06. 04. 2015

ANEM Contribution to Public Debate on Bylaws within Competence of REM

Between 20 March and 6 April 2015 the Regulatory Authority of Electronic Media (REM) conducted an integrated public debate on the drafts of the following rulebooks: on audio-visual commercial communication; on the procedure of license issuance for media service provision based on a public competition; on the procedure of license issuance for media service provision based on a request; on the protection of human rights in the media service provision sector; on conducting award contests in the media service provision sector; and on the obligations of media service providers during election campaigns.

Participating in the public debate, ANEM submitted its suggestions to REM pertaining to the drafts of the above listed rulebooks. General suggestions are related to the improvement of the practice of conducting public debates on drafts of bylaws within the competence of REM; regarding the draft rulebooks on audio-visual commercial communication and on the protection of human rights - due to the large volume and complexity of rules that require specific legal knowledge and knowledge of the European regulation, it is necessary that REM offers help to media service providers in the implementation of the prescribed rules and to have understanding for them during the period of adapting to the new rules; regarding the draft rulebook on conducting award contests in the media service provision sector and the one on the obligations of media service providers during election campaigns - in ANEM opinion, these draft rulebooks overstep legal competences and venture into original regulation of rights and obligations, which is potentially contrary to the Constitution, and thus these two domains, if there is a need for it, may be regulated by a recommendation as a more flexible instrument for harmonizing inconsistent practice; regarding draft rulebooks on the procedure of license issuance for media service provision based on a public competition and on a request - amendments are necessary to the drafts of these rulebooks by prescribing conditions and criteria for issuance of licenses considering that these issues, together with the procedure and the content of a license, make up a logical whole.

ANEM SUGGESTIONS ARE AVAILABLE HERE (IN SERBIAN ONLY)