Monitoring media pluralism in the digital era : application of the Media Pluralism Monitor in the European Union, Albania, Montenegro, the Republic of North Macedonia, Serbia & Turkey in the year 2021 : country report : Croatia.
Date: 2022-09-20
Institutions: European University Institute
Subjects: Albania, Croatia, European Union, Montenegro, North Macedonia, Serbia, access to EU information, communications profession, digital technology, freedom of communication, mass media, pluralism in the media, report, right to information

MONITORING MEDIA
PLURALISM IN THE DIGITAL ERA
APPLICATION OF THE MEDIA PLURALISM
MONITOR IN THE EUROPEAN UNION,
ALBANIA, MONTENEGRO, THE REPUBLIC OF
NORTH MACEDONIA, SERBIA & TURKEY IN
THE YEAR 2021

Country report: Croatia

Pasko Bilic, Institute for Development and International Relations

Monika Valecic, Independent Researcher

Toni Prug, University of Rijeka

Research Project Report

Issue -

June 2022

TABLE OF CONTENTS

1. About the project

1.1. Overview of the Project

1.2. Methodological notes

2.

Introduction

3. Results of the data collection: Assessment of the risks to media

pluralism

3.1. Fundamental Protection (43% - medium risk)

3.2. Market Plurality (65% - medium risk)

3.3. Political Independence (63% - medium risk)

3.4. Social Inclusiveness (62% - medium risk)

4. Pluralism in the online environment: assessment of the risks

5. Conclusions

6. Notes

7. References

Annexe I. Country Team

Annexe II. Group of Experts

4

4

4

6

8

9

12

15

17

20

23

25

26

 
 
 
 
 
 
© European University Institute 2022
Chapters © Pasko Bilic, Monika Valecic, Toni Prug, 2022

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Views expressed in this publication reflect the opinion of individual authors and not those of
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1. About the project

1.1. Overview of the Project

The Media Pluralism Monitor (MPM) is a research tool designed to identify potential risks to media pluralism
in the Member States of the European Union and in candidate countries. This narrative report has been
produced on the basis of the implementation of the MPM carried out in 2021. The implementation was
conducted in 27 EU Member States, as well as in Albania, Montenegro, The Republic of North Macedonia,
Serbia and Turkey. This project, under a preparatory action of the European Parliament, was supported by
a grant awarded by the European Commission to the Centre for Media Pluralism and Media Freedom
(CMPF) at the European University Institute.

1.2. Methodological notes

Authorship and review

The CMPF partners with experienced, independent national researchers to carry out the data collection and
to author the narrative reports, except in the case of Italy where data collection is carried out centrally by the
CMPF team. The research is based on a standardised questionnaire that was developed by the CMPF.
In Croatia the CMPF partnered with Pasko Bilic (Institute for Development and International Relations),
Monika Valecic (Independent Researcher), Dr Toni Prug (University of Rijeka), who conducted the data
collection, scored and commented on the variables in the questionnaire and interviewed experts. The report
was reviewed by the CMPF staff. Moreover, to ensure accurate and reliable findings, a group of national
experts in each country reviewed the answers to particularly evaluative questions (see Annexe II for the list
of experts). For a list of selected countries, the final country report was peer-reviewed by an independent
country expert.
Risks to media pluralism are examined in four main thematic areas: Fundamental Protection, Market
Plurality, Political Independence and Social Inclusiveness. The results are based on the assessment of a
number of indicators for each thematic area (see Table 1). 

Fundamental Protection

Market Plurality

Political Independence

Social Inclusiveness

Protection of freedom of
expression

Transparency of media
ownership

Political independence of
media

Access to media for
minorities

Protection of right to
information

News media
concentration

Editorial autonomy

Access to media for
local/regional
communities and for
community media

Journalistic profession,
standards and protection

Independence and
effectiveness of the media
authority

Online platforms
concentration and
competition enforcement

Media viability

Universal reach of
traditional media and
access to the Internet

Commercial & owner
influence over editorial
content

Audiovisual media, online
platforms and elections

Access to media for
women

State regulation of
resources and support to
media sector

Media Literacy

Independence of PSM
governance and funding

Protection against illegal
and harmful speech

Table 1: Areas and Indicators of the Media Pluralism Monitor 

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The digital dimension

The Monitor does not consider the digital dimension to be an isolated area but, rather, as being intertwined
with the traditional media and the existing principles of media pluralism and freedom of expression.
the Monitor also extracts digital-specific risk scores, and the report contains a specific
Nevertheless,
analysis of risks related to the digital news environment.

The calculation of risk

The results for each thematic area and indicator are presented on a scale from 0 to 100%. 
Scores between 0 and 33%:  low risk
Scores between 34 and 66%: medium risk
Scores between 67 and 100%: high risk
With regard to indicators, scores of 0 are rated 3% while scores of 100 are rated 97% by default, in order to
avoid an assessment of total absence, or certainty, of risk.

Disclaimer: The content of the report does not necessarily reflect the views of the CMPF, nor the position of
the members composing the Group of Experts. It represents the views of the national country team that
carried out
the data collection and authored the report. Due to updates and refinements in the
questionnaire, MPM2022 scores may not be fully comparable with those in the previous editions of the
available on:
MPM. For more details regarding the project, see the CMPF report on MPM2022,
http://cmpf.eui.eu/media-pluralism-monitor/.

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2. Introduction

Country overview: Croatia is a country with a population of 3.8 million inhabitants (Croatian Bureau of
Statistics, 2022a). The population has been steadily decreasing since the 1990s. The total population
was 4.7 million in 1991, 4.4 in 2001, and 4.2 in 2011. Geographically, the country is situated between
Central Europe, the Mediterranean, and Southeast Europe with a long Adriatic Sea coastline.

Languages: The main spoken language is Croatian.

Minorities: Croats make up more than 90 percent of the population. The country is multicultural, with
22 constitutionally recognized minorities. The main is Serbian (4.4%), followed by Bosnians (0.73%),
Italians (0.42%), Albanians (0.41%), Roma (0.40%), and Hungarian (0.33%), according to the 2011

census data (Government of the Republic of Croatia, 2021).

[1] 

Economic situation: In 2020, the GDP declined (in real terms) by 8.4% compared to 2019. In 2021,
the GDP grew by 10.4% (in real terms) compared to 2020, second only to Ireland within the EU
(Croatian Chamber of Commerce, 2022). The GDP reached 431.454 million Croatian Kuna in 2021
(Croatian Bureau of Statistics, 2022b). Croatia is heavily reliant on the service sector and tourism,
In 2021 there was a significant
which was strongly impacted by COVID-19 mobility restrictions.
recovery of overnight stays for domestic and foreign tourists, although it did not reach pre-pandemic
levels (Croatian Chamber of Commerce, 2022).

Political situation: Between 1945 and 1991, Croatia was one of six republics of the Socialist Federal
Republic of Yugoslavia. After the dissolution of Yugoslavia, and since Croatian independence was
declared in 1991, the HDZ (centre-right/right-wing) party won most parliamentary elections. The Social-
Democratic Party (SDP) formed the government between 2000 and 2003, and between 2011 and
2015. The Croatian Democratic Union (HDZ),
liberal
in coalition with minority representatives,
democrats (HNS), and Reformists, formed a government after July 2020 parliamentary elections.

Media market and regulatory environment: Total media advertising expenditure declined in 2020
due to the COVID-19 pandemic and reduced economic activity. Total advertising expenditure, across
all media, dropped by 10% between 2020 and 2019. It recovered in 2021, although it was still 3% lower
than in 2019. The biggest decline was recorded for print and radio. Internet (without social and search)
recorded growth in the same period (HURA, 2022). In terms of news sources, television (through a TV
set) was the main source (39.9%) in 2021, followed by online newspapers (16.4%), web portals (15%),
and social media (13.8%). Internet users prefer to access news directly on media websites (43.3%),
social media (42.9%), searching the media brand (42.5%), or searching particular news through search
engines (27.3%) (Vozab and Peruško, 2021).The media sector is within the purview of the Ministry of
Culture and Media. The main regulatory body is the Council of the Agency for Electronic Media (AEM).
There is no regulatory body for the print media. Print media report ownership changes to the Croatian
Chamber of Commerce (HGK). The main professional association protecting the interests of journalists
is the Croatian Journalists’ Association (HND). One of the biggest risks for media pluralism is the
presence of strategic lawsuits against public participation (SLAPPs). In April 2021, there were 924
active lawsuits (HND, 2021). Some of them were strategically raised by individuals, politicians, judges,
and the public service broadcaster (HRT) bringing their journalists to court. The former Director-

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General of the HRT is currently under charges for corruption and was dismissed by the Supervisory
Committee in July 2021. In December 2021, a new Electronic Media Act (OG 111/21) was passed
transposing the AVMS Directive. The Act brought more technical than substantial changes aimed at
improving media pluralism in Croatia. It was not based on strategic documents for the development of
the media system.

COVID-19: Croatia saw the poor implementation of the vaccination strategy and poor communication
by the Civil Protection Headquarters and the government’s Scientific Council to the general public. This
has led to an increase in the number of deaths in late 2021 and early 2022. Only 55% of the population
is fully vaccinated in March 2022 (Our World in Data, 2022). There were ongoing criticisms of the
introduction of COVID certificates with right-wing parties mobilising anti-vaccination sentiments to
organize a referendum and destabilize the government. The media suffered initial cuts in sales and
advertising but the industry is slowly recovering, although not to the pre-pandemic level. Freelance
journalists suffered the most from the effects of the pandemic.

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3. Results of the data collection: Assessment of the risks to media pluralism

Croatia scores medium risk in all four domains: Fundamental Protection (43%), Market Plurality (65%),
Political Independence (63%), and Social Inclusiveness (62%). The results are comparable to the previous
edition of the MPM. Consistency depends on the poor quality of industry data, outdated data, or a complete
lack thereof. This is particularly evident in the Market Plurality area and indicators such as Media viability.
There are no official statistics on the number of employed journalists which makes it difficult to evaluate the
indicators also
general situation in the media, especially during the pandemic. The evaluation of digital
suffers from incomplete or non-existent data.

In April 2021,

In the Fundamental Protection (43%) area, the Journalistic profession, standards, and protection scores
high risk.
there were 924 active SLAPP cases, according to the Croatian Journalists’
Association (HND, 2021). Although announced as such, the Electronic Media Act (OG 111/21) did not
change the appointment procedures to ensure better independence of the Council for Electronic Media.
Academic and expert reports have previously indicated that the parliamentary majority has too much power
in nominating and appointing members of the Council for Electronic Media (INDIREG, 2011; Lisičar, 2016).
In addition, the Council was a part of a public scandal in 2021 after a concession for a popular radio station
was not extended. It was instead granted to an owner with ownership connections through other business
entities with several radio stations. This opened the question of ownership transparency and concentration
in the radio market.

In the Market Plurality (65%) area the high-risk indicators are the Online platforms concentration and
competition enforcement, and the Commercial and owners' influence over editorial content. Most data on
media ownership is easily accessible and searchable on the website of the Agency for Electronic Media.
Print ownership structures are slightly more difficult to access as they are monitored by the Croatian
Chamber of Commerce. Ultimate beneficial owners can still be hidden behind business entities. The online
advertising market is unregulated through media-specific laws. Taxation of digital services is not a part of

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the public policy debate in the country. The working positions of journalists are precarious. Legal and self-
regulatory mechanisms are inefficient in protecting journalists from commercial interests.

In the Political Independence (63%) area the Editorial autonomy, Political independence of media, and
Independence of PSM governance and funding all score high risk. Media statutes and ethics codes are
highly inefficient in securing editorial autonomy. The appointment of the PSM Director-General is done by a
majority vote in the Parliament. The Director-General spent a portion of 2021 incarcerated, under suspicion
for influence peddling/trading in influence.

In the Social Inclusiveness (62%) area, the results have not changed since last year. Access to media for
women and Media literacy are high-risk indicators. Women are underrepresented at the executive level of
the PSM and private TV media. The media usually report about women in a stereotyped fashion. Despite
activities of the main regulator in the field of media literacy and several non-governmental organizations
covering a variety of issues ranging from children’s literacy, digital skills, film literacy, and other areas, there
is no national strategy targeting media literacy in the general population. There is a need to ensure broader
implementation of media literacy in elementary and high school education through adequate education and
training for teachers. Media and digital literacy is mentioned in the 2030 National Development Strategy
(Croatian Parliament, 2021) and the Recovery and Resilience Plan 2021-2026 (Government of the Republic
of Croatia, 2021). However, the Ministry of Culture and Media, while openly promoting media literacy, has
not specified or created any strategies that would provide measurable outcomes and benchmarks to reach
these proclaimed goals.

3.1. Fundamental Protection (43% - medium risk)

The Fundamental Protection indicators represent the regulatory backbone of the media sector in every
contemporary democracy. They measure a number of potential areas of risk, including the existence and
effectiveness of the implementation of regulatory safeguards for freedom of expression and the right to
information; the status of journalists in each country, including their protection and ability to work; the
independence and effectiveness of the national regulatory bodies that have the competence to regulate the
media sector, and the reach of traditional media and access to the Internet.

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The Fundamental Protection area scores medium risk of 43 percent, a slight increase from the 2020
assessment of 42 percent. Risk percentages per indicator remain the same except for the Journalistic
profession, standards, and protection. This indicator saw an increase from 62 to 68 percent, which reflects
attacks and threats to journalists, both men, and women, as well as precarious working positions of
freelance workers who suffer from insufficient social security or collective provisions.

The Protection of freedom of expression indicator scores medium risk of 38 percent. The country follows
international freedom of expression standards in the Constitution and media legislation. Insult (Article 147),
shaming (Article 148), and defamation (Article 149) are the main mechanisms for violating freedom of
expression. They are considered criminal offenses in line with the Criminal Code and are punished with
fines (OG 125/11; 144/12; 56/15; 61/15; 101/17; 118/18; 126/19; 84/21). As signatories to the Code of
Practice on Disinformation, online platforms have been asked to improve their transparency. However,
reports are self-reported and not conducted by independent bodies. Only a fraction of removals are done by
following national legislation and government requests. Other removals are not done transparently.

involvement of

The Protection of right to information scores medium risk of 50 percent. The right is recognised in the
Constitution and the Access to Information Act (OG 25/13; 85/15). The Information Commissioner (2021)
reports that the biggest number of appeals relates to ʻmanagement silenceʼ. Access to information is mostly
exercised through the direct
the Information Commissioner. Croatia passed the
Whistleblowers Protection Act (OG 17/19) in 2019. However, local NGOs stressed that the allocated funds
for the full implementation of the law were insufficient. There was no action plan for the implementation of
the law. In 2021, a whistleblower case gained media attention after an employee of a utility company
exposed bribery and corruption, which led to the arrest of a local mayor and three politicians. After the
arrests, the employee lost her job and is now taking the case to court based on the Whistleblowers
Protection Act. A new act (OG 46/22) was passed April 2022 to better align with the EU Directive
2019/1937.

The Journalistic profession, standards, and protection indicator scores high risk of 68 percent. The
Croatian Journalists' Association (HND) publicly promotes professional values and cooperates with national
and international NGOs, academic communities, and professional associations. The HND has a Journalistic
Council of Honour, which regularly issues warnings, breaches, and severe breaches. However, self-
regulatory measures do not improve professional standards in the country. According to the HND (2021),
there were 924 active lawsuits against journalists in April 2021 demanding retributions totaling 78.5 million
Croatian Kuna (10.4 million EUR). Some of them were strategically raised in large numbers by individuals,
especially politicians and judges. A large number of lawsuits were raised by the public service broadcaster
(HRT) and directed toward their journalists. The former Director-General of the HRT is currently under
charges of corruption and was dismissed by the Supervisory Committee (HINA, 2021). Working conditions
for journalists have consistently been deteriorating over the past decade and a half, especially after the
2008 economic crisis. The COVID-19 pandemic has sped up some of these processes. Freelancers and
self-employed journalists often work without social security protection. Minimal protection is offered for trade
union members, but it is only partial and not sufficient for subsistence. There were multiple death threats
and attacks on the physical and online safety of journalists in 2021. In December 2021, Croatian fact-
checking website Faktograf received threats of physical violence and death threats after a well-known
businessman directed his followers on social media to set up a joint fund to sue the platform. In November
2021, multiple journalists faced insults and hostility as they tried to cover a protest in the capital of Zagreb
against government measures introducing mandatory COVID-19 vaccine certificates. In November 2021, a

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journalist was subjected to a torrent of abuse and insults online after he published a controversial column
about what he called the politicisation of the victims of the Battle of Vukovar. In July 2021, a journalist was
physically attacked by individuals burning the LGBT flag. The HND (2020) reports that there were 64 attacks
and threats directed at journalists between 2015 and 2020. Out of nine attacks in 2020, the State Attorney
only raised two cases. Many other cases from previous years are still not closed. There is no legal
framework to prevent SLAPPs. The Ministry of Culture and Media acknowledges the problem and has set
up a working group and a round table to discuss the issue. No direct results of this activity have been
presented to the public.

The Independence and effectiveness of media authority scores a low risk of 25 percent. Low risk
reflects the fact that duties and responsibilities of the authority are defined in the Electronic Media Act (OG
111/21), sanctions for breaching the law are defined, and appeal mechanisms against the authority’s
decisions are in place. There have been no arbitrary government overrulings of the authorities’ powers.
Budgetary resources are defined in law, which prevents political interference. Article 81 of the Electronic
Media Act (OG 111/21) states that the budgetary resources for the functioning of the Agency are allocated
by the annual financial plan of the Agency from 0.5% of the total annual gross income from the previous
year by electronic media operators. In practice, however, the appointment procedures of the Council
members can be problematic. Academic studies (INDIREG, 2011; Lisičar, 2016) outline the fact that they
can be re-elected an unlimited number of times which can have negative effects on the independent
decision-making processes. The parliamentary majority has too much power in nominating and appointing
members of the Council. Lisičar (2016) also argues that the definitions of expertise and qualifications
necessary for the election to the Council of Electronic Media are very broad and open to multiple
interpretations. The new Electronic Media Act (OG 111/21) introduced minor changes and specified
qualifications in the fields of media, journalism, technology, economics, sociology, and law necessary for the
election to the Council. In 2021, the Council was in the midst of a public scandal due to an expired
concession of Radio 101, was one of the most important radio stations offering critical voices during the
1990s. The concession for Radio 101, which was not extended, was instead granted to an owner who has a
variety of ownership connections through different business entities with several other radio stations. This
opened the question of proper implementation of the legal and regulatory duties of the Council, especially
concerning ownership transparency and market concentration, as well as questions of conflict of interest
among some Council members.

The Universal reach of traditional media and access to the internet indicator scores medium risk of 33
percent. The universal coverage of the PSM is guaranteed by the contract between the PSM and the
government. The majority of the population is covered by the signal of all public television and radio
channels (DVB-T2), as well as by broadband internet. Regulatory safeguards for net neutrality are
implemented in practice.

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3.2. Market Plurality (65% - medium risk)

interests. The first

The Market Plurality area focuses on the economic risks to media pluralism which derive from a lack of
transparency and the concentration of ownership, the sustainability of the media industry, the exposure of
journalism to commercial
indicator examines the existence and effectiveness of
provisions on the transparency of media ownership. Lack of competition and external pluralism are
assessed separately for the news media (production of the news) and for the online platforms (gateways to
the news), and we consider separately horizontal and cross-media concentration; the concentration of the
online advertising market; and the role of competition enforcement. The indicator on media viability
measures the trends in revenues and employment, in relation to GDP trends. The last indicator aims to
assess the risks to market plurality that are posed by business interests, in relation to the production of
editorial content, both from the influence of commerce and owners.

The Market Plurality area scores a medium risk of 65 percent, a decrease from the 71 percent score in
2020. The result is affected by a lack of data and data inconsistency. The transparency of media ownership
and Commercial & owner influence over editorial content indicators remain the same as in 2020. The News
media concentration, Online platforms concentration, and competition enforcement, and Media viability
indicators have seen a decrease from 68 to 60, 88 to 83, and 73 to 56 percent respectively.

The Transparency of media ownership indicator scores a medium risk of 50 percent. Print media report
changes to the Croatian Chamber of Commerce, while electronic media (audio-visual, radio, and digital
media) report to the Council for Electronic Media. Citizens can easily access registers of all relevant media.
In the previous version of the Electronic Media Act, the media reported ownership changes on an annual
basis. In Article 61, paragraph 1 the new Electronic Media Act (OG 111/21) requires all electronic media to
report changes within five days. Paragraph 5 states that it is prohibited to conceal the ownership structure of
a media service provider or the ownership of the acquirer of shares or business stakes in a media service
provider by any legal means. There is a similar provision in Article 32, paragraph 2 of the Media Act (OG
54/04) which states that all publishers are required to deliver information about whether the stock or shares
are owned individually or by others. The amended Media Act (OG 84/11) added a paragraph to Article 32

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stating that any cover-up of the ownership structure by other legal means is forbidden. Yet the laws do not
have an explicit definition of the ultimate beneficial owner which can still be hidden.

The News media concentration indicator scores a medium risk of 60 percent. The new Electronic Media
Act (OG121/11) introduces the notion of the dominant market position (Article 65), which is reached when a
media service provider, or electronic publication, reaches 40 percent of annual revenue within the market.
Electronic publications are not included in cross-media concentration restrictions (Article 64) and the rules
are still unclear. A new provision (Article 64, para 4) of the Electronic Media Act (OG 111/21) states that all
the regulations apply adequately to providers of media services via satellite, internet, cable, and other
permitted forms of
transmission. This implicitly includes electronic publications although they are not
mentioned as such in this article. In 2020, the top 4 audio-visual media owners in the country accounted for

96 percent of the market.

[2]

The audience concentration of the top 4 audio-visual media owners in the country

in 2021 was 55 percent.

[3]

The market share of the top 4 radio owners was 72 percent in 2020.

[4]

The

audience concentration of the top 4 radio owners in 2021 was 39 percent.
We received no new data for
newspaper owners in terms of market shares. The lack of data affects the score of the indicator in

[5]

comparison to 2020. The top 4 newspapers in the country accounted for 18 percent of the readership.

[6]

The

market share of the top 4 online news media in the country was 50 percent.

[7]

The audience share of the top

4 online news media was 83 percent.

[8]

The Online platforms concentration and competition enforcement scores a high risk of 83 percent.
Side door access for news is becoming increasingly relevant and the majority of people access online news
through social media and search engines. There is no data on the audience concentration of the top 4
online players (news media and intermediaries included). According to the last available data, Google and
Facebook captured 76,3 percent of the digital advertising market in Croatia in 2018 (Bilić, Prug, and Žitko,
2021). The high degree of concentration in the digital market can be prevented through the enforcement of
competition rules but there are no advertising laws or regulatory bodies monitoring concentration in the
advertising market. The country has not introduced or scheduled any form of taxation of digital services.

The Media viability indicator scores a medium risk of 56 percent. Consistent, relevant, and official data
sources for this indicator in Croatia are difficult and, sometimes, impossible to obtain. Revenues for the
audio-visual and radio sector have been stationary. We received no data on the revenues of the newspaper
publishing industry, local media, or digital native news in 2021. There are no official statistics that specify
the difference between native news, online traditional news media, and online platforms. Advertising data is
usually compiled under the ʻinternet advertisingʼ category by the industry association, while the revenue
data for native news and online traditional news media is compiled under the ʻelectronic publications
revenueʼ category by the regulatory agency. The advertising industry monitors overall investments in the
media without differentiating between news media and other media. Total advertising spending has grown
by 7 percent between 2021 and 2020 (HURA, 2022). Many news portals in Croatia introduced paywalls in
2021 (e.g. Jutarnji List, 24 sata, Telegram, Večernji), making a large section of their content available
through subscription only. There are no official data sources on the number of journalists in Croatia. The
HND has numbers on members of the association and the SNH on the number of trade union members.
These numbers do not represent all employed journalists.

The Commercial and owner influence over editorial content scores a high risk of 75 percent. Media
statutes as self-regulatory acts (Article 26 of the Media Act (OG 59/04)) are created to regulate the
participation of
journalists in cases of appointing editors, managing working conditions, determining
journalistic responsibility, resignation procedures due to ownership or management changes that alter

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program schemes and content (so-called consciousness clause). However, media statutes are highly
inefficient
influence often results in
favourable reports and avoiding negative views about major advertisers.

in protecting journalists from commercial

interests. Commercial

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3.3. Political Independence (63% - medium risk)

Independence indicators assess the existence and effectiveness of regulatory and self-
The Political
regulatory safeguards against political bias and political influences over news production, distribution and
access. More specifically, the area seeks to evaluate the influence of the State and, more generally, of
political power over the functioning of the media market and the independence of the public service media.
Furthermore, the area is concerned with the existence and effectiveness of (self)regulation in ensuring
editorial independence and the availability of plural political information and viewpoints, in particular during
electoral periods.

The Political Independence area scores a medium risk of 63 percent. Scores for the Editorial autonomy and
the Independence of PSM governance and funding indicators remain the same as in 2020. The Audio-visual
media, online platforms, and elections saw a slight decrease from 31 to 28 percent, the State regulation of
resources and support to the media sector increased from 46 to 54 percent and the Political independence
of media from 63 to 71 percent.

The Political independence of media scores a high risk of 71 percent. The elevated risk assessment
compared to 2020 is the result of procedural problems in radio frequency spectrum allocation by the Council
for electronic media. Prevention of Conflict of Interests Act (OG 26/11, 12/12, 124/12, 48/13, 57/15, 143/21)
indirectly regulates restriction of media ownership for politicians, banning conflict of interest. The 2021
changes to the law caused plenty of public debate. While the new version of the law expands the categories
of persons the law applies to, the designated body monitoring compliance with the law - the Committee for
Resolving Conflicts of Interest - saw some changes (both expansion and reduction) with regards to its
sanctioning/enforcement powers. GRECO (2021) issued a negative opinion on the law's alignment with
GRECO recommendations before the 2021 adoption. The amendments to the HRT Act in 2012 provided for
the election of a Director-General of the HRT with a majority vote of Parliament. The majority of the Group
of expert members agree with the assessment of the presence of high risk and political control over the
audio-visual media. Radio, particularly at the local level, is also highly influenced by political interests. In
terms of newspapers and digital native media, the majority of the Group of expert members evaluate the risk

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from political dependence as medium risk. The Croatian Informative News Agency (HINA) is the leading
news agency in Croatia. According to the Croatian News Agency Act (OG 96/01), the Management Board of
HINA is appointed and dismissed by the Croatian Parliament (4 out of 5 members). All experts agree with
the high-risk assessment of the independence of HINA.

The Editorial autonomy indicator scores a high risk of 97 percent. Neither the Media Act (OG 59/04, 84/11,
81/13) nor the Electronic Media Act (OG 111/21) contains safeguards to guarantee autonomy when
appointing and dismissing editors-in-chief. The vast majority of media statutes are usually not made public.
The Croatian Journalists' Association has a Journalistic Council of Honour which monitors the behaviour of
journalists according to its Code of Ethics. While it monitors implementation and issues warnings, breaches,
and severe breaches, its effectiveness does not seem to improve the overall editorial independence in the
country. In a 2021 study on a sample of 23 journalists and editors, two-thirds answered that they have
witnessed pressures on editorial independence (of both commercial and political nature) while performing
their jobs (Klancir, 2021).

The Audio-visual media, online platforms, and elections indicator scores a low risk of 28 percent. The
HRT Act (OG 137/10, 76/12, 78/16, 46/17, 73/17, 94/18) and the Contract with the Government (2018-2022)
do not have explicit access guarantees for political actors during elections. Access to airtime is governed
through the Rules for Electronic Media with a National Concession in the Republic of Croatia. The PSM
aligns its editorial policy during each election cycle through self-regulation. In general, different groups of
political actors and/or viewpoints are represented in a biased way in the PSM channels. The group of expert
members agrees with the high-risk assessment of PSM political bias. Experts also agree that different
groups of actors are represented fairly on private channels during elections. There are no regulatory
measures to ensure equal opportunities in online media during electoral campaigns. The requirement to
separately report social media costs as part of campaign costs came into effect in 2019. After two elections
since then, it is clear that there is room for improvement in the practice of reporting social media campaign
costs. Not all candidates/parties are equally meticulous in filling out forms and submitting accurate data.

The State regulation of resources and support to the media sector scores a medium risk of 54 percent.
In 2021, the Council for Electronic Media made a controversial decision on the new concessionaire for the
101 MHZ radio frequency. After the license expired for the previous owner (an influential Radio 101 station,
especially in the nineties), Top radio d.o.o. was selected as the most favourable bidder. According to
available public registries, the owner and director of Top radio d.o.o. is connected to 27 business entities,
radio stations. This opened the question of ownership
including informative agencies and other
transparency, market concentration, and conflict of interest among Council members. The majority of
Council members approved the new frequency owner, while two Council members published dissenting
opinions. Professional associations voiced their disapproval publicly and in written letters to national and
European institutions. There are few regular direct subsidies to media outlets. The Council for Electronic
Media is in charge of the Fund for the Promotion of Pluralism and Diversity, based on the Electronic Media
Act (OG 111/21). The 3% of the PSM license fee is allocated to the Fund based on the Croatian Radio-
television Act (OG 137/10). The Fund finances the production and broadcasting of audio-visual, radio, and
online content. In addition, some local governments earmark direct media subsidies in their annual budgets
for local media. Article 38 of the Electronic Media Act (OG 111/21) states that state bodies and legal entities
owned by the Republic of Croatia are required to spend 15% of their annual budget for the promotion of
their services or activities on advertising in audio-visual or radio programs of regional and local television
and/or radio broadcasters and/or electronic media. Rules on the distribution of state advertising to media
outlets are unclear. State administration bodies and legal entities fulfill their legal obligation by informing the

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Electronic Media Council about placed advertising by 31 March of each calendar year.

The Independence of PSM governance and funding indicator scores a high risk of 67 percent. With a
simple majority of votes, the Parliament elects the Director-General for a five-year mandate (a procedure
which, according to the previous iteration of the Law, required a 2/3 parliamentary majority). Four out of five
members of the Supervisory Committee are appointed by the Croatian Parliament. The former PSM Director
General spent part of 2021 imprisoned on charges of influence peddling and corruption while holding the
PSM Director General position. During his term, HRT became infamous for filing SLAPP lawsuits against its
employees who also hold functions in the Croatian Journalists' Association. The new PSM Director-General
was confirmed by a thin simple majority in the Parliament. The PSM has dual financing from the license fee
and advertising. Article 35 of the Croatian Radio-television Act (OG 137/10) determines the license fee at
1,5% of the average net salary in Croatia based on the statistical indicators of the previous year.

3.4. Social Inclusiveness (62% - medium risk)

The Social Inclusiveness area focuses on the access to media by specific groups in society: minorities, local
and regional communities, women and people with disabilities. It also examines the country’s media literacy
environment, including the digital skills of the overall population. Finally, it also includes new challenges
arising from the uses of digital technologies, which are linked to the Protection against illegal and harmful
speech. 

The Social Inclusiveness area scores an overall medium risk of 62 percent. The Access to media for
minorities, Access to media for local/regional communities and community media, and Media literacy
indicators remain the same as in 2020, scoring 58, 44, and 67 percent respectively. The Access to media
for women and the Protection against illegal and harmful speech saw some fluctuation: from 86 to 80
percent and from 56 to 63 percent respectively.

The Access to media for minorities indicator scores a 58 percent risk. A legally guaranteed minority right
is the right to access the media and public information services in a minority language and script. The
Croatian Radio-Television Act (OG 137/10 and 76/12) obliges the Croatian Radio-Television (HRT) to

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produce and/or broadcast programs dedicated to informing persons belonging to national minorities in the
Republic of Croatia. In practice, twenty-two national minorities recognized by the Constitution are entitled to
two one-hour shows on public television and one broadcast on public service radio. Most members of the
Group of experts agree with the assessment that most minorities do not have adequate access, or that it is
not proportional to the size of their community. The national news is not available in any minority language.
Inclusion of people with disabilities in the media is sporadic and usually reserved for specialised TV, or
radio, shows. Subtitles, signing, and sound descriptions are available only on an irregular basis, or in the
least popular scheduling windows. Sound and audio descriptions are available for blind people in PMS or
private TV channels on an irregular basis.

The Access to media for local/regional communities and community media scores a medium risk of 44
percent. The Council for Electronic Media grants concessions to local and regional communities based on
Article 77 of the Electronic Media Act (OG 11/21), Electronic Communications Act (Article 12, OG 72/17),
and the Concessions Act (Article 8, OG 69/17). It supports them through the Fund for the Promotion of
Pluralism and Diversity. The Fund stimulates the production and broadcasting of audio-visual and radio
levels (Article 71 Para. 1 of the
programs of television and/or radio broadcasters at local and regional
Electronic Media Act). However, these media are usually granted less than 50 percent of requested funds,
based on the most recent data (Council for Electronic Media, 2021). In 2021, the Croatian Journalists'
Association (HND) and the Croatian Journalists' Union (SNH) organised a campaign to warn about the
increasing dependence of local media on subsidies from the local and municipal
levels. These types of
funding agreements are usually funded through non-transparent ʻadvertisingʼ transactions which severely
damage their independence and turn them into mouthpieces of local politicians and businessmen.

The Access to media for women indicator scores a high risk of 80 percent. The gender equality principle
has been included in a series of legislative, strategic, and other documents dealing, inter alia, with media.
However, the PSM does not have a comprehensive gender equality policy. Neither the Agreement between
the Government of the Republic of Croatia and the Croatian Radio and Television for the period 2011-2017
nor for the period 2018-2022 contain a provision on gender equality promotion as a mission or a value
promoted in the programs of PMS. Women are underrepresented at the management and executive level of
the PSM, as well as at the executive level of private TV companies. In the annual Ombudswoman for
gender equality report (2021), the most persistent reported media trend is the objectivization of women's
bodies, evaluating women based on their physical appearance both in advertising content and in media
personalities, persons from the private sector, politics or sport. While some media try to improve their
reporting styles, others (including the public service broadcaster) show a basic misunderstanding of what
gender stereotypes are, as well as a lack of effort and will to become more educated or to change their
reporting practices. The group of experts agrees that male experts are evidently and systematically more
often invited by media to comment on political and other relevant matters and events than female experts.

The Media literacy indicator scores a high risk of 67 percent. Part of the curriculum of the Croatian
language courses in elementary and high schools covers topics related to media literacy. The Agency for
Electronic Media has been active in developing materials for the parents, teachers, and children on media
literacy. The Agency developed Recommendations for children's protection and safe use of electronic
media and started a portal promoting media literacy. However, there is no overarching media strategy or
level aiming to develop media literacy. There is a need to ensure broader
policy at
implementation of media literacy in elementary and high school education through adequate education and
training for teachers. Media and digital literacy are mentioned in the 2030 National Development Strategy
(Croatian Parliament, 2021) and the Recovery and Resilience Plan 2021-2026 (Government of the Republic

the national

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of Croatia, 2021). However, the Ministry of Culture and Media, while openly acknowledging the importance
of media literacy, has not specified or created any strategies that would provide measurable outcomes and
benchmarks to reach these proclaimed goals.

The Protection against

illegal and harmful speech indicator scores a medium risk of 63

[9]

Disinformation is frequent in the country, especially related to the COVID-19 emergency. It is a
percent.
major source of mobilisation for anti-vaccination and anti-mask protests and rallies. Disinformation is mostly
spread over social media and messaging applications. The existing legal framework contains a rather
general article 15 in the Electronic Media Act (OG 111/21) targeting false information. However, social
media and messengers are not covered by any law or policy. The fact-checking organisation Faktograf
regularly publishes debunking information related to the main sources of disinformation. The impact of their
activities is limited. Since February 2020 and until December 2021, Faktograf reported 40 violent and death
threats for exposing disinformation. Article 14, paragraph 2 of the Electronic Media Act (OG 111/21) states
that incitement, or spreading, of hate speech, or discrimination, is not allowed. In Article 94, paragraph 3 the
Act introduced the responsibility of online news portals (i.e. electronic publications) for user comments
unless users are properly registered and warned of using hate speech. Hate speech is also regulated by the
Criminal Code which in Article 325 regulates public incitement to violence and hatred.

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4. Pluralism in the online environment: assessment of the risks

The Fundamental Protection area in the online environment scores a medium risk of 53 percent. Online
platforms are generally cooperative with government requests by local law and corporate Terms of Service.
Between January and June 2021, Facebook restricted access in Croatia to one item for allegedly inciting
hatred as part of the EU Hate Speech Test under the 2016 EU Code of Conduct on Countering Illegal Hate
Speech Online. Facebook also restricted access to seven items for violating Article 325 of the Croatian
Criminal Code (OG 125/11). The company launched an advertising campaign in Croatia to educate its users
on how it uses fact-checking organisations to combat disinformation (Facebook, 2021). Facebook directly
cooperates with Faktograf. In Search, Google introduced a comprehensive experience for COVID-19 that
provides easy access to information from health authorities alongside new data and visualisations. When
people looked up information for COVID-19 vaccines, the search engine surfaced a list of authorised
vaccines in their location, as well as information on each approved vaccine. The problem with these
they are mostly self-initiated and/or self-reported, not conducted by
initiatives and reports is that
independent bodies. There is a strong indication that disinformation is widely spreading in different
channels, especially applications such as Viber and WhatsApp, as reported by Faktograf.

On 11 December 2021, Faktograf received physical violence and death threats after a well-known
businessman directed his followers on social media to set up a joint fund to sue the platform (European
Centre for Press and Media Freedom, 2022). The intimidation started after an entrepreneur posted on his
Facebook page, which has 40,000 followers, a pledge to launch a criminal lawsuit against it for allegedly
“censoring” his posts. He even suggested that people set up a fund to pay the legal costs of lawsuits. After
the post, Faktograf received numerous threatening messages on Facebook and via email, including death
threats against their staff. The most serious threats were reported to the police. On 14 December, the
platform reported that its website was under DDoS attacks. The HND and SNH condemned the attacks.
There have been other well-documented online threats and harassment cases in 2021 (European Centre for
Press and Media Freedom, 2022). The GDPR Implementation Act (42/18) contains no specific provisions

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about the legal monitoring of journalists by law enforcement authorities. Media specific legislation and the
Act on the protection of natural persons about processing and exchange of personal data for the prevention,
investigation, detection or prosecution of criminal offences or the execution of criminal penalties (68/18)
contain no such provisions.

The Market Plurality area in the online environment scores a high risk of 72 percent. The national
legislation in the Media Act (OG 54/04) and the Electronic Media Act (OG 111/21) contains no provisions
requiring the disclosure of the ultimate owners of digital-native news media. The market share of the top 4
online news media is 50 per centNOTA_1086] The audience share of the top 4 online news media is 83 per
centNOTA_1087] Internet users prefer to access news directly on media websites (43.3%), social media
(42.9%), searching the media brand (42.5%) or searching particular news through search engines (27.3%)
(Vozab and Peruško, 2021). There is no data on the audience concentration of the top 4 online players
(news media and intermediaries included). According to the last available data, Google and Facebook
captured 76,3 per cent of the digital advertising market in Croatia in 2018 (Bilić, Prug and Žitko, 2021). In
principle, competition law applies to all markets which are determined according to the Regulation on
Determining Relevant Markets (OG 9/11) and the Market Competition Protection Act (OG 79/09; 80/13).
There are no media-specific laws that would apply to the advertising market. There is no reliable data on the
revenues of digital-native news in 2021. There are no official statistics or monitoring mechanisms that
specify the difference between native news, online traditional news media and online platforms. Advertising
data is usually compiled under the ʻinternet advertisingʼ category by the industry association, while the
revenue data for native news and online traditional news media is compiled under the ʻelectronic
publications revenueʼ category by the regulatory agency. The advertising industry monitors overall
investments in the media without differentiating between news media and other media. Total advertising
spending has grown by 7 per cent between 2021 and 2020 (HURA, 2022). While competing with online
platforms for advertising revenue, many news portals in Croatia have introduced paywalls in 2021.
Measures that would apply to the protection of journalistic work in online new media are non-existent and
largely left to self-regulation which has already proven to be highly ineffective for traditional print and
electronic media.

The Political Independence area in the online environment scores a medium risk of 34 percent. Digital
audiences are segmented and the digital space is showing signs of political polarisation (i.e. left-wing vs.
right-wing) (Vozab and Peruško, 2021). Digital media are sometimes used for the mobilization of citizens for
political reasons (e.g. voting mobilization in referendum initiatives). The State Electoral Commission does
not consider social media as media, in line with the way media are defined in the Media Act, and asks for
social media costs of political campaigns to be reported separately from media advertising costs. There has
been some CSO advocacy to increase the transparency of political advertising on online platforms during
electoral campaigns since many parties and candidates do not fill the forms correctly. For instance, they do
instead, merge them into a single sum. Not all
not state each social network separately but,
candidates/parties are equally meticulous in filling out forms and submitting accurate data. Social media
costs that a PR agency representing a specific party pays from their lump sum budget is, oftentimes, not
reported at all. The forms themselves could be made more specific and clear to reduce ambiguity. The
Croatian Personal Data Protection Agency occasionally publishes relevant materials to educate
stakeholders or to interpret relevant EU regulations. In practice, it only reacts to active cases of complaints.
There is no detectable, active monitoring and acting upon violations of GDPR, especially in the electoral
context.

The Social

Inclusiveness area in the online environment scores a medium risk of 56 percent.

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Disinformation is widely spread in the country, especially related to the COVID-19 emergency. It is a major
source of mobilisation for anti-vaccination and anti-mask protests and rallies. The fact-checking organisation
Faktograf regularly publishes debunking information about the main sources of disinformation. Faktograf is
a member of Facebook's Fact-Checking group. Faktograf started in 2015 as a joint project of the Croatian
journalists' association and the civil society organisation GONG. In 2018, GONG was the main publisher,
and in November 2021, it became an independent organisation founded by the members of its editorial
board. Their main activity is fighting disinformation in public spaces. Since February 2020 and until
December 2021, Faktograf reported 40 violent and death threats to the police. In December 2021, an
entrepreneur called his Facebook followers to start lawsuits against Faktograf due to a supposed breach of
his freedom of speech. Previously, Faktograf reported and exposed his posts for spreading disinformation.
The existing legal framework contains a rather general article in the Electronic Media Act (OG 111/21)
targeting false information. Article 15 states that all electronic media are obligated to publish truthful
information and respect human rights and fundamental freedoms. However, the law extends only to radio,
television and news portals (i.e. electronic publications). Social media and messaging applications, which
are the main sources of disinformation, are not covered by any law or policy.

Article 14, paragraph 2 of the Electronic Media Act (OG 111/21) states that incitement, or spreading, of hate
speech or discrimination based on racial or ethnic belonging, skin colour, gender, language, religion,
political or other beliefs, national or social origin, economic status, union membership, education, social
status, marital or family status, age, health condition, disability, genetic heritage, gender identity, sexual
orientation, antisemitism, xenophobia, ideas of fascist, nationalist, communist and other totalitarian regimes
are not allowed. This relates to what the Act defines as electronic publications or edited news portals. In
Article 94, paragraph 3 responsibility of online news portals for user comments is introduced, unless users
are properly registered and warned of using hate speech. Hate speech is also regulated by the Criminal
Code, which in Article 325 regulates public incitement to violence and hatred based on racial, religious,
national or ethnic identity, origin, the colour of skin, gender, sexual orientation, disability, etc. Regulation is
ineffective and there is no regulatory framework in place to tackle hate speech on social media.

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5. Conclusions

Croatia scores medium risk in all four domains in 2021: Fundamental Protection (43 percent), Market
Plurality (65 percent), Political Independence (63 percent), and Social Inclusiveness (62 percent). The
results are comparable to 2020. The main risks to media pluralism in Croatia have been consistent over the
years and have not been dealt with by strategic thinking, or new legislation. Such an approach further
deteriorates media pluralism. The new Electronic Media Act (OG 111/21) brought many technical changes,
but none targeting detected systemic deficiencies. Tackling all
issues detected by the MPM requires
coordinated and sustained communication of the Ministry of Culture and Media with all involved actors (i.e.
main regulator(s), journalists’ association and trade union, industry associations, non-profit media, academic
and policy experts, the general public, etc.).

Fundamental Protection: 

The Ministry of Culture and Media should establish and promote continuous communication between
the judiciary, journalists’ association, and trade union to reduce the number of SLAPPs and the
negative effects they have on freedom of expression.

Defamation, shaming and insult charges should be decriminalised and the Criminal Code (OG 125/11;
144/12 61/15; 101/17; 118/18; 126/19; 84/21) amended.

The EU anti-SLAPP directive needs to be supported and properly adapted to local conditions.

Market Plurality: 

The Ministry of Culture and Media should open the public debate and introduce taxation of online
platforms.

New tax income should be redistributed to projects promoting media freedom and media pluralism.
The Council for Electronic Media and the Croatian Chamber of Commerce need to improve their data
collection strategies to allow better understanding and regulation of the digital economy. There is no
revenue monitoring of online platforms, native news media, and digital outlets of traditional media as
separate entities. There is no official data on the number of employed and unemployed journalists in
the country.

Political Independence: 

The Croatian Radio-television Act (OG 137/10; 76/12; 78/16; 46/17; 73/17; 94/18) needs to be
amended to change appointment procedures for a key management position. To reduce direct political
interference, Director-General and the Management Committee should be approved in the Parliament
through a two-thirds majority, instead of a simple majority.

The Media Act (OG 59/04, 84/11, 81/13) and the Electronic Media Act (OG 111/21) should be amended
to include safeguards that guarantee editorial autonomy from political interference when appointing and
dismissing editors-in-chief. All media statutes should be made public.

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Social Inclusiveness: 

Gender equality should be granted a prominent role in the new Contract between the HRT and the
Government (2023-2027).

The Ministry of Culture and Media should create and implement strategies with measurable outcomes
to improve media literacy in the country.

To tackle disinformation and hate speech, the Electronic Media Act (OG 111/21) should be amended to
include social media in Article 15.

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6. Notes

[1]

[2]

[3]

[4]

[5]

[6]

[7]

[8]

[9]

  Until March 2022, the Croatian Bureau of Statistics has not yet published the updated statistics on the
percentage of minorities in Croatia from the 2021 census.
  Data provided by the Agency for Electronic Media.

  Data provided by the Nielsen agency's SHR measure.

  Data provided by the Agency for Electronic Media.

  Data provided by Ipsos based on daily reach among all radio stations (February – September 2021).

  Data provided by Ipsos based on Average Issue Readership (AIR) among 60 newspapers (January –
September 2021).
  Data provided by the Agency for Electronic Media.

  Data provided by Ipsos based on average monthly share of unique visitors (January – November
2021).
  This composite indicator for this year’s evaluation contains 9 variables compared to 7 in the previous
MPM. For this reason, it is difficult to compare results over time. 

[10]   Data provided by the Agency for Electronic Media.

[11]   Data provided by Ipsos based on average monthly share of unique visitors (January – November

2021).

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7. References

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ANNEXE I. COUNTRY TEAM

First name

Last name

Position

Institution

Pasko

Bilic

Senior Research Associate

Institute for
Development and
International Relations

Monika

Valecic

Responsible for the Political
Independence area

Independent
Researcher

Toni

Prug

Responsible for the Market
Plurality area

University of Rijeka

MPM2022 CT
Leader

X

ANNEXE II. GROUP OF EXPERTS

The Group of Experts is composed of specialists with a substantial knowledge and recognized experience in
the field of media. The role of the Group of Experts was to review the answers of the country team to 16
variables out of the 200 that make up the MPM2022. Consulting the point of view of recognized experts was
aimed at maximizing the objectivity of the replies given to variables whose evaluation could be considered
as being subjective, and, therefore, to ensure the accuracy of the final results of the MPM. However, it is
important to highlight that the final country report does not necessarily reflect the individual views of the
experts who participated. It only represents the views of the national country team that carried out the data
collection and authored the report.

First name

Last name

Hrvoje

Josip

Zovko

Popovac

Position

President

President

Viktorija

Car

Associate professor

Bojana

Bozanic Ivanovic

President of the Assemly

Institution

Croatian Journalists' Association

Council for Electronic Media

Faculty of Political Science,
University of Zagreb

The Croatian Employer's
Association - Newspaper
Publishers Association

Research Project Report

Issue -

June 2022

doi:10.2870/779430

ISBN:978-92-9466-268-2

QM-08-22-233-EN-N

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