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How harmful information may spread if Article 17 EMFA becomes EU law…

Today, DOT Europe has shared a factsheet with over 300 MEPs signalling the possible consequences negative consequences for content moderation arising from voting in favor of article 17 EMFA.

Proposed in September 2022, the EMFA includes safeguards against political interference in editorial decisions, tackles the independence of public service media and fosters transparency of media ownership. Our sector is particularly concerned by Article 17 of the proposal which targets online services and establishes additional obligations on the treatment of media service providers’ content on Very Large Online Platforms (VLOPs).

Article 17 EMFA undermines the Digital Services Act (DSA) by creating a special status solely for media service providers (MSPs) and by assuming the content they will publish online will never be harmful. There is no need to create an additional mechanism in EU law for a specific type of users because the DSA already provides the tools to all users, including media, to challenge content moderation decisions. Article 17 opens the door to a ban on moderating MSPs’ content online and to a must-carry obligation for VLOPs. This is problematic because the nature of the content provided by MSPs can be harmful (e.g. disinformation or inappropriate content for certain audiences).

DOT Europe recommends policymakers to:

  • Reject any proposal that would re-introduce a media exemption, in line with the European Parliament’s stance during the DSA in January 2022.
  • Support the amendments which safeguard the possibility for VLOPs to tackle harmful and infringing content on their services.


See the factsheet: EMFA_Art17_factsheet for plenary

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