MOZOM-analyse
MOZOM analyses: European Media Freedom Act, media freedom or platform gatekeeper?

- Source
- Europese Commissie, EUR-Lex, Europees Parlement, EU-Handvest/FRA, ARTICLE 19/MFRR en EDRi
- MOZOM headline
- MOZOM analyses: European Media Freedom Act, media freedom or platform gatekeeper?
- Original headline
- European Media Freedom Act: media freedom, platform safeguards and the risk of gatekeeping
- Author
- the MOZOM.nl editorial team
- Date
- 8 juli 2026 om 01:06
- Subject
- MOZOM is investigating whether the European Media Freedom Act mainly protects media freedom, or can also create a new gatekeeper layer in which recognized media receive more platform protection than small opposing voices.
Summary of the original report
The European Media Freedom Act, officially Regulation (EU) 2024/1083, has largely been applicable since August 2025. The law obliges EU member states to respect editorial independence, organize public media more independently, make media ownership more transparent, distribute state advertisements more transparently and better protect journalists against pressure and surveillance. At the same time, Article 18 introduces a separate procedure for media providers on Very Large Online Platforms, the largest online platforms under the Digital Services Act. Media that declare that they meet conditions, such as editorial independence, supervision or self-regulation, ownership transparency and human editorial control of AI content, will receive an explanation in advance, a 24-hour response time and priority complaint handling in the event of intended removal or visibility restriction. Officially, this should protect journalism against the arbitrariness of Big Tech. The MOZOM question is more pointed: will this be a fair shield for all serious media, or a gateway through which established, legally organized and already recognized media in particular can access more easily?
Own source research
MOZOM has mainly compared Article 18 of Regulation (EU) 2024/1083 with the Commission guidelines of 6 February 2026. Its own finding is concrete: the law allows media providers to declare themselves as media service providers with Very Large Online Platforms. To do this, they must, among other things, declare that they comply with Article 6(1), are editorially independent of Member States, political parties and third countries, are subject to supervision or recognized self-regulation, have AI content humanly checked and provide legal contact details. A platform must then provide reasons in advance if it wants to remove content or limit visibility, and the media provider is normally given 24 hours to respond. That is not a substantive publication right and no guarantee of ranking, but it is a better legal position than ordinary users have. The MOZOM layer: anyone who already has an editorial staff, lawyers, supervisory relationship, professional standards and institutional status can pass through this gate more easily than a small alternative publisher or citizen journalist.
Striking in this message
The word 'freedom' does heavy work here. The law protects media from political pressure, but at the same time builds new definitions of professional media, supervision, ownership, self-regulation and platform protection. This shifts the discussion from 'are you allowed to publish?' to 'will you receive institutional protection and visibility if platforms intervene?'. That is a quieter form of power, but no less important.
Less visible context
It is less visible that media freedom is now not only decided in newsrooms. It is also determined by search engines, social media, recommendation systems, state advertising, subsidy channels, complaints procedures and reputation labels. If established media have been positioned through public funding, official access, ranking advantage and institutional trust for years, a new media freedom law could inadvertently consolidate their position. EMFA is trying to combat exactly such capture, for example through ownership transparency and state advertising. But the same law can still act as a gatekeeper if small opposing voices are not given the same legal and organizational access to the protected media status.
Possible message behind the news
A possible message is that the EU is trying to respond to real media capture with EMFA. The sharper MOZOM reading: if the established media chain is first made large and credible through money, reputation and reach, a later media freedom law can inadvertently protect that position, while the opposite pole has less platform space and less procedural power. This has not been proven to be intentional, but it is a real risk in operation.
Neutral conclusion
The neutral conclusion: EMFA is legally permitted as an EU rule for the internal media market and is in line with Article 11 of the EU Charter, but its implementation determines whether it truly delivers pluralism. The MOZOM conclusion: anyone who takes media freedom seriously must not only combat state propaganda and Big Tech arbitrariness, but also prevent 'recognized media' from becoming a new fence around the public debate.
Source:
- Europese Commissie: media freedom and pluralism / EMFA
- EUR-Lex: Regulation (EU) 2024/1083, European Media Freedom Act
- Europese Commissie: guidelines Article 18, media content on online platforms
- Europese Commissie: consultation on Article 18 declaration functionality
- Europees Parlement: Media Freedom Act adopted, March 2024
- EU Fundamental Rights Agency: Charter Article 11
- ARTICLE 19 / MFRR: political commitment crucial for EMFA success
- EDRi: EMFA falls short in safeguarding journalists