The signatories of this letter of consultation are specialized civil organisations with a long history of commitment to the freedoms of speech and press and extensive professional experience in this area. Said organizations were very pleased that, partly in response to the situation of the Hungarian media, the European Commission has set up the working group entitled High Level Group on Media Freedom and Pluralism, under the leadership of Chairperson Vaira Vīķe-Freiberga. We also welcome the fact that the European Commission has released the working group’s report for public consultation. Following the logic of the recommendations laid down in the Report, the undersigned civil organisations articulate their own observations and suggestions in the present letter. Several of the signatories are currently also involved in organising the Hungarian campaign for the European Citizens’ Initiative for Media Pluralism, whose objectives – preventing excessive concentrations of ownership in media markets, ending the possibility unilateral governmental and party influence over national broadcasting authorities – mesh with the goals pursued by the Freiberga Group.
Above all, we would like to point out that the Tavares Report initiated by the European Parliament, which evaluated the state of democracy and rule of law in Hungary, has also shown that we are generally facing systemic problems in the public law and political realms: problems pertaining to the democratic quality of the constitutional order and concerning violations of the principle of separation of powers point to concerns that are far too comprehensive to illustrate with individual examples, no matter how grievous those may be. We encounter similar systemic problems in the areas within our specialised range of expertise, that is the media system, media pluralism and the freedoms of speech and press.
For a nuanced assessment of the prevailing media situation, we would like to point to historical particularities in Central and Eastern European development, above all the functional anomalies of democratic institutions, the difficulties in engendering a diversity of opinions, an increasing contraction of the opportunities available in media markets, and the attempts by successive governments to gain ground in all segments of the media. Journalists and editors in Central and Eastern European member states are still prone to engage in self-censorship – in large part due to the lingering legacies of the communist era – as soon as they face governmental pressure. Media regulations harmonised at the European level, including a wider application of the recommendations and common minimum rules laid out in the Freiberga Report, could still constitute guarantees for media pluralism and press freedom in our region.