welcome that this work is increasingly informing policy discussions across the OSCE region, including its use by the European Data Protection Supervisor, as I learned during recent meetings in Brussels. We continue to engage with participating States in bringing our Policy Manual out of the Hofburg to capitals. 32 Statement by President von der Leyen with Executive Vice-President Virkkunen on the digital age verification app 33 Mandate holders: United Nations (UN) Special Rapporteur on the Promotion and Protection of the Right to Freedom of Opinion and Expression, the Organization for Security and Co-operation in Europe (OSCE) Representative on Freedom of the Media, the Organization of American States (OAS) Special Rapporteur on Freedom of Expression, and the African Commission on Human and Peoples’ Rights (ACHPR) Special Rapporteur on Freedom of Expression and Access to Information in Africa

20 I encourage all participating States to ensure that regulatory responses address these systemic challenges effectively, while remaining fully aligned with international human rights standards, including the protection of freedom of expression and access to information. Independent Media Regulators and Oversight Bodies Independent media regulators play a critical role in shaping the information environment across the OSCE region. They are essential for ensuring compliance with legal standards, safeguarding pluralism, and upholding the public interest in increasingly complex and fragmented media ecosystems. In this context, recent developments across the OSCE region have drawn renewed attention to the role of media regulators and oversight bodies. I am concerned over the lack of independence of regulatory authorities in several participating States, including in situations where political or institutional pressures may affect their functioning. While regulators play a vital role, their credibility depends fundamentally on their independence, transparency, and insulation from undue influence. Where these conditions are not met, there is a risk that regulatory frameworks are perceived not as safeguards of media freedom, but as instruments of pressure. This can have far-reaching consequences, including reduced trust in regulatory institutions, legal uncertainty for media actors, and a chilling effect on independent journalism. These concerns arise in different forms across the region. In some contexts, delays or irregularities in appointments to regulatory bodies have raised questions about governance and continuity. In others, concerns relate to the scope of regulatory powers, the proportionality of sanctions, or the risk of political influence over licensing and oversight decisions. A t the same time, strong, independent, and effective regulators remain a cornerstone of resilient media systems. Ensuring their effectiveness in a rapidly evolving digital information environment is an equally pressing challenge. Regulatory frameworks and mandates must be regularly updated to reflect technological developments, including the growing role of digital platforms and algorithmic content distribution. This also requires adequate resources, institutional capacity, specialised expertise, and sustainable funding. Without these, even formally independent regulators may struggle to fulfil their mandate and to safeguard the public interest in a transformed media landscape.

21 Where regulators operate with clear and up-to-date mandates, sufficient resources, transparent procedures, and effective safeguards against interference, they contribute to a fair, pluralistic, and predictable media environment. Ensuring the independence of media regulators is therefore not only a matter of institutional design, but a core requirement for safeguarding freedom of expression and media freedom in line with OSCE commitments. Public Service Media: Trust, Independence and Sustainable Financing Public service media remain one of the most important pillars of democratic information systems. To fulfil their democratic function, they must be politically neutral, adhere to the highest journalistic standards, be adequately funded, and be protected from political interference. When properly protected from political interference and supported by sustainable funding, public service media provide reliable information, foster pluralistic debate, and ensure universal access to journalism that serves the public interest. Evidence from European Broadcasting Union (EBU) research 34 highlights that strong and well-funded public service media correlate with higher levels of press freedom, greater voter participation, and increased resilience against disinformation and polarisation. Such evidence reinforces the case for investment in and protection of these institutions as fundamental to democratic life. Ensuring that public service media are politically neutral, financially sustainable, and trusted by the public is therefore a core component of any comprehensive strategy to uphold freedom of expression, access to information, and resilience against disinformation across the OSCE region. However, in many participating States there is a growing lack of trust in, and support for, public service media. In some contexts, editorial independence has been perceived as compromised or politically contested, contributing to lower trust levels and deepening polarisation. Addressing these challenges requires transparent governance, legal guarantees of editorial independence, and stable funding insulated from short-term political pressures. Strengthening public service media is therefore not simply a matter of media policy; it is an investment in democratic resilience and social cohesion. This is especially important as public service media play a crucial role in countering disinformation by providing reliable, fact-based reporting, ensuring the availability of 34 European Broadcasting Union report

22 trusted information, and supporting informed public debate, particularly in times of crisis and uncertainty. In this context, it is important to distinguish clearly between public service media and state-controlled media. The distinction between public service media and state- controlled media is not merely institutional, but functional. Public service media are designed to serve the public interest, operate under legal guarantees of editorial independence, and provide pluralistic and impartial information. This requires transparent and independent appointment processes, as well as governance and management structures that are insulated from political interference. It also depends on sustainable and adequate funding models that protect editorial autonomy and prevent undue influence. By contrast, state-controlled media are subject to direct political influence and often function as instruments of government communication. The key difference lies not in ownership, but in governance, editorial independence, funding structures, and accountability. Where these safeguards are weak, formally public media risk functioning in practice as state-controlled outlets. This distinction is essential. Participating States should ensure that their media systems are built around genuinely independent public service media, in line with OSCE commitments, rather than models that risk political influence or control. There are also some encouraging examples where public support for strong and independent public service media remains high, demonstrating their continued public value. In Switzerland, a national referendum in March 2026 saw Swiss voters decisively reject a proposal to significantly cut the licence fee that finances the Swiss public broadcaster SRG SSR, reaffirming broad public backing for a strong and well-funded public media system rooted in all linguistic regions of the country. The election result was widely interpreted as a clear signal of popular trust in independent, high-quality journalism and in the role of public service media in supporting democratic participation and access to reliable information. In Lithuania, too, it was encouraging to witness substantial public engagement in defence of PSM independence: over ten thousand citizens, journalists and civil society representatives rallied in Vilnius against legislative proposals that could weaken the independence and governance safeguards of the Lithuanian public broadcaster LRT, and more than 140,000 people signed a petition opposing changes. In this context, I publicly expressed concern 35 that the proposed legislative amendments could affect the editorial independence and financial sustainability of LRT, recalling that independent and adequately funded public service media are essential to media freedom and the public’s right to information. This position was subsequently echoed by the European Parliament and by the European Broadcasting 35 See: OSCE media freedom on X: "My statement regarding the proposed legislative changes affecting the Lithuanian National Radio and Television LRT

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