 Good afternoon to you all. My name is Joyce O'Connor and I chair the digital policy group here at the Institute of Internationals and European Relations. You're all very welcome. I'm delighted to see that we have three audience today. This is a hybrid event to our audience here at Northgate-Georgia Suite. You're all very welcome. Great to see you in person again. We have an audience on Zoom and also streaming on YouTube. We're very pleased to have you all here and you're very welcome. We have a great event today, very lively and I'm looking forward to a good discussion and debate on the issues that are raised by our speakers. And it's as you know it's on safeguarding media pluralism and independence in the digital age, Ireland in context. I'm delighted now to welcome our distinguished guests. Dr Anna Harald, head of the Audio and Media Policy Unit in GD Connect in the European Commissions on our right, is with us from Brussels. You're very welcome, Anna. We look forward to your presentation. And beside, Anna is Renata Schroeder, who's director of the European Federation of Journalists. Anna, you're very welcome. I hope the weather is as good in Brussels as it is in Ireland. It's absolutely splitting the waves here. Very unusual for Ireland, as you know. And here in Dublin we have Dr Eileen Cullity, who's assistant professor in the School of Communications in Dublin City University. She's deputy director of the Institute of Media Democracy and Society. And beside Eileen is Celine Cray, commissioner of the commission, the media commission. So you're all very welcome. And I really appreciate very much you taking the time to be with us today. And it's great to have you here in person, but also online. So each panelist will speak for about 10 minutes, and then we will go to you the audience for questions and answers. Those of you are here in the IIEA, if you can put up your hands. I promise we won't force you to, but if you could put up your hands for either Q for a question or comments. And obviously those online can use the Zoom Q&A function at the bottom of the screen. I very much appreciate if you give your name and affiliation when you're asking a question or comments. That would be really very helpful. Now today's webinar is longer than usual. It's an hour and a half just to let you know that. But what is usual, it's on the record, both the presentations and the Q&A. And if you would like to join our discussion on Twitter using the handle at IIEA, we'd be very pleased. Now today's event is organized in collaboration with the Economic Regulators Network, ERN, a cross-sectional group of economic regulators in Ireland. The ERN is composed of a range of commissions, the Commission of Communication Regulation, the Competition and Consumer Protection Commission, the Commission for Regulation of Utilities, Commission Neman, the Central Bank of Ireland, the National Transport Authority, and the Commission for Aviation Regulation. As we were talking earlier today, and I'm sure if you're listening to radio and looking at other media, our webinar today is very timely. There's been a lot of discussion and recent reports on the topic of our webinar. And yesterday you might have seen the Commission of Neman launch their report, digital news report, Ireland 2023, which was published. And research was carried out by Reuters Institute of the Study of Journalism in Oxford University. And the Irish report was completed by DCU's Institute of Future Media, Democracy and Society. That's a very interesting report. It covers worldwide national and international trends on online news audience, how audience, online audience access news. The whole issue about trust in news and sources, and also the issue of paying for news. It's the largest ongoing study of news consumption in the world, so it's well worth looking at. Our next panel today will explore how media, pluralism and independence can be maintained in the context of digital transformation and against the background of deteriorating media freedom across Europe. The European Media Freedom Act, as you know, is a proposal for a European regulation with the fundamental object to strengthen media independence and media pluralism. It comes with both rights and duties for a whole range of media players. The panel will assess the implementation of the MFA for digitalization of media in both Ireland and Europe, and also consider how the EFMA may interact with other digital policies. And those of you who are here will know there's a lot of digital policies, a lot of regulations, and that really, you know, poses a big challenge. Our guest speaker and our first speaker is Dr Anna Harald. Anna, you're very welcome again. Anna, as I've said, is head of the Audiovisual and Media Policy Unit at DG Connect. Anna has worked in the European Commission since 2003, dealing with the media, audio visual, telecommunications policy, as well as competition law. She's previously served as a member of the Cabinet for the Digital Economy and Society Commissioner Gunter Ottener, and prior to that she was with Roberto Viola in DG Connect. She has published widely on media, law and policy, international law and competition law. Anna, we look forward to your presentation. Thank you. Thank you so much. I hope you can hear me and see me well. It's indeed equally hot in Brussels, very unusual, which makes our work on the European Media Freedom Act even more complicated, if you want, because as you might know, we are now in a very particular phase and delicate phase for the adoption of this crucial legislation from the point of view of the European Commission, the Media Freedom Act that you have already introduced, and thank you for that, because the Member States hopefully next week will agree on a common mandate to start negotiations with the other co-legislators of the European Parliament, hopefully in the autumn. It's, as I said, a great pleasure and also it's extremely interesting that you put the today's discussions in the context of the digital transformation, which is an angle that sometimes I have the impression is a little bit overlooked in our Brussels discussions when we look at the European Media Freedom Act. Of course, it is beyond any doubt, and you have said it, that the genesis or the backdrop of the adoption of the proposal in the Commission is, of course, the situation, the overall situations, the deteriorating situation in terms of media freedom across the European Union. And we know that there are significant differences between the Member States. This is shown, of course, this has been pointed out by, for example, reporters without borders already for many years. So we have seen this unfortunate backsliding now in this kind of leading role of Europe as the bastion of media freedom, if you want. And the European Commission, as you know, has also started looking at these issues more closely as part of its rule of law reports where media freedom, media pluralism, media freedom is one of the three pillars that are being looked at in terms of the situation across the Member States. But, and this is why I think that this discussion is particularly timely, when we have started discussing about this new piece of legislation within the Commission, we really looked at it, precisely from the perspective that you are taking in today's debate. Is there anything, is there anything that we could still do for the European media sector that is needed in order to better face the digital transformation, because I think that was a little bit the missing puzzle in all the regulatory aspects that we have already undertaken before with the revision of the audio visual media rules with the Digital Services Act and the Digital Markets Act. Are we, we have asked ourselves, have we been paying enough attention to media pluralism in the digital context, and the digital aspects of MFA. Because you know it's been a bit of a common thread, if you look at the recitals, I think it's very, it's very visible that the whole thinking about the primary objectives of these legislations which are obviously to, to protect first and foremost editorial and in general media independence and of course, by that also pluralism in the, in the, in the media markets have been really to see how we can also help the media and help us, the viewers, listeners, readers of the news media to have the, to continue to have the best possible media offer at our disposal when we inform ourselves in these completely changed environments, of course there has been you know so much discussions and development so I will of course not everything it's common knowledge you know that we are kind of living in a completely transformed environment in terms of access to media content. The idea and the kind of common thread of the media freedom act has been, can we do more in order to ensure this media independence and media pluralism for European citizens. And so, I think that it's useful maybe a bit zoom in on those provisions that are precisely trying to respond to these challenges in the digital environment, while of course not forgetting about you know the primary goals and pretty sure that Renate when she will be talking refer let's say to the core of M5 you want which is of course about protecting editorial independence of the media, protecting journalists, protecting specific media that are particularly close to the state like public service media and also avoiding favoritism, for example as regards the allocation of state advertising so of course this is the core, if you want, of the media freedom act, but since you have chosen this digital topic I would like to zoom in a little bit on the more digital aspects of this new piece of legislation and I think I would quote probably the three main provisions. I think that probably will not be a surprise because this belongs also to those that are mostly discussed most hotly debated now in Brussels. The first, obviously, will be the additional guarantees that we try to provide to reputable professional media. These are the relationships to the very large online platforms. In particular, where the content coming from such professional reputable media might be blocked, removed as potentially incompliant with the terms and conditions of platforms. And of course a lot of debate on this topic already previously in the context of the adoption of the digital services act. The reason why we have come back to this topic in the media freedom act is because we have, of course we have discussed this with the colleges latest at the time of the dsa adoption and it was the decision of the colleges later is not to include any provisions in this respect but the reason why we thought that now the situation has been different and that we cannot simply put it leave the European Union without answers on this important issue from the point of view of access of citizens to professional media content online is that precisely the, the whole framework that we are trying to create that has been put in place with guaranteeing the editorial independence of media would allow us now also to make sure that there are enough guarantees that the content coming from such media will genuinely be produced in line with the professional standards the journalistic standards we so much cherish here in Europe. And so that is a bit maybe why we have come back to this important topic and anyway, our thinking is that of course, we would like this new digital actors that have become so important in some sort of gateways to content for for all of us in today's consumption of media. So of course we would like them, and this was the primary and remains the primary objective of the legislation that has been put in place with the digital services act to identify and address all the systemic risks that you know that the dissemination of content online might pose. So of course we want to continue the platforms to act diligently or start acting even more diligently than maybe they have done so far. But at the same time, what we care incredibly about. I think here in this part of the world is that media freedom in a way should be the default, and it should not be necessarily the private companies that should decide which content is how should I put it not to their liking. If it's not compliant with the terms and conditions so that has been a bit the background of this of this provision that has been hotly debated and it will continue to be hotly debated of course. And between the stakeholders and of course by the colleges latest. I think what is extremely useful to note is that the whole discussion I have, I have, as we have seen it now evolving. I think gradually embraced I think what was the logic that I was trying to explain of the Commission's proposal. There is of course a lot of discussion on this on the, on the, you know, who can qualify for this privileged treatment by the platforms in terms of professional media. And that, in a way goes precisely, you know in the direction of the Commission's proposal so we are very happy to see this discussions and, and the evolution maybe to try and to tighten up even more the safeguards that that we have foreseen. But first there is an ongoing discussion also on the scope of the, of the, of the, of the actual privileges, where I think that from the Commission's perspective will be extremely important that we sort of try to strike the right balance between these efforts that were mentioned in by the platforms and obligations under the dsa specifically and in particular as regards this information because of course we are talking here only about potentially harmful content this is totally without prejudice to of course anything that might qualify as illegal content. It will be very important that we strike the right balance and make sure that these two pieces of legislation that have very different objectives if you want, but can work harmoniously together. There are two other provisions that they want to mention that the discuss maybe a little bit less, but for us have been a very important part of the mix. One is what you can find an article 19 of our proposal, which is the right of customization of the in our proposal audio visual media offer. And then there is also an important provision on audience measurement that might seem extremely technical, but it's also incredibly important in our view to make sure that we are preserving the right conditions of access to content on the one hand but also of production of high quality content and diverse content for the benefit of all of us. So, as regards the customization of the media offer. This has been an attempt from our side to counteract the yet another trend that has become very visible in the way that the offers media offers are being presented to us. And all of course, including accessing our content via the either, you know, all the sort of interfaces, either on our smart TVs or other devices. And it is very easily, it is, it's much more, it is, it is much easier for us to be locked, if you want, into and also directed or not into consuming certain types of content as opposed to other, as it used to be before. And I think there is a little bit of a paradox, if you want, that while this seems to be that the, you know, the access opportunities to content of course have exponentially increased with the digital revolution, but we are kind of experiencing a mix with that often even realizing that this is the case. And this is what our provision, you know, tries to at least partially address by mandating for manufacturers and producers of of all these interfaces and devices to make progress for the users to freely choose the configuration of the content that appears, if you want, on the home screen when we open whatever device we are accessing our content from. That is probably, you know, an aspect that has been discussed a little bit less, but I think in the, in the future we will hear even more about this, and it really boils down to this debate about whether we, you know, want to have, you know, the right provision of appreciation and on maneuver when we are deciding what to watch, listen or read as opposed to what is being decided by the commercial agreements between those that provide us with accent access to content. But at least this provision on audience measurement. And it's also extremely important, I mean audience measurement has been, you know, hasn't been a particularly sexy topic in media regulation so far, because the industry has, if you won't sell regulated itself very successfully. It has changed in the online environment because of this development of the proprietary methods of measuring audience that, you know, can easily be manipulated and can have an enormous impact on the way media content providers plan even their content production. And not to speak that of course it can have any impact on their advertising revenues as such. And by the way, as you know very well audience measurement is also something which is extremely important for actually knowing the level of media pluralism and the market. So of course if we allow, if you want developments in a direction whereby, you know, it is controlled again by very powerful players in the market without much transparency. It might become increasingly difficult for us to assess what we would think from the public policy perspective as an appropriate level of pluralism in the market. This is why we have introduced the requirements for audience measurement transparency in the media freedom act. And we sincerely hope that once in place this new requirements will lead to let's say will direct the market into a direction that in the end will be much more conducive to much more open, much more conducive to for all the media players that in particular the media service providers to invest in, you know, with the full let's say to make informed choices when they are investing in content. So I think that these were the two provisions I wanted to a little bit zoom in, I will still if you allow me two more minutes want to say a few words about another aspect that is probably less discussed but I think equally interesting from the perspective, say from the digital perspective that you are now kind of looking at on media pluralism issues today, which is the provisions that we have in the proposal on cooperation between media regulators. And we have, I mean, if you look at the media freedom act you will see that it is a piece of legislation that of course, and deliberately stays on a very much principle based level of harmonization because of the sensitivities of the issues of course for the member states. And also sometimes difficulties in regulating media pluralism that I think everybody who has been involved in those regulatory debates know very well about. At the same time, we are building a very strong institutional, if you want, framework by trying to draw on the experience of independent media regulators that are the only ones. I think that we have that know so much about media regulation regulation and in particular about media pluralism in Europe and are independent show should be at least independent according to the to the provisions under the individual media services directive. And so, of course, where we also can make a difference in case there shouldn't be you know the required level of independence in one particular case, and can do two things. On the one hand, provide with the right type of advice when things go wrong in the media market I'm pretty sure and I will say a few things about it. But also, and this is extremely important, look at the media regulation, also from the media pluralism perspective, let's say, from the European, from the European level. Of course, we are talking about, you know, media regulation Ireland and Celine knows that very well. And of course, it's a little bit how they put it in the limelight now know especially as regards the new rules of the audio visual media services directive, because of the country of origin principle and the fact that many of the new online players that we are trying to regulate will be under the responsibility of the Irish regulator. So, this is of course, the principle, and this is how we have imagined Europe know on the basis of mutual trust, and the fact that of course we can rely that if there is robust regulation and one member states, then there can be freedom to provide services at the same time. It is of course undisputed that these players that we are talking about the video shame platforms or you know as they are now some of them will be also the very large online platforms under the DSA players that are so important for all the member states because they provide services of course everywhere in Europe and beyond that I think it is unthinkable to think of media regulation and something purely national. So there has to be a forum for discussion and, and the more formalized framework of cooperation between the media regulators in Europe and this is what we are trying to do also with MFA that the regulators can talk with each other when that there is a specific mechanism for ensuring that these new obligations on video shame platforms work well under the ADMST, but also, and this is also extremely important, take common approaches or even decisions as regards maybe certain third country providers that distribute their content in Europe, but do not necessarily abide by the same standards that our media providers do and this has been of course acutely felt recently in the context of the Russian war in Ukraine. So, I think that with that I leave the other speakers to complement the picture but these were the provisions I wanted a little bit to zoom into and I wanted only to stress again how grateful we are to be involved in those discussions and of course how important the Irish contribution to this debate is because I think of the particularly positive developments I think in the in the Irish media market and the approaches to media pluralism that of course we would like to somehow, you know, now to draw upon and and promote with the new legislation legislation once it is in place. Thank you. Thank you very much Anna. I think you've given a very clear overview of the European perspective and the issues and challenges that are there, but you have asked a very fundamental question, is there anything we can do better to address digital transformation in this area. And I think you've highlighted some of those key issues. I'm not going to summarize what you said but I thought it was very interesting that you emphasized institutional cooperation and institutional framework and also the fundamental value of freedom of media. I think they were really key points that you've made so thank you very much for for your presentation. So we'll come to our second speaker, Renata Schroeder, Renata you're very welcome again, and Renata as you know is the director of the European Federation of journalists. Before joining the EFJ, Renata worked in the UN in New York and the fast research center in Berlin, and in the Frederick Ebert Foundation in Brussels. And as the director of the EFJ, her work covers a wide range of activities. You're a busy lady, Renata advocacy at EU and Council of Europe level international meetings, fact finding media freedom missions, and she also works on a range of expert groups covering areas such as media literacy and broadcasting, the role of freelancers and digital journalism. Renata, we look forward to your presentation. Thank you very much. Just, I may add that it's been almost 30 years that I've been working now for journalists for journalists unions and associations because unions and associations at national level are our members we are working for and we have members in all EU and Council of Europe member states and I think it's very important because we are, we say the one and only but the main journalist federation representative in that sense and also a member both of the European trade union federation, but also of the Council of Europe steering committee and others. And indeed I'm very busy and partly thanks to Anna Harold and her team who has done excellent job I think specifically this last European Commission has woken up to the challenges that I will explore a bit more on media freedom on on journalism and understood what is at stake. Indeed, it's not only pluralism it's not only the right to know it's not only the rule of law. It's not only democracy. It is European integration at large and I think we all have a vested interest in working on that together. First in my hopefully brief presentation, repeat maybe a little bit more the challenges we the journalists at regional, national and local level are facing, then come also regarding the European media freedom act, highlight a few other issues on on the media freedom act Anna already referred to me she knows what our most important concerns are to finish with some conclusions specifically relating to enforcement mechanisms. So, yeah, as, as you can imagine, we are fighting not only myself, but our members on all levels to infect a restore an enabling environment where journalism as a public good can play its fundamental role of a watchdog. And here we also appreciate it that not only UNESCO saying information is a public good but also the Commission in the M for has stressed their term that it is a public goods and public goods need protection from all sides. So, in general journalism today, maybe more important than ever, as it allows giving the voiceless a voice as it engages with different audiences reaches out when enabled with new forms to the young and in different groups with new forms sorry, promoting social conclusion inclusion by that in particular at local level to the ever more diverging and unfortunately polarized audiences. All that, however, is possible only if the legal and financial framework enables journalists to do the work they are best at searching the truth researching analyzing going in the streets, covering wars, but also being constructive and not only work within the 24 hours news agenda. People are used to and are getting very tired of news avoidance has been a term used by media researchers and you referred to the Reuters report which just came out yesterday and news avoidance among us is a big issue we all have to take very seriously. And we have to make sure that public interest journalism is not becoming only a niche for the few and for the rich, we need to replace what we were used as in terms of mass media, we don't have that anymore. We are going digital, and we have to make sure that journalism as a public good is secured in the digital world with new and potentially dangerous players. So in recent years, as I said, we face many challenges and I'm sure you all from your national level have others to add. The most important one is the lack of a business model for independent journalism. And here, we cannot only blame the monopolies, the internet platforms coming from the US, but of course, they don't help. And also the increased control by politicians, including really harsh media campaigns in Trump style, unfortunately now also in European member states. Media capture physical attacks precarious working conditions attacks against protection of sources, due to increased surveillance of the states are not helping. Anna rightly said, we have very different systems within the member states, I think Ireland is one of the better one of the best, but some of the southern more century eastern countries face serious problem. However, we also know there is no member states without any problem. So we have to be very careful. This digital transformation the rise of the platforms to information monopolies at not no costs, but attention economy driven business models, often prioritizing this information, and not only as Anna said, those by third countries. And the clickbait journalism, which goes in that direction has indeed not helped the state of independent journalism today. It's not too late but hopefully not too late the cure and European Commission has understood the challenges, as I just mentioned, and delivered quite a bit in these last years. And the latest one has been the draft of the European media freedom act which was published on in September last year. I will not go into the details either on the DSA on the DMA, but also other developments regarding slap strategic lawsuits, which are also increasingly led against journalists and the order visual media service directive, which have all been very important and have to seen be seen in a more holistic way. So a few words on the proposal. First of all, I think it's important to say that the FJ has welcomed the draft regulation by the European Commission, specifically also as a political symbol, and knowing how difficult indeed it is to touch about media issues. As I said before I've been working 30 years in this field. I started when we had a green paper on media concentration. It got close but in the end it failed due to some media modules which are called Robert Murdoch, unfortunately it's still there. Robert Murdoch and Berlusconi who just passed away. And I'm very surprised by the media now making him a hero. For me he was a criminal but this is just a side sentence. So, yes, indeed. We have a proposal here we all know it's not easy, but we have to be ambitious. It's now or never. We told the Commission for us this draft is not ambitious and not enough. But of course we understand there are many, many different interests to to take care of. But our work and that's I think why I have been terribly busy in these last seven months has been trying to improve it specifically on the issues which are dear to journalists and journalists freedom, which is and I'll tell you in a nutshell there is for once article four dealing with protection of sources and protection from surveillance spyware Pegasus you name it. And five, of course, as Anna said very important the independence of public service media, but also the financing of it ever more under the attack in almost all member states I would say, and for us article six which is dealing with media transparency and contemporary independence, which I have to say something fiercely attacked by not all but many and the bigger press publisher groups who for that very reason called the media freedom act and unfreedom act, which I think was based on disinformation that the Commission would try to control content, which is by no means included. But this, I'm just giving this example because I show was the level of distrust, when it comes to any attempt or draft, in this case by the European Commission to deal with media freedom issues, the level of distrust we also heard with members of the European Parliament of national member states afraid that the Commission is taking over. And I found that particularly disfrustrating reading the text because I know the Commission was extremely careful not to go into this direction. But that's why we face so many challenges and I will come up with. Maybe some ideas how to get rid of that. So, just in a nutshell, the most important points for us are the need to adopt a forward looking inclusive definition of media and media service providers in line with international standards and explicitly include journalists. I believe that as it is defined now I think it's based on the copyright directive is not far reaching and modern enough. It should also include non commercial media actors and and all kinds of new forms, including journalists, who are fulfilling of a public function and who work within ethical lines. We always refer to the Council of Europe because the standards giving there are in our view, the best ones. We wanted to have an improvement regarding protection of sources of journalists and deployment of any spyware to be in line specifically with Council of Europe standards which we found the Commission proposal has not been. We are in our view a need for more binding common and clear rules on transparency of media ownership to ensure meaningful transparency, which is so necessary to have more trust in journalism. We also asked for strengthening of safeguards of the independence of national regulatory authorities. It is true that the issues of independent national authorities has been dealt with by the audio visual media service directive. So they it's been tried to get the implementation of this independence into that and agrees, I'm sure, unfortunately, this has not happened yet that I have to also congratulate the Irish media regulatory authorities sorry I'm not using the right it was a bit late but I think they have done a great job and it's a good example now to show how to also deal with the new challenges, but also the the challenges regarding resources I've heard that actually you would need much more resources to deal with all these issues. It just shows that it's not only political independence, but the governments have to give the researchers needed for the additional work to be done as well. And then we also asked for maybe a more specified assessment of public interest tests when it comes to media mergers as a minimum action by the board to include civil society and professional organizations in there. This is in our view pivotal to fight media capture by media moguls and oligies and also to help the boards and the commission to to have more enforcement I get to that later. And of course, as I said the need for enforcement which probably is the most important point because we feel as the media freedom extends now. As we said it's very much based on principles the board in the end has no big role so that's why we also don't understand all the fuss around it. So the question is how can we make sure that existing EU legislation and what's supposed to be regulated through the MFR can be better enforced. Just to give you a few frustrations from the work up to now, because we really hoped that was the help of the co legislators, the European Commission, the European Parliament on the one hand and the Council of Ministers. On the other hand, we would be able to improve the draft. There has been a first compromise text now out by the Council of Ministers which is supposed to be decided upon next week. They are very ambitious they would like to get something seriously done by another Swedish presidency. And I'm saying that time is not on our sides we all would like to get this act to be adopted prior to the next European Parliament elections. I don't think I have to say why. Unfortunately, this article for I mentioned before, which is so important for us on protection of sources has been considerably watered down, specifically due to a non paper, which had been proposed by the French government, I think Macron is behind it to put national security above media freedom, above protection of sources. And that for us is is a big blow. It's a really, really big blow and we will, we already wrote the press release but we will come out on Monday with a letter to many, many civil society groups, digital rights groups, media freedom organizations, all members of the EFJ saying to the ministers, you cannot say you are defending press freedom and at the same time showing that national security is more important. We understand national security is important specifically today, but we have to keep it very precise and put it in our view, media freedom above on this very issue and stand specifically in line with the court of justice of the European Union, which has been mentioned here that the mere purpose of safeguarding national security cannot render you law in in a political and does not exempt member states from the obligations to comply with the rule of law. If we lose that I think we lose it all. It's not really so bland, but I think it's very important. On the other side, more from the European Parliament, we have been concerned that article six, which, as we said before, 61 deals with transparency and 62 deals with internal press freedom with editorial defendants in that way more from the owners or from advertisers, which as we have seen through a lot of research and interviews with journalists is something on the rise and self censorship has been the response by many journalists and it's not only in those countries where we have media capture where we have oligarchs and politicians doing media only for their own interest, it, it, it also happens in Germany and in other countries. And that reason we find we really need finding rules that that protect journalists, and specifically that gives editors in chief, the strengths as the first journalist protecting their stuff and protecting the independence of their content. And here we are a bit concerned that the reporter of German reporter of the European Parliament has been very much influenced by some certain publishers. And what we have then now is makes it completely useless. She adds liability clause she adds the the over rolling editorial line with that many of our members now already say well why then having the European media freedom act so that is a big challenge. There's a lot more to say but I don't want to go into details of all I think it's also difficult to follow special specifically for those who don't know it. Very often when we talk to journalists and ask them why don't you write about it. They say well it's so complex. It takes so much time we don't have it. And that's one reason why there's not enough in my view news about this very important development, which is actually of concern to all the journalists they should be writing about. I mentioned article 17 on content moderation which indeed is probably the most disputed article. We think it's too much there it is important absolutely for us it's not the most important one but what we have there at the moment post in the Council and in in the Parliament is not so bad. There are still challenges we can discuss it later I don't want to go too much into the details now, but as it's rightly said, illegal content is being dealt with the DSA. And it's very important to be complimentary here. And now we have to see how the DSA is being implemented how it works, and there are a lot of questions we all don't know. That's why I think to write something decent on article 17 is not an easy one. So to finish just a few words on enforcement. As I said before, in our view these proposed tools do not have the potential of making the already existing enforcement tools specifically regarding the other visual media service directed more effective. If joined by several media experts argue that the proposed tools failed to effectively improve the already available enforcement sorry I'm repeating myself. And we think that all decisions of the board and the Commission should be supported by a wider consensus of experts and stakeholders, it could be yet another high level expert proved. It would help to create more trust, as we said before trust is missing trust is missing between the different professional groups between the regulators between the governments the Commission and all that. And to have a more inclusive approach could really help to, to make this very complex EU governance on media policy not only more transparent, but also more efficient. I think that's that's it for for the moment. Trust, I want to finish it, we need more trust, we need more trust in journalism we need more trust among institutions. And I think I don't give up yet. I still hope we're getting something decent we can all be proud of when we finish it next year, but I'm not sure. Thank you very much for that. I'm absolutely sure you haven't given up on yours. You'll still go on and thank you for raising that issue about ambition and vision and the importance of that. And I think I won't summarize what you said but I think there's a critical issue here that perhaps we haven't talked about. And that is awareness that people's awareness of that regulation and acts that are going through Europe are critically important. And that's where the media does have a role to help people understand what the issues are, what's happening. So that's something I took out of what you said as well as your very clear frustrations on things that needed to be done but I think you've made those points very clearly and thank you very much for that. We're moving back to Dublin and we've had to both Anna and Renata have given great praise for what's happening here in Ireland and we have two speakers here have been actively involved in this. And our first speaker here in the IIA is Dr Eileen Cullerty, who is the assistant professor in the School of Communications and DCU and Deputy Director of the Institute of Media, Democracy and Society. Eileen coordinates that the Ireland hope for digital media observatory, and she's Vice Chair of the Media Literacy Ireland, a member of the Board of Management for Europe Training Network harnessing digital data technology and journalism. Dr Cullerty has published widely is an award-winning researcher, her research examines disinformation, digital governance and the media, and her latest book co-authored with her colleague Jane Souter is disinformation and manipulation and digital media, which is published by Russellage. So Eileen over to you and thank you very much. Thank you very much for the kind introduction into the IIA for the invitation. So at the DCU Fuji Institute we work on a lot of projects that look at the changing media landscape and the implications of that for democracy. For example, and I had to list them out. We are the Irish representatives for the media pluralism monitor, the media ownership monitor, the local media for democracy monitor, the European Digital Media Observatory and the Reuters digital news report among others. And what all of those projects do is they put Ireland in a comparative context. And that comparative context can be really interesting because it allows us to get some perspective. So for example the Reuters digital news report which is funded by Commissioner Neiman was published yesterday, and it found that people in Ireland are more trusting of news than the EU average. Or the media pluralism monitor that was published last year ranked 32 countries for their risks to media pluralism and Ireland was the low, the ninth lowest. So in general, when you look at those comparative perspectives, things in Ireland seem quite favorable. Of course, one of the challenges when you do that comparative work is that we can become very complacent and we can start to take things for granted and assume well things are far worse in other countries so we don't really need to worry about it. The media pluralism monitor reports that came out last year my colleague Dr Roddy Flynn writes, though professional journalism norms, generally ensure editorial content is not shaped by commercial or owner influence in Ireland. The absence of overt rules requiring this remains a concern. So editorial independence has not really been a major issue here because of journalism norms, but if it were to become an issue and in a kind of volatile changing media market there's no reason to assume that it won't. There has not been any kind of legal framework to support media. And in many ways that lack of recognition for the importance of editorial independence for pluralism for media freedoms generally. It's actually very surprising. For those of us who work in media who teach it research it are regulated. We spend a lot of time talking about the democratic role of journalism, and the role of journalism as a fourth to state and about holding power to account. So when you think about it is actually quite strange that we haven't got any of that well enshrined or backed up by by robust legal frameworks. And it's in that context that I think the European Media Freedom Act is really necessary and very welcome and we should probably have had something like this quite a long time ago, because it finally gives that recognition to media as a pillar of democracy. And might disrupt the kind of media capture that we see in some countries, and then it might also force more complacent above average countries like Ireland to actually start taking that democratic role far more seriously than they have. So I would just like to make a few observations about the act and the maybe specific challenges for Ireland and media, and obviously that the act sits alongside, as Renata mentioned these these other big developments like the DSA the anti slap directives and the recommendation on the safety of journalists but allowing all of that. It picks up a lot on what Renata said there that there's a major issue at defining public interest media. Because in our digital media landscape, I think that's the most essential thing to do because the nature of media is changing and what we think of, we inherited all these ideas from a historical system. That's now being disrupted and changing. We're not entirely certain what the future is going to be. So we really ought to be defining what are the things we really want and value. The act refers to media service providers but that's a very, very broad term. And when you consider that the barriers to becoming a media producer to setting up the media outlets have never ever been lower. I think we need to be much clearer about what we want to protect. Renata mentioned you know about media that are professional and reputable but I mean those are value judgments, and a lot of people, the idea of who is a professional now is in flux anyway across a lot of sectors. So I think that's something I'm not saying that the act, or maybe it should be in the act I don't know but I think we need to be much clearer about who isn't isn't included there, especially when we're seeing such a rise of opinion driven websites and social media that claim to be doing journalism but they're, they're clearly not. And I think that definitional issue is also at the heart of some of the lobbying that's come from the publishing industry, which is a huge part of the DSA and is now following this. Because what needs to be protected is not the publishing industry. I mean, I don't think there's any duty on any of us to care about the future of the publishing industry in itself what we care about is public interest journalism. And, and beyond that media that serves, if you think of an Ireland, we have our distinct culture and heritage media that serves that and acknowledges that that's valuable, who the specific players are as far less interesting, I think. I think a second big issue is about the funding of public service media and this is of course critical in Ireland. So the act has specific provisions to ensure editorial independence. And it seems kind of clear that those were designed to target countries for public service media has been captured by political interests. I think in Ireland we've had the opposite issue where public service media has not been captured it's been completely abandoned by political interests. So successive governments have ignored or to ease please to reform the license fee. The government ignored its own future of media commission, which gave its main recommendation was to introduce a new funding model, and that recommendation was ignored. So when the against that history of neglect article 18 of emphasis that it is necessary to guarantee that public service media providers benefit from sufficient and stable funding to fulfill their mission. And I think for us in Ireland we need to ensure that that actually is something that the government prioritizes and take seriously. Incidentally, a number of research studies have shown that the countries with stronger public sector media tend to be more resilient to disinformation. So, as was already mentioned, public service media is under attack everywhere, and we really need to be defending it. The third major issue and particularly here in Ireland is defamation and the slap cases so the threat of defamation has always been a massive issue in Ireland because of our very particular defamation laws and the fact that those cases are heard in front of And recently the journalist Naomi O'Leary compiled a report for the International Press Institute and she wrote legal intimidation affects the full range of Irish media from the smallest shoestring podcasts and magazines to major broadcasters and the people she interviewed described you know suppressing or quelling stories on things like the housing crisis, sport sexual abuse and just day to day politics. This is obviously a massive massive problem. Now the EU anti slap directive is about cross border cases, rather than domestic cases. So again we have to look at our own defamation laws which is currently being debated and making sure that that is fit for purpose and that does protect media freedom. And finally I think there's just the fundamental hate to absolutely you use the phrase but the elephant in the room and that is the financing of independent journalism like there's no getting around it. We inherited a commercial media system so leaving aside public service media we inherited a commercial media system that was based on the fact that there was finite resources, a limited number of media outlets were able to command massive audiences advertising revenues on that and fund things that are very expensive and time consuming and not the most popular by confess to get a journalism that could be funded because there was lots of money to be made another stuff. That system is broken and it's not coming back. And that's the issue that we need to address. And that's why I think it is crucial to focus on public interest media. Those are the bits we want to see how they can be funded. The other stuff is, you know, it's of interest in other ways that the critical part for democracy is who is funding the public interest media. In the introduction to the action of there's references to her how you funding could do this it's obviously not sustainable that the EU could be funding public interest, not also desirable. In Ireland with the some of the recommendations coming out of the future of media commission that are now being implemented look at funding for funding a broader range of public interest media so not just broadcasting but also grants for courts reporting grants for Irish language reporting things like that. I think we need to be much more open about the model we're moving towards to get that type of valuable content done, and being upfront about it and how you secure independence in this context so if you move to a grant system where somebody like commission the man now has to evaluate grants well how do we ensure their independence. So I think the media freedom act is very welcome. It's fantastic but we need to keep zoning in on securing public interest media. Thank you. I think you've made a very clear presentation of the issues here in Ireland, and that we have to be careful that we're not complacent. And I suppose we've all heard please for more funding. But I think the context that you're putting it in and what the act now is is looking at is absolutely critical in terms of public interest media. So that's very critical and thank you very much for that. So the speaker then is Celine Craig is the broadcasting commissioner with common man who was established last March and and Celine is one of four commissioners. This is the policy and regulatory area for broadcasting media and on demand service prior to working and to taking up a role as commissioner. As you know Celine was the CEO of broadcasting authority of Ireland with over 30 years experience in the media regulation she also worked with all of the BAI predecessors which I won't go into. She has played a senior leadership role in strategic planning for legislative institutional structural change in Irish and European media regulation regime. She's one of the four principles involved in the establishment of the Irish digital regulatory group, and one of the four regulations establishment of the global online safety regulations network in 2002, and she's chaired the European platform of regulatory authorities. She's an active participant in a range of national European and global forum on legislative and regulatory matters in the audio visual and online safety fields. And we look forward to your presentation. Thank you very much, Joyce and good afternoon everyone. And thanks indeed to the IEA for the invitation to address this important piece of legislation. I've been asked to give a regulators perspective on the European Media Freedom Act. And as some of you know I've been involved in media regulation for many years. As a result of that I suppose that the core of my work has been the pursuit of the objectives of media regulation, which in a nutshell really concern, providing diversity of content for audiences, and ensuring plurality. And the promotion and protection of freedom of expression, I think is also with the core of media regulatory work, and together with providing a media environment that promotes and sustains independent and impartial journalism. And I've heard the core objectives of Irish media regulation, and they have been there since the very outset in embedded in Irish public policy, and indeed very much embedded in the remit of the new Commissioner Man. And it might come as any big surprise to you that I'm a very strong proponent of the European Commission's proposal for regulation on media pluralism and independence. However, just given that comes soon is a newly established regulation is currently defining and elaborating its policies and objectives. I'm not proposing to get into the weeds of the details of the legislative provisions, the provisions. Although we are very much engaged in that, particularly with our European colleagues. What I would like to do is to give a high level and view from a regulatory perspective of the policy objectives underfinning the proposal, and as well as an assessment of the Irish regulatory environment and our readiness to embrace and indeed implement the regulation when it comes into force. And probably, as I've been sort of just a very into there I think the first thing to say is that the important principles that underprime the regulation are not new. And these principles have always been central to protecting plurality and liberty of expression. Very particular threats facing Europe as all of the previous speakers have have have alerted us, and the ever increasing cross border nature of the provision of media services the distribution, and indeed the consumption of media content. The principles take on a very addicts added significance and importance. I believe in the digital media age. I think the European Union's ambitions to be a strong free safe and democratic Europe can only be achieved if we've a strong free safe and democratic media environment that promotes and reflects fundamental European values. But, but as again has been has been said earlier, the European media sphere is under threat and the finding of European commissions and annual rule of law reports and the CNPF media pluralism monitor and identify many of the associated risks to the European media pluralism environment, including not only the sustainability challenges that are facing some of our traditional news media, but also market concentration issues, editorial interference and the rising market power of a few digital media majories. And all of those threats in my view lead very compellingly to the case and the desirability of putting in place a legislative instrument at the European level that sets out a common set of principles and strength and protects media freedom and promotes editorial independence. And secondly, I think as well this piece of legislation is very complimentary to the other legislative initiatives at the European level, and in relation in within the media environment such as the AVMS and and the DSA, the regulation of the transparency and targeting a political advertising and the European advertising plan. And I'm glad to say that I come today with a degree of confidence and that Ireland's media is in a relatively healthy state, and that's not to be in any way polyanna is about about the situation. There are many challenges facing the Irish media sector but I think in the big picture of things that's heartening to note that currently we rank second in the world press freedom index. And as Eileen has referred to earlier also trust in media in Ireland is relatively high as as was reported in our launch yesterday of the Reuters digital news report Ireland for 2023. Reporters without borders state that the overall climate for press freedom in Ireland is positive and with journalists work able to work freely and without interference, but they do caution that concerns remain. However, and in particular they flag the future funding of the media including M or TE as our public service broadcaster. All of which is to say that we can't be complacent and there is still much to do to ensure an ongoing healthy and sustainable media sector in Ireland in the years ahead. So, so I'd like to maybe take a look at how I believe the regulation will impact Ireland. I don't believe I believe it doesn't present any major concerns or threats and that's again not to recognize some of the issues that have been flagged here today that that need to be addressed. But, but I think it's important to point out that, you know, we come at this from a strong constitutional legislative and regulatory position within which the regulation is going to be given effect. We have an express constitutional provision in relation to liberty of expression, a whole range of legislative instruments, and that have established the new media regulator, with which I have the honor of working. And with wide ranging powers and functions in respect of broadcasting on demand and online platforms. And for the legislative provisions and indeed plans are in train to give effect and grant additional powers to the Commission, in respect of the DSA and the European Media Freedom Act. I think as well many of the issues which have been flagged and can be addressed through the strong media development function that comes human has been charged with it's, it's a core, and I believe one that people have remarked to me has been a very critical aspect of commissure demands role as a regulator, and which had many of which that the provisions and many of the provisions within the legislation aimed to support the sustainability of the Irish media media sector through funding for public interest content through media literacy research and other development activities. I'd like to focus maybe a little bit on plurality in the Irish media as well more specifically, and something which is quite somewhat unique as I understand it to Ireland and in measuring plurality. For many years, really for for the most part, and other European jurisdictions and assess the level of plurality within any media context. They assess it in terms of the economic or competition framework that operates there. In my view, Ireland took a very brave and a very really well thought through and step in the amendment of the competition after 2002, when in 2014 it introduced and specific provisions within our media mergers legislation that distinguished the competition issues from the media plurality considerations, and accordingly gave different roles to both the competition regulator and the the broadcasting regulator at that time, and in providing separate implications to the plurality aspects of regulations and I think that's been quite important that that that that intervention and combined with other functions that were given to the media regulator, such as for example the requirement to undertake periodic research to assess changes in media plurality in the state, and we're also very, very far reaching, I believe at the time. The plurality considerations also transfers a lot of the other regulatory functions of the media regulator such as in licensing and compliance media literacy, etc as well. So it wasn't just solely confined or isn't just solely confined to media mergers, but I think all of these provisions are consistent with the statutory requirement that the the the media regulator and the man currently to endeavor to ensure a diverse and pluralistic media sector, and the promotion and protection of freedom of expression. And so, so just moving then on to our, maybe an assessment of our ready readiness to embrace that the European Media Freedom Act in an Irish regulatory context. We are well placed, possibly even uniquely placed and to implement many of the provisions of the regulation. And, as I said, the principles underpinning the proposal are very consistent already with public and regulatory policy more generally. Not only is there a strong understanding I think of what the regulation aims to achieve. And, but the context in which the regulation will be introduced is, is conducive to the achieves to the achievement of the aims of the proposal. And as I referred already to the strong constitutional legislative underpinning, there's well established regulatory practices in place and, as I said, our new statutory regulator charged with protecting media freedom and independence. I think there is, again, on a positive note I think there is widespread political public awareness of online harms and the value of trusted, of trusted media and public interest content more generally. The sustainability of public interest media and the availability and prominence of public service content are reflected across a range of uncomissioned statutory functions and indeed our regulatory activities. Areas already that we're already undertaking such as the regulatory system of oversight of public service media organizations is entirely consistent with these 2009 communication on the application of the state aid rules. Again, regulatory policies, practices and rules have already been adopted to promote transparency in the beneficial ownership and control of media services. Indeed, and they form a strong basis I think upon which we can build out and up from our additional requirements of the legislation and one such example really in relation to the aim of the media freedom act to to provide greater transparency and media ownership has been in collaboration with our colleagues in DCU where a media ownership database has already been introduced for a couple of years now. Funding schemes, as again, as Eileen referred to for public interest content are in place and plans are in train, foreign media funds, the objectives of which will include supporting local democracy and courts reporting. We have relevant regulatory and research experience in monitoring, for example, the code of practice on disinformation that I think will come sharply into focus once the regulation is introduced. And Anna referred earlier to that need to work in a cooperative fashion with other regulators and in pursuit again of some of the particular provisions of the, the and I think we've a strong basis and indeed we're key drivers here in Ireland in developing a more random of understanding with with fellow regulators and that will actually provide a basis I'm not saying all of this is already in place, but all of these factors I think provide a good basis to build up and out from that. So we're not starting from a blank sheet. Yes, I think finally, and by no means least, and given that commission a man has been designated as the digital services coordinator for the purposes of the DSA, I think we can readily appreciate and work through at a practical level, the interplay between the proposed legal instrument and indeed when it comes to applying the provisions of both pieces of legislation. So what might there be left to do for Ireland well look I think as might be apparent from what I'm saying I think we're we're well placed to give and fairly ready effect to the provisions of the regulation when they're introduced. And while I'm not going to say we've already taken a full mapping exercise of existing legislation, and as against the provisions of the the proposed regulation I that's normally the function of our colleagues in the department and we're always glad to to assist in that regard, but if something is not ready and train I imagine that that will be will be will be undertaken, but I do think that as I said we're working off a strong basis. I have a couple of thoughts on a few things that might need might need to be to be given some greater effect I think there's some existing regulatory practices I gave example there of transparency, but some of these might need to be put on a legislative footing. And I think while there's well functioning and independent audience measurement system for broadcasting services there will be a need to expand the principles of some systems at least to the online space where that might be appropriate. For example, the requirement for measurement system for state advertising. While I'm glad to say no major concerns have have surfaced today, in fact, I'm not aware of any concerns that have surfaced at all, but a formal and independent system for measurement would would need to be introduced and potentially put on a statutory footing. And I think it's really for me and I just goes just to share a few concluding concluding thoughts I think I think the regulation that's planned has has real potential to create a more even regulatory environment within which media services can operate and across the European Union by harmonizing certain elements of what are currently diverging national media pluralism frameworks. It has enormous potential I believe to faster and promote an environment that protects editorial freedom and independence to tackle disinformation in the media to deal with foreign interference and to ensure the protection of journalists and and increase transparency in media ownership. And the proposal for a greater level of structured coordination between regulators is a welcome one, and one that will ultimately help to ensure the achievement of the regulations objectives. And I think as well to address the cross border nature of many of the challenges and threats to media freedom within the European borders. And I believe the proposal is consistent with the whole range of other European legislative provisions and proposals that support and protect the media environment. And in an Irish context, I believe they're largely consistent with current media law and practices. And as I said, finally, I think Ireland is well placed in terms of existing structures policies and regulatory practices to give effect to the provisions, but that's not in any way to to sell short some of those areas that we know still need to be addressed as I mentioned today like the defamation act, public service funding a public service media but I think overall I would, I would have a positive view about our ability to effectively implement the regulation. Thank you. Thanks very much Celine I think made a very clear case of where Ireland is, and that we are well placed but look into the future that some of the issues and challenges that are there, as you say around transparency and sort of framework, and also indeed the funding issue that was raised by Eileen but also by Renata as well that I think this is an issue not only in Ireland, but also elsewhere. But we've had four excellent presentations and I think we've got a very good feel for the issues for this act and the whole issue of tourism and independence but I'd really like to get over to you or audience for questions. What concerns you would have for and issues you can address with our panel. So who'd be who would like to raise an issue. Sheamus yeah. Thank you very much for all those addresses. So my question is in relation to protecting media content on very large online platforms when it comes to content moderation. I have two questions. So first of all to what degree is it democratic or fair to give this type of protection to media organizations as opposed to a broader range of stakeholders to say NGOs civil society researchers and so on. You can do really valuable work when it comes to public discourse. I know also help to keep media to account and keep helping the media landscape to be healthy. I have one question building off of that. So I know that we want this protection to apply to reputable and quality media. But one of the big reasons for this act in the first place is the issue of media capture. So we see lots of European countries where governments use friendly businesses to buy up the media landscape to buy up previously quality reputable media, and how do we prevent the risk of this protection, applying to media that becomes captured that was previously therefore gives a level of protection to this captured media that doesn't apply to other actors to civil society, who may be challenging these governments and this captured media. Yeah, for everyone's coming on it. Yeah. We would like to start Celine I see you have your hand up there. And then we're not sure. Yeah, I think. I think the second question first. And she was I think so. Sorry, I just needed to disrupt my thoughts here. And the, the, sorry, I'm actually losing I'm going back to your first question would you mind repeating the second question. When it comes to the media organization, a certain level of protection. Yeah, I'm wondering how do we prevent this buying to capture media. So if we have no quality media organizations that then become better by the government say, yeah, what happens does the protection apply to them how do we stop that from happening what's the right way to deal with that. Yeah, so I think in a way that what the media freedom act it's not going to necessarily solve every problem but what it does give very importantly is a minimum set of standards by which states across the European Union will be required to to implement. And I think, looking at for example, and some of the advisory functions, and of the new ed, the new, the new European board for media services. That also gives a basis upon which you have an independent view established of actions that are being taken within the member states and effectively gives the basis for calling some of the things that are happening. And, and, and a basis for trying to negotiate and and, and, and change the kinds of practices and the kinds of controls that are in place. So I think you have to look at the whole set of provisions in the round, and that are designed to really change if you like the operating in relation for media services, but also the, the actual political environment as well it, some of these will take time, and, but I think it does give the basis within which, as I said, it gives a basis for a common set of harmonized principles, and a basis to ultimately call member states when when the actual media environment is completely out of alignment with what are considered good European practices. Renata. Thanks very much Celine. Yes, as I said this article 17 is the one which is a great gets the main questions, which is understandable but maybe also frustrating. But your question of course, are the ones that that concern us all. And I think that show how difficult it is to deal with it. First of all, what we said it cannot be that the big platforms, the big American platforms are the arbitrators of who deserves a privilege. And I do not want to call it exemption because it was supposed we tried an exemption was in the DSA. We were also against it. And now we are dealing with a privilege which is not the same. But if it's up to them upon a self declaration by media to decide this media is should get the exemption or not. I think we already have a problem. Because then it is the bigger media who have most resources right the best self declaratory statements and probably the platforms wouldn't have the resources or interest to really check and balance what's written there. The problem is, we have different bodies who could potentially do it there's there are the national regulatory authorities, unfortunately, in quite a few countries, they are also captured they are not independent so we all know whom they would give this self declaration. We have media councils press councils which could do that role. Again, they only deal in the print and not in the broadcasting, and we do not have so many. So it really is a challenge who could do it or it's the judges but that also takes time or we create new independent bodies of media experts who who deal with that issue that all is is at least to me, not completely clear within the course we would rather have a journalist privilege that would also help not to deal with the big media public rights but really go back to to trying to protect the, the integrity of professional journalists, even though we know they're also bad actors of journalists but it really has to be and this is of course according to national law normally journalists have to bite to cross codex to ethical standards to professional rules what what have you. But in my view it all shows how how complicated it is. I reckon that the problem is there that many specific public service media we had in many countries content was taking away. And even though it was we put a little later it does, does not help. And I have to discuss with that the whole question of prominence the whole question of algorithm transparency. I mean again, it cannot be that it's a platforms who decide what we all read, and this is happening at the moment and and the DSA has already worked on that in terms of transparency, but I think much more has to be done. Thank you very much. Thank you. Thank you. Maybe just to add, of course, there is an ongoing debate as to the exact conditions and the details you know under which the self declarations from the media service providers would be accepted. I think that it also fair to acknowledge that already in the Commission proposal I think it was very clear that there are additional conditions that's why I have spoken before about reputable media because it's a new it was a kind of a short. description of the condition of the article, but it is also fair. And this is maybe an answer to your first question to say that we are introducing certain duties for media service providers in the regulation. No, which is probably and that was the article that Renata a lot insisted on on both the transparency and also the, what she called internal editorial freedom obligations that we would expect media service providers to put in place. So I think that there is a logic. I'm not disputing that there are important questions beyond media service providers as to how platform street content from many other players in the whole ecosystem, but at least there is a very clear logic in the in this additional privileges because of the role of the so called professional media content is probably good that Renata has been also recalling and giving them this privilege treatment for platforms, because they are regulated and because they are also getting additional duties under the new regulation that will come into force provided that we'll have these new roles in place I think that, while of course the discussion on the additional qualifications and the system and who should benefit from these privileges will continue and I'm pretty sure that it will come up with a system which will be much more watertight than the original commission proposal. The basic premise is correct. And also in this discussions on this additional additional safeguards as to who qualifies, we should be very careful not to fall into a different trap into that that would, you know, force us, and we don't know actually to decide who the good or reputable media are and which are not so I think we have to keep the be very careful about the criteria you know and that they're objective that they're objective criteria, and that we do not what do not introduce any sort of how they put it, judgmental elements into the system and I think in that respect, the regulation itself already referred to very good work that has been done by the journalistic community itself know in trying to put in place a framework of objective criteria to which professional or reputable media service providers should adhere to. So it is not an easy subject, but I think we are trying, you know, to put in place a system that in a way balances out, you know, the different interests at stake. And we should still not forget that the basic premise here is that what we would like to have in the online environment in Europe is still immediate freedom by default. No, rather than rather than than than the letting a very powerful handful of very powerful companies decide what we should or should not see or read. Thanks very much, Anna. Eileen, you'll have the last word. Another question raises something very interesting and it comes back to this idea of, there's a big difference between saying who should have privilege, and which types of content or which pieces of work deserve privilege because they're very valuable and those end up with, you know, you end up with two different kinds of criterion. And because we are in a state of flux in the middle of digital transition, we are seeing a lot more people who are not traditional journalists or media workers doing those types of investigations, even within the media sphere there are a whole range of new roles that are not journalists. But they have different titles, you know, Storyful here was quite a big one. A lot of the people that work at Storyful were not journalists or they didn't study journalism. And they do other stuff, but it's part of investigation and it's essential a lot of think tanks and institutes to do really great work as well so I think we need to put emphasis on the work. And that can't address all of these these massive issues so that idea of media freedom by default is a very good basis to start with, but like anything we just need to be open that things might change in the future and there has to be flexibility there and we have to not become fixated on that defining who deserves privilege because the who isn't what's as important. Thank you very much for that and I think it's good note to end on and we're just past our time unfortunately time has gone very quickly. And I'd like to thank our excellent speakers Anna, Renata, Eileen and Celine for your really incisive presentations once that set out very clear for discussion and perhaps we hadn't as much time for discussion as we would like and we might come back to this again because I think you've raised very fundamental issues. What's clear is though the debate is not over the discussion will go on and there will be robust I think Renata you're not in your head there there be robust interventions in certain areas on topics and I think that's that's very healthy. I think Anna you've summed it up there that freedom by default is what everybody wants and what we want to look at, and I thought I was particularly interested in that whole idea of more cooperation between regulators learning from one another, building on what's good. I think we're all very pleased here to say to see and I hear you say how good the Irish situation is, but also our Irish contributors here both Eileen and Celine said we can't be complacent. We need to not just look at regulation, but with that fundamental principles that we have within our value system are so critical. So, thank you very much for that was absolutely excellent and very very interesting. I'd like to thank our audience here for your attendance for your participation. I hope you'll see you at our next digital group fixture on the 28th of June on digital skills completely different area but we'd love to see you there. I'd like to thank her IEA team, Lorcan Mullally, Sarah Burke, Hanadisi who's there and our facilities people Tom, Breen and Shona Carney and of course Seamus Allen our digital policy researcher. You know, tomorrow is Bloom's Day so I hope we all have this good weather since we're here in Northgate Georgia Street with the Joyce James Joyce Center I hope you'll enjoy that enjoy the rest of the wonderful weather that we're having here and we look forward to seeing you again here either in person or online. And thank you very much and thank you again very much again to all our presenters. Have a good day. Thank you. Thank you for the great moderation. Bye bye. Thank you. Bye now. Thank you. Good day.