Monitoring media pluralism in the digital era : application of the Media Pluralism Monitor in European Member States and in candidate countries in 2023 : country report : Austria.
Date: 2024-07-11
Institutions: European University Institute
Subjects: Austria, EU candidate countries, European Union, 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 MEMBER
STATES AND CANDIDATE COUNTRIES IN
2023

Country report: Austria

Josef Seethaler, Austrian Academy of Sciences, Institute for Comparative Media & Communication Studies

Maren Beaufort, Institute for Comparative Media and Communication Studies (CMC) at the Austrian

Academy of Sciences and the University of Klagenfurt

Research Project Report

Issue -

June 2024

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 (30% - low risk)

3.2. Market Plurality (65% - medium risk)

3.3. Political Independence (41% - medium risk)

3.4. Social Inclusiveness (49% - medium risk)

4. Conclusions

5. References

Annexe I. Country Team

Annexe II. Group of Experts

4

4

4

6

8

11

15

19

24

29

31

 
 
 
 
 
 
© European University Institute 2024
Editorial matter and selection © Josef Seethaler, Maren Beaufort, 2024

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1. About the project

1.1. Overview of the Project

The Media Pluralism Monitor (MPM) is a research tool that is 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 that was carried out in 2023. The
implementation was conducted in 27 EU Member States, as well as in Albania, Montenegro, The Republic
of North Macedonia, Serbia and Turkey. This year a part of the MPM has also been piloted in Bosnia and
Herzegovina and Moldova. 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. The research is based on a standardised questionnaire that was developed
by the CMPF.

(Austrian Academy of Sciences,

Institute for
In Austria the CMPF partnered with Josef Seethaler
Comparative Media & Communication Studies), Dr. Maren Beaufort (Institute for Comparative Media and
Communication Studies (CMC) at the Austrian Academy of Sciences and the University of Klagenfurt), 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). 

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.
Nevertheless, the Monitor also extracts digitally specific risk scores, and the report contains a specific
analysis of the risks that 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

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Scores between 34% and 66%: medium risk

Scores between 67% and 100%: high risk

With regard to the Indicators, scores of 0 are rated as 3%, while scores of 100 are rated as 97%, by default,
in order to avoid an assessment that offers a total absence, or certainty, of risk.

Fundamental Protection

Market Plurality

Political Independence

Social Inclusiveness

Protection of freedom of
expression

Transparency of media
ownership

Political independence of
the media

Representation of
minorities

Protection of right to
information

Plurality of media
providers

Editorial autonomy

Plurality in digital markets Audiovisual media, online

Journalistic profession,
standards and protection

Independence and
effectiveness of the media
authority

Media viability

Universal reach of
traditional media and
access to the Internet

Editorial independence
from commercial and
owners' influence

platforms and elections

State regulation of
resources and support to
the media sector

Independence of PSM

Local/regional and
community media

Gender equality in the
media

Media Literacy

Protection against
disinformation and hate
speech

Table 1: Areas and Indicators of the Media Pluralism Monitor 

Methodological Changes 

For every edition of the MPM, the CMPF updates and fine-tunes the questionnaire, based on the evaluation
of the tool after its implementation, the results of previous data collection and the existence of newly
available data. The results obtained for these indicators are therefore not strictly comparable with those
results obtained in the previous edition of the MPM. The methodological changes are explained on the
CMPF website at http://cmpf.eui.eu/media-pluralism-monitor/.

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 who carried out the data collection and authored the report. Due to updates and
refinements in the questionnaire, MPM2024 scores may not be fully comparable with those in the
previous editions of the MPM. For more details regarding the project, see the CMPF report on
MPM2024, which is available on: http://cmpf.eui.eu/media-pluralism-monitor/.

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2. Introduction

Country overview. Austria covers an area of 83,878 square kilometres. As of January 1, 2023, it had a
population of 9,104,772 (data from Statistics Austria), 1.4% more than at the beginning of 2022. The
population growth, which has continued for years, is exclusively due to people with non-Austrian
citizenship.

language. However,
Languages. German is the official
Slovenian and Hungarian are also recognised as official languages of autonomous population groups.

in some regions, Burgenland-Croatian,

Minorities. 21.7% of the population were born in countries other than Austria (data from 2023). These
include Germany (2.8%), Bosnia and Herzegovina (1.9%), Turkey (1.8%), Serbia (1.6%), and Romania
(1.6%). People with a migration background (= 1st and 2nd generation) count
the
population (annual average 2022) (data from Statistics Austria).

for 26.4% of

Economic situation. After the sharp economic downturn in 2020 and the temporary growth in 2021
(4.5%) and 2022 (5.0%), Austriaʼs economy recorded a GDP decrease of 0.8% (in real terms) in 2023.
The inflation rate in 2023 is 7.8% and, therefore, only slightly below 8.6% in 2022 (all data from
Statistics Austria). According to the EUROSTAT definition, the unemployment rate in 2023 was 5.6%;
according to the national definition, it was 6.4%. This represents a slight increase compared to the
previous year (data from the Austrian Ministry of Labour and Economy).

Political situation. Since 2020, Austria has been governed by a coalition of the conservative Austrian
People’s Party (ÖVP) and the Greens. In June 2023, the Social Democratic Party elected a new
chairman who positioned the party more to the left of the centre. According to surveys, however, most
parties are losing support, except the right-wing Freedom Party (FPÖ), which is gaining popularity.

Media market. The dramatic decline in news interest observed after the peak during the COVID-19
crisis has slowed. In 2023, 54.3% of the Austrian population are very interested in news, and an
additional 31.5% are somewhat interested (compared to 56.9% and 32% in 2022). Despite losses,
television remains the most significant source of information, and the public service broadcaster has
maintained a relatively high market share of about one-third of the television market. For people under
35, social media is the most important daily news source, but it has lost some of its importance in the
overall population. This also applies to messaging apps. On the other hand, newspaper websites and
apps and radio programmes have gained in importance and have even slightly surpassed social media
as the main source of news. Printed newspapers, however, are steadily losing ground. General trust in
news has fallen to 38.3%, slightly below the level before the pandemic. Nevertheless, the public service
broadcaster is still the most trusted news source (61%), followed by the quality newspapers ‘Der
Standard’ (58%) and ‘Die Presse’ (56%) (all data from Gadringer et al., 2023).

Regulatory environment. The Austrian media regulatory authority is the 2001 established “Austrian
Communications Authority”
(KommAustria), which, since 2010, has been legally distinct and
functionally and effectively independent from the government and any other public or private body. In
2023, several regulatory measures were adopted, including the transposition of the EU Whistleblower
Protection Directive (Directive 2019/1937) into national law (see Chapter 3.1) and an amendment of the
Transparency in Media Cooperation and Funding Act, which requires all public legal entities to report all
insertions and media cooperations to the regulatory authority regardless of a medium's frequency of
publication and the amount involved (see Chapter 3.3). On December 20, 2023, the Minimum Taxation

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Reform Act (Mindestbesteuerungsreformgesetz) passed the parliament, which - in accordance with
Council Directive (EU) 2022/2523 of 14 December 2022 - provides for the incorporation of Pillar Two
into domestic law and replaces the Digital Tax Act (see Chapter 3.2). The 2021 Act on Measures to
Protect Users on Communications Platforms will be replaced by the Digital Services Act (DSA), the
accompanying regulation of which came into force by February 17, 2024 (see Chapter 3.1). In October
the Federal Act on the Austrian
2023, The Constitutional Court annulled some provisions of
Broadcasting Corporation (ORF Act) on the appointment and composition of the Foundation Council
and the Audience Council as unconstitutional. The provisions violate the requirement of independence
and pluralistic composition of these bodies enshrined in Art I para 2 of the Federal Constitutional Act on
Guaranteeing the Independence of Broadcasting. They must, therefore, be amended by March 2025
(see Chapter 3.3). After years of struggle, a new and much-criticized Freedom of Information Act was
adopted on January 31, 2024, but will not come into force until September 2025 (see Chapter 3.1).

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

low risk. The other

the MPM 2024 in Austria indicates (like all previous MPM editions) that only
The implementation of
Fundamental Protection is at
three areas – Market Plurality, Political
Independence and Social Inclusiveness – are at medium risk, with Market Plurality at the highest border
of medium risk. Horizontal and cross-media concentration, insufficient consideration of changes in media
supply and use in competition law, decreases (or, at best, only modest) increases in revenues, the outflow
of well over one-third of advertising revenue to a few global platforms, cost-cutting measures for
newsrooms, and a system of media subsidies that favours large corporations instead of democratically
relevant journalism – all threaten market viability and market plurality. Across all four areas, four out of
twenty indicators represent a high risk, eleven a medium risk, and only five a low risk.

It has to be emphasised that the foundations of a democratic media system are intact and robust: Freedom
of expression is well protected, even on the Internet. Media authorities work independently. Public TV and
radio signals reach almost everyone, and access to journalism is unrestricted. There still is a varied supply
of regional and local media services, including a lively community media sector. During election campaigns,
the public service broadcaster ORF reasonably represents the parliamentary parties in its programmes.
Regulatory safeguards that preclude government officials and political parties from media ownership in the
audiovisual and radio sector, the Austrian Press Agency’s (APA) professional work, and editorial statutes
(wherever they are in place) are among the precautions that seek to make political interference in journalism
more difficult.

However, these results are impeded by other indicators that point to a considerable risk. The new Freedom
of Information Act represents a missed opportunity to secure a truly democratic right to information (e.g.,
Forum Informationsfreiheit, 2024; Gasser, 2024). A comprehensive framework for protecting journalists’

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physical, digital and social safety, including protection from strategic lawsuits against public participation
(SLAPPs), is still missing at a time of increasing social tensions, which are increasingly being exploited by
forces that are ready to use violence – also against journalists. Most newsrooms lack structures and clearly
communicated guidelines for dealing with threats, sexual harassment and hate speech against journalists,
but also against other people in community forums, and the media industry, in general, suffers from
rudimentarily developed self-regulatory systems.

Due to investigations by the Economic and Corruption Prosecutor’s Office, more and more suspected cases
of attempted political influence are becoming publicly known (for example, concerning the ORF and the
daily newspapers ‘Die Presse’, ‘oe24/Österreich’, ‘Heute’ und ‘Kronen Zeitung’). So, it seems that the
existing legal provisions for the private media sector, rated as low risk by the MPM, cannot effectively
safeguard political
independence and independence from commercial and owner influence in practice –
which indicates a lack of control mechanisms. In addition, political influence on ORF is facilitated by some
procedures provided by law for appointing the members of the highest management body and electing the
Director-General (which have now been ruled unconstitutional by the Constitutional Court). In too many
newsrooms, strong and comprehensive editorial statutes and other self-regulatory measures that ensure
editorial autonomy and guarantee transparency of editors-in-chief appointment and dismissal procedures
are missing. The extraordinarily high state advertising expenditures, amounting to 225 million euros in 2021
and 201.4 million in 2022, is another factor that can raise doubts about the political independence of the
media and reduce trust in them.

There is a certain lack of transparency in the disclosure of political parties' online campaign costs, in the
criteria for awarding state advertising contracts, in the labelling of paid content, in the procedures for
appointing and dismissing editors-in-chief, and in the disclosure of media ownership (information on the
ultimate ownership structures of media companies is not generally available). Only regarding awarding state
advertising contracts to media companies are amended legal provisions intended to ensure greater
transparency. Women and minorities are largely underrepresented in media content and media
management, and a comprehensive policy (and adequate resources) for fighting disinformation and hate
speech and promoting media literacy is missing.

Mentioning some of these risk factors in its most recent assessment, Reporters Without Borders (2023)
ranked Austria only 29th in its World Press Freedom Index in 2023 and only 32nd in the recently published
index for 2024. That is two places better than last year, but since 2019, Austria is no longer among the
countries where media freedom is best protected. This should set alarm bells ringing among politicians and
regulators.

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  Focus on the digital environment

In three of the four MPM areas, the risk measured in the digital environment is above the general
level.

Plurality in digital markets has reached a level that signals a high risk (69% compared to the
already high figure of 65% in general). The digital market is dominated by a few global platforms, and
the associated migration of exorbitantly high and rapidly increasing advertising expenditure to these
global platforms jeopardises the viability of national providers and, ultimately, the national media
market in general.

At 62%, the risk in the area of Political independence is also above the general value of 41% and
close to the high-risk threshold. This is mainly due to inadequate regulations to disclose online
political advertising spending and the increasing control of political parties over a steadily growing part
of the online news sector.

Concerning Social Inclusion (for which there is a 58% risk), disinformation, hate speech (including
persistent
threaten media
freedom.

threats to journalists), and the population's low media literacy level

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3.1. Fundamental Protection (30% - low 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.

Fundamental Protection of the media is, to a large extent, guaranteed in Austria (30% – low risk). This
also applies to the digital environment. However, there are violations of the spirit of the law and deficiencies
in the legal and social protection of journalists. Online threats and harassment against journalists are
becoming a major problem, and a new law on the right to information, which was subject to struggle for
decades and will not come into force until 2025, only partially meets the expectations from a democratic
perspective.

For the first time, Protection of freedom of expression is at medium risk (35%). At the legal level, it has
been enshrined in Austria’s constitution since 1867 (Art. 149 Federal Constitutional Law, 1930/2020,
referring to Art. 13 Staatsgrundgesetz, 1867). In 1958, Austria ratified the European Convention on Human
Rights (which was given constitutional status six years later) and, in 1978, the International Covenant on
Civil and Political Rights (ICCPR). All these constitutional guarantees also apply to freedom of expression
online, which is handled carefully in copyright law and platform regulation.

In practice, however, highly recognized NGOs complain that there has recently been “violence at public
events [that has] prevented journalists from reporting freely”, that “press freedom has been undermined by
various political pressures or restrictions on access to information”, (Reporters Without Borders, 2023) and
(Forum
that
Informationsfreiheit, 2023). This development is one of the main reasons why Austria only ranks 29th (2023)
and 32nd (2024) in the ‘World Press Freedom Index’, and the index value for the ‘Media’ pillar of the
Austrian ‘Democracy Index’ fell by 7.1 points to 60.2% in 2023 compared to the previous year.

“attempts by politicians to discredit serious journalism” have become more frequent

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The provisions of the Criminal Code on defamation of the Republic of Austria or one of its federal provinces,
the parliamentary bodies at the federal and provincial levels, the federal army and the authorities also pose
a serious threat to freedom of expression in the legal sphere, as they provide for an increased prison
sentence (up to one year) for defamation if this is made accessible to a wider public via the mass media (§§
111, 115, 116, 248 (1) Bundesgesetz vom 23. Jänner 1974 über die mit gerichtlicher Strafe bedrohten
Handlungen [Federal Act of January 23, 1974, on Acts Punishable by Law]). Insulting the Austrian federal
flag, an Austrian provincial flag, a national emblem, the federal or provincial anthem (§ 248 (2)), a state-
recognised church or religious community and a religious doctrine or custom (§ 188) is punishable by up to
six months in prison or a fine of 360 daily rates.

Protection of the right to information is at medium risk (52%). The slightly lower risk level (compared to
previous years) is because, after decades of struggle, the government submitted a new law on the right to
information to parliament on October 6, 2023. It was adopted on January 31, 2024, but will not come into
force until September 2025 (Bundesgesetz, mit dem das Bundes-Verfassungsgesetz geändert und ein
Informationsfreiheitsgesetz erlassen wird [Federal Act amending the Federal Constitutional Act and
enacting a Freedom of Information Act], 2024). While this will finally abolish official secrecy in Austria, there
has been much criticism because municipalities with fewer than 5,000 inhabitants – i.e. 1,834 out of 2,093
municipalities – are exempt from any proactive publication obligation and § 6 (1) provides for far-reaching
exemptions from the publication obligation. Moreover, failure to disclose information that must be published
proactively is not subject to sanctions and does not lead to any legal consequences.

The EU Whistleblowing Directive (European Parliament and Council, 2019b) was transposed into national
law in February 2023 (HinweisgeberInnenschutzgesetz – HSchG [(Whistleblower Protection Act], 2023)
after the European Commission had opened infringement proceedings against Austria because of missing
the 2021 deadline. NGOs like Amnesty International (2023) and Transparency International (2023) criticized
the fact that public consultation had not occurred and that the law has numerous weaknesses that limit its
effectiveness from the outset. For example, the handling of anonymous reports is insufficiently regulated,
there are restrictions depending on the size of the company or the report's content, and administrative
penalties for false reports could deter potential whistleblowers. The positive connotation whistleblowing
holds in Austrian society (Frohner, 2022) would have allowed a more comprehensive law.

The Journalistic profession, standards and protection indicator once again exceeded the medium risk
threshold (35%), as it did in 2021. ‘Mapping Media Freedom’ by the European Centre for Press and Media
Freedom reported several attacks on journalists' physical safety by politicians of the right-wing Freedom
Party and fans of the German rock band Rammstein. Reporters Without Borders (2023) accused the police
of preventing journalists from reporting or harassing them with identity checks in some cases. In June 2023,
the public prosecutor’s office ordered the confiscation of cell phones, computers and tablets belonging to a
investigative news site and reports on alleged abuses in local
Carinthian journalist who runs a local
government. The case was dropped a few days later because the order was illegal (#doublecheck, 2023).
Moreover, the number of SLAPPs is increasing (not to mention the unreported cases), and the pressure
built by threatening SLAPPs alone is causing incalculable damage (Strobl, 2024). While legal safeguards
against SLAPPs are still missing in Austria, the European Parliament adopted the Anti-SLAPP Directive in
February 2024, which the Austrian government must transpose into national law.

While access to the profession is free and open, and § 31 Media Act provides strong protection for the
confidentiality of journalists’ sources (Federal Act on the Press and other Publication Media, 1981/2023), the
working conditions of journalists are worsening (Resei & Kraus, 2023). One-third of Austrian journalists (with

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45% of women journalists) are only part-time employed, 20% have additional jobs outside journalism and an
estimated 10% work as freelance journalists facing uneasy social conditions because they are neither
protected by social security systems nor insured against unemployment, and they must take out costly
voluntary insurance themselves (Kaltenbrunner et al., 2020).

Regarding journalistic standards, the 2010 re-established Austrian Press Council, which has published a
Code of Ethics, only encompasses print media and their online platforms, news agencies, and – since 2021
– community radio and television stations. Even with these media, granting subsidies is not
tied to
membership to the Council or compliance with ethical standards. The Press Council’s financial situation is
not sufficiently secured, and all sponsoring organizations would have to jointly decide on publishing its
judgments in all member media outlets. This often fails due to the veto of the publishers’ associations. In
2023, the Austrian government established the ‘Media Hub Austria’ (Bundesgesetz über die Wiener Zeitung
GmbH und Einrichtung einer elektronischen Verlautbarungs- und Informationsplattform des Bundes), a state-
run journalism training centre endowed with an annual budget of 6 million euros – more than the budgets of
all existing private training initiatives combined. Critics see this as threatening journalistic independence
(Presseclub Concordia, 2023).

The indicator for Independence and effectiveness of the media authority remains at a very low risk level
(3%). The 2001 established Austrian Communications Authority (KommAustria) is legally distinct and
functionally and effectively independent from the government and any other public or private body. No
governmental
individual or body can issue instructions to the media authority (§ 6 Federal Act on the
Establishment of an Austrian Communications Authority). Decisions and holding public consultations, which
are mandatory before all decisions, must be published. In media matters (such as monitoring net neutrality,
among others), KommAustria is operationally supported by the Austrian Regulatory Authority for
Broadcasting and Telecommunications (RTR), a non-profit state-owned company. KommAustria is
accountable to the court of auditors; RTR is subject to periodic review by external private auditors.

Finally, the indicator on Universal reach of traditional media and access to the internet shows a low but
increasing risk (27 compared to 8% in 2023) because the percentage of
the population covered by
broadband connections is rising too slowly and remains in the midfield at 94.7%. In traditional media, public
TV and radio signals reach almost everyone.

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  Focus on the digital environment

The slow increase in the supply of broadband connections to the population is one of the main
reasons for the growing risk in the area of Fundamental Protection in the digital environment (30%
compared to 19% in 2023). Even more worrying is the fact that online threats and harassment against
journalists – and especially female journalists – have become “commonplace” (Reporters Without
Borders, 2023). However, this is still a taboo subject, and there is not only a lack of accurate data but,
in many cases, a lack of appropriate protection and support measures.

A somewhat unclear situation has arisen regarding journalism and data protection. On the one hand,
the Austrian legislator has complied with Directive (EU) 2016/680 of the European Parliament and
Council (2016), which prevents illegal surveillance of journalists by law enforcement authorities by
formulating Article 9 in the Data Protection Act. In December 2022, however, the Constitutional Court
ruled that exemptions for media companies in § 9 (1) are unconstitutional. Data processing for
journalistic purposes may not be generally exempted from the Act’s provisions, as this media privilege
violates the fundamental right to data protection. The legislator must now ensure a more differentiated
balance between the interests of individual persons in data protection, also with regard to the media,
and the requirements of journalistic work protected by Article 10 of the European Convention on
Human Rights by mid-2024.

In accordance with a ruling by the European Union Court of Justice in November 2023, which states
that a national law regulating communications platforms cannot be binding on companies based in a
different country, the 2021 Act on Measures to Protect Users on Communications Platforms will be
replaced by Digital Services Act (DSA), the accompanying regulation of which came into force by
February 17, 2024, and applies to all intermediary services (DSA-Begleitgesetz, 2023). Since then,
the media authority KommAustria is the national “Digital Services Coordinator” (RTR, 2024). In the
last year of validity of the previous law, X (formerly Twitter) did not report about filtering and removals.

In general, websites are not blocked or filtered arbitrarily due to official decrees. In monitoring net
neutrality,
the Regulatory Authority balances legal protection and the fundamental rights of all
stakeholders concerned. Legal provisions requiring Internet Service Providers (ISPs) to set up blocks
can be found in the Copyright Act, which transposed the EU Copyright Directive (European
Parliament and Council, 2019a) into national law in December 2021 (Urheberrechts-Novelle). The EU
Court of Justice concedes that, despite some room for improvement, the transposition of the Directive
in principle meets the Court’s standards because ex-ante safeguards against over-blocking (such as
quantitative minimum thresholds for the use of upload filters and “pre-flagging”), as well as additional
procedural safeguards that can be invoked ex-post, are foreseen (European Digital Rights, 2022;
Reda & Keller, 2022). Based on data from 2023, the Varieties of Democracies project (V-Dem) of the
University of Gothenburg ranks Austria among the countries with unrestricted Internet access.

An important exception to this general policy was the extraordinary measure taken by the Austrian
parliament to block those Russian media channels affected by EU sanctions against Russia over its
war on Ukraine (European Council Decisions between March 1, 2022, and September 28, 2023)
(KommAustria, 2023).

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3.2. Market Plurality (65% - medium risk)

The Market Plurality area considers the economic dimension of media pluralism, assessing the risks
deriving from insufficient transparency in media ownership, the concentration of the market in terms of both
production and distribution, the sustainability of media content production, and the influence of commercial
interests and ownership on editorial content. The actors included in the assessment are media content
providers, with indicators including Transparency of media ownership, Plurality of media providers, Media
viability, Editorial independence from commercial and ownership influence, and digital intermediaries (with
the indicator on Plurality in digital markets).

Market Plurality area is at medium risk (65%). Even if it records a decrease in the risk level (compared
with last year assessment), it is very close to the high risk threshold. This is mainly related to the declining
market viability accompanied by a high degree of concentration in traditional and digital media markets. All
three indicators point to high risk.

The indicator Plurality of media providers shows the highest risk in this area (81%). Horizontal
concentration, measured by the Top 4 indexes for market revenues and audience, is between 70 and 92%
in the audiovisual, radio and newspaper sectors (data from 2023), and the market share of the Top 4 news
media owners across different media markets is 64% (based on 2022 data of the twenty largest media
companies tax-registered in Austria, not including platforms). Only the audience share of the Top 4 online
news media outlets (not including platforms!) is still in the middle ground, at 42% (unique users, data from
2023). The Austrian media authority does not officially provide most of the numbers; they are based on the
authors’ calculations using data provided by Österreichische Auflagenkontrolle, RMS Austria, AGTT,
Österreichische Webanalyse and Fidler (2023).

If one considers the legal provisions, two weak points become apparent. The first problem is that only
legislation for the audiovisual sector contains specific restrictions regarding areas of distribution and market
shares to prevent horizontal and cross-media concentration; for all other media sectors, only cartel
law
provides media-specific merger control provisions. For example, specific multipliers must be applied to the
revenues to assess jurisdiction. The second problem is that all these restraints are not very tight (Holoubek
et al., 2014; Seethaler & Beaufort, 2019). Ultimately, media and cartel laws, while establishing diversity of

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independent media companies as a top priority, have been largely ineffective in preventing mergers of
media companies for decades – this is one of the causes of the high level of media concentration, which is
increasingly extending to the online sector: The leading traditional news media owners are also occupying
leading positions in the online news sector (in terms of market share): Mediaprint, ORF, Styria Media Group
and Digitale Medien GmbH (‘Heute’, a free daily).

Concerning Media viability, the risk level decreased from 74% in the previous year to 68%. After a short-
term economic recovery following the end of the COVID-19 crisis, the situation on the media markets
deteriorated again in 2022. While Austriaʼs economy recorded a decline of 0.8% in 2023 (GDP in real
terms), the advertising year closed with a total volume of 4.67 billion euros, representing only a slight
increase of 0.3% compared to 2023. This is less than the 0.8% increase from 2021 to 2022, which,
however, was well below the GDP growth of 5%. The biggest gains in the advertising market were recorded
by ‘classic’ online media (8.5%) and private (mostly regional) radio stations (7.8%), while daily newspapers
(-3.9%), private TV (-2.2%) and regional weeklies (-0.9%) experienced losses (Focus Marketing Research,
2024). It can, therefore, be assumed that regional and local broadcasting works quite well and that regional
and local newspapers seem to be at least in a less precarious but nevertheless deteriorating position. These
mixed year-end results make forecasts difficult; however,
the long-lasting decline of newspapers will
certainly continue, and television will have to struggle for its market position. Several major newspaper and
television newsrooms have cut salaries and jobs in these troubled times. The number of employed
journalists has been declining for years, and this decline is primarily attributable to the print sector, where
most journalists traditionally work.

Even a long-established system of state subsidies covering all traditional media sectors cannot stop this
development, as the criteria for supporting market diversity and journalistic quality are insufficient (e.g., APA
News & Horizont Redaktion, 2023). Moreover, no substantial subsidies are available for digital native media.
Even for the “Fund to Promote Digital Transformation”, fed from 2020 Digital Tax Act revenues, online-only
media are not eligible to apply. The extent to which this fund will be effective cannot yet be said, but
awarding practices continue to reveal a preference for large media companies – and those that had started
late to develop digital offerings (Binder, 2022; iab Austria, 2023). On the one hand, the existence of local
newspapers, which are still comparatively well positioned on the market, could be jeopardized by this
funding strategy (Beaufort & Schulz-Tomančok, 2024). On the other hand, this strategy is detrimental to
innovative business and editorial approaches (Meier et al., 2022), especially as the willingness to pay for
online news, which at 14.3% is mediocre anyway, is growing slowly and for the first time only includes the
under-35s (Gadringer et al., 2023).

Transparency of media ownership is at medium risk (56%). Although § 25 Media Act contains provisions
to ensure transparency of media ownership (which also apply to any online media except small
personal/private websites), information on the ultimate ownership structures of media companies is not
generally available, partly due to a vague formulation in the 2011 amendment to the law: the German word
Inhaber can be interpreted as ‘100% owner’ (Berka et al., 2019). In some cases, the relevant information is
provided in a way that, as Access Info Europe criticizes, “can be considered difficult for an ordinary member
of the public to find or decipher the information available” (Craufurd Smith & Stolte, 2014, p. 19). Moreover,
foreign media are only covered by the transparency provisions when they are “completely or almost
exclusively” distributed in Austria (§ 50 Media Act). Similar exclusions apply to foreign state publications and
publications of Austrian public authorities. Only PSM is required by media law to make its annual and
consolidated financial statements publicly available (§ 7 (4) ORF Act).

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A similar risk level (53%) is revealed by the indicator for Editorial independence from commercial and
owners' influence. On the one hand, in all media sectors (and even applying to native advertising and
influencer marketing), rules exist that prevent the use of advertorials (Berka et al., 2019). Advertising and
journalistic contributions must be clearly separated and marked (which is in line with Commission
Recommendation (EU) 2022/1634, Art. 7/d). On the other hand, cases of commercial
influence are
repeatedly reported. For years, and also in 2023, the media authority KommAustria ruled in several cases
that paid content in television broadcasts is not sufficiently labelled as advertising and is separated from the
editorial content. In previous years, the Austrian Press Council also criticized similar cases in the print
the Supreme Court and the Supreme
media. However,
Administrative Court regarding the regulation of audiovisual advertising (§ 2 (2) and (40) Audiovisual Media
Services Act) and the regulation of the labelling requirements for advertising in print media (§ 26 Media Act)
insofar as the latter requirements only refer to advertisements for which a fee is actually paid directly. This
influence on the editorial staff (see VfGH, E 992/2022-12, E 1265/2022-13,
may increase commercial
5.12.2022). Furthermore, little is known of relatively new phenomena such as content marketing, brand
journalism, corporate publishing, and native advertising.

there are differences in the case law of

A similarly ambivalent situation can be observed concerning journalism and advertising. PSM law (§§ 13 (3),
14 (10) and 16 (5) ORF Act) and private broadcasting law (§§ 32 (2) and 37 (1) Audiovisual Media Act, and
§§ 19 (4c) and (5b) Private Radio Broadcasting Act) contain rules which aim to prevent journalists to base
editorial decisions on commercial interests. However, regarding print media and their online editions, only a
short statement in the Journalistic Code of Ethics (which applies only to members of the Press Council)
recommends that the economic interests of the media company owner should not influence editorial work.
Another statement in the Code of Ethics refers to disclosing conflicts of interest in financial and economic
reporting. Still, no legal provisions exist concerning the incompatibility of the exercise of the journalistic
profession with advertising activities, and there is no obligation to disclose conflicts of interest arising from
news organisations' editorial and commercial activities. This is, for example, the case for the energy drink
company Red Bull, which owns and operates a TV station, online platforms, and magazines. Some
researchers argue that economic interests intentionally influence editorial content in such arrangements
(Kaltenbrunner et al., 2020).

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  Focus on the digital environment

The threshold for high risk in the area of Market Plurality has been crossed in the digital environment
(69%). This is due to the indicator Plurality in digital markets, which shows an equally high risk.

In 2022, the Austrian online advertising market had grown by about 22% to 2.365 billion euros
(Momentum, 2022). Based on digital
tax revenues of 96 million euros and a tax rate of 5%
(Bundesministerium für Finanzen, 2023), it can be assumed that, in 2022, the global platforms
generated around 1.92 billion in advertising revenues – this is an increase of at least 11.6% compared
to the previous year. The four biggest players – Alphabet (which owns Google and YouTube), Meta,
TikTok and Microsoft Bing – account for 72.3% of the Austrian online advertising market, i.e. more
than 1.7 billion euros. In comparison, ORF’s revenue from online advertising amounted to 19.5 million
in 2022. Despite a huge number of online offerings, the audience share of the Top 4 online players is
60% (unique users, data from 2023, provided by Datareportal and oewa.at). The migration of
advertising revenue to global platforms and the limited opportunities for digital native media to apply
for state funding compared to traditional media jeopardize the viability of the national digital market.
The fact that there are only a few successful digital native media in Austria tend to confirm this idea.

initiated sector

Concerning the role of antitrust authorities regarding the digital economy, Fussenegger & Robertson
(2020, p.19) argue that “so far, the BWB (Bundeswettbewersbehörde [Federal Competition Authority])
traditional media
has not
undertakings (publishing houses, free tv channels) but also traditional advertising undertakings claim
that online advertising suppresses more and more traditional advertising in print titles or in free tv.
Following such comments, the previous approach which defines separate product markets, e.g., for
advertisement in newspapers, magazines, classified ads or in free tv, would be arguably too narrow.” 

inquiries concerning online advertising.

In general,

On December 20, 2023,
the Minimum Taxation Reform Act passed the Austrian parliament
In accordance with Council Directive (EU) 2022/2523 of 14
(Mindestbesteuerungsreformgesetz).
December 2022, the Act provides for the introduction of the Pillar Two income inclusion rule (IIR) and
the undertaxed payment/profit rule (UTPR) to ensure a minimum tax level of 15% for multinational
enterprise groups with annual consolidated revenue of at least EUR 750 million in at least two of the
preceding four fiscal years. The Act also provides for introducing a qualified domestic minimum top-up
tax (QDMTT) for members of in-scope groups, which Austria refers to as a national supplementary
tax. The law applies to financial years beginning on or after December 31, 2023 (wts global, 2024).

Austria had already introduced a unilateral digital tax in 2020 (Digital Tax Act) but has joined the
Unilateral Measures Compromise in 2021, which aims to stop the proliferation of Digital Services
Taxes by replacing them with a consensus-based reallocation of taxing rights. This compromise –
agreed upon by the U.S., Austria and several other countries – covered the interim period (“Pillar
One”) between January 2022 and December 31, 2023 (Bloomberg Tax, 2023). The digital tax levied
until the end of 2023 generated tax revenue of 56.6 million euros in 2020, 80.2 million euros in 2021,
96 million in 2022, and 103 million in 2023 (Bundesministerium für Finanzen, 2024). 134 million euros
from this pot will be used from 2022 to 2027 (and retroactively for 2021) to support the digital
transformation of Austrian legacy media. Therefore, the Digital Tax Act was effective during its
existence, but ultimately, it has not proven to be an effective long-term solution.

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3.3. Political Independence (41% - medium risk)

The Political
Independence indicators assess the existence and effectiveness of regulatory and self-
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 ambivalence of the relationship between media and politics, typical of a democratic-corporatist country
like Austria (Hallin & Mancini, 2004; Seethaler & Melischek, 2006), is reflected in the widely differing MPM
scores for the assessment of risks in the area of Political Independence, which is – similar to the previous
year – assigned an overall medium risk of 41%.

Although their scope is far from comprehensive, the existing regulatory safeguards in the audiovisual and
radio sector aim to preclude state entities and political parties, as defined in the Political Parties Act, from
media ownership (§ 8 (1) and (2) Private Radio Broadcasting Act; § 10 (2) Audiovisual Media Act) and
government officials, MPs and party leaders and employees from PSM executive management positions, at
least if the held those positions within the last four years (§ 26 (2) ORF Act). Even if there is no comparable
legal regulation in the newspaper sector, ownership structures generally do not overlap with the political
sector. All things considered, and taking into account the independence of Austria’s only big news agency,
the Austrian Press Agency (APA), from political groupings – it is owned by twelve Austrian newspapers and
the ORF –, the risk to the Political independence of media appears to be low (25%).

However, concerning the largest private television provider, the German group ProSiebenSat.1, it must be
noted that, some time after Germany, the Austrian competition authority approved MediaforEurope’s plan to
increase its direct stake in ProSiebenSat.1 to almost 30% on February 8, 2024. This move will enable the
Berlusconi Family, the owner of MediaForEurope, to control the majority of voting rights at shareholder
meetings and thus have de facto sole control over the company (Reuters, 2024).

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In contrast to the regulatory provisions that aim to prevent political control over media ownership, Editorial
autonomy is – for the first time – at high risk (69%). Information on the appointment and dismissal
procedures of editors-in-chief is hardly publicly available, and the framework of self-regulatory measures
that should guarantee freedom from interference in editorial decisions and content is underdeveloped.
Concerning the latter aspect, there are several factors to consider. Firstly, only a few editorial statutes are in
place to restrict influence on editors-in-chief's appointment and dismissal procedures. Secondly, only TV
and radio stations are obliged to have editorial statutes; all other media are allowed to establish such
statutes but are not required. Thus, it is no surprise that the largest newspaper and one of the biggest online
the Kronen Zeitung (which is among the primary beneficiaries of state advertising
news providers,
spending), refrains from any self-regulatory measures. Thirdly, the Press Council, which is only responsible
for parts of the media industry (see Chapter 3.1), lacks the power to impose penalties and compensation
measures and has to rely on ‘soft’ sanctions such as naming, shaming, and blaming.

Numerous revelations from the Economic and Corruption Prosecutor’s Office investigations have shown
intense pressure from political actors on editorial offices. Besides the former Federal Chancellor Sebastian
Kurz, two editors-in-chief (‘Die Presse’, ORF) also had to resign as a result of these investigations; in other
cases, the media house “Österreich”, the free daily newspaper Heute, the Kronen-Zeitung and an opinion
research company are suspected of being involved. In the Lower Austrian election campaign of 2022/23,
favouritism for the ruling party in ORF coverage led to the suspension and, finally, the resignation of the
head of the regional studio; another ORF journalist made an appearance at an election rally for that party
(e.g., Dave, 2022; Dossier, 2022; Wurnitsch, 2023).

Threats to editorial autonomy due to political influences are the main reason Austria has fallen from 26th to
33rd in the “Political context” sub-index of the Press Freedom Index. Even if, in those editorial offices where
journalists are better equipped to defend themselves collectively against
editorial statutes exist,
interference, more binding and more comprehensive instruments of self-regulation aimed at resisting
political pressure are urgently needed – given the decline in trust in the Austrian media, which has fallen
from 40.6 in 2022 to 38.3% (Gadringer et al., 2023).

The indicator Audiovisual media, online platforms and elections is slightly above the limit of middle risk
(36%). This is mainly because in the current ‘super election year’, the lack of studies on the role of
commercial broadcasters is particularly regrettable – especially since ‘Servus TV’, the private television
channel with the largest reach (4.3%), which the Red Bull company finances, had been accused of
distorting formulations and disinformation during the COVID-19 pandemic (KommAustria, 2023). On the
other hand, public service media is obliged by law to cover political matters unbiased and impartial (§ 1 (3)
ORF Act), and KommAustria is responsible for legal supervision. Moreover, this legal provision is detailed in
the ORF editorial statute (ORF, 2022).
In practice, all parties with parliamentary representation can
participate in unbiased election debates. This can “be seen as an obstacle to new parties”, as the
Bertelsmann Stiftung (Helms et al., 2022, p. 29) states in its evaluation of the electoral process in Austria.
Nevertheless, for at least the last two decades, the ORF has, to a considerable extent, offered a fair
representation of the various parliamentary parties during election campaigns (Seethaler & Melischek, 2014,
2019; OSCE, 2019).

Since 2002, political advertising in public service television programmes has not been allowed during
election campaigns.
from private TV stations and must be identified as paid
advertising – according to § 31 (1) Audiovisual Media Act (2001/2022), which, after a 2020 amendment,
applies to all audiovisual media services, among them video-sharing platforms such as YouTube and

It may only be bought

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Dailymotion and social media such as Facebook and Instagram (Berka et al., 2020). Moreover, media
companies are urged to provide all parties with equal conditions for advertising because the principle of
equal opportunities for all political parties is enshrined in the Federal Constitution (1930/2020). However,
only concerning the online platform of the public service broadcaster, self-regulation is in place that aims to
ensure fairness of online political advertising during electoral campaigns (ORF Enterprise, 2019).

The indicator State regulation of resources and support to the media sector shows a low risk (21%)
and thus scores better than in the last years. This is mainly due to the recently amended Transparency in
insertions and
Media Cooperation and Funding Act. According to this urgently needed amendment, all
media cooperations must be reported to the Austrian Regulatory Authority for Broadcasting and
Telecommunications (RTR) regardless of the medium's publication frequency and the amount involved; the
previous de minimis limit of 5,000 euros has been dropped. The reporting obligations have also been
extended to social media, poster advertising, and cinema advertising. A transparency report must be
prepared and published for every campaign with a budget volume of more than 150,000 euros, and an
impact analysis must be carried out in addition to the transparency report for every campaign with a budget
of one million euros or more. The penalty for failure to report has been doubled and will be 60,000 euros
and 100,000 euros in case of a repeat offence. All information on public legal entities’ insertions and media
cooperations will be published on the RTR website. The previous obligation to delete transparency data
after two years has been lifted. While, in 2021, state advertising expenditures had reached a record high
(225 million euros), they declined in 2022 by 11% (201 million euros), and this trend is likely to have
continued in 2023 (see the calculations of the University of Applied Sciences Joanneum, Graz, based on
data provided by RTR). However, state advertising spending that flowed to Google and Meta (the parent
company of Facebook and Instagram) increased in the first quarter of 2023 by 10% and 22%, respectively
(Kienzl, 2023). Because the amended law does not set a cap on the placement of state advertising, it
remains to be seen whether greater transparency will go hand in hand with greater fairness.

Concerning the distribution of media subsidies, the rules can be considered transparent but not fair. Austria
has a wide range of subsidies, but, in general, the primary beneficiaries are and have always been big
media companies. This also applies to the recently established ‘Fund to Promote Digital Transformation’,
from which digital native media are excluded (Horizont Redaktion, 2022). This financing logic, which has
been practised for decades, has not prevented the permanently increasing horizontal and cross-media
concentration (Trappel & Tomaz, 2021; Seethaler, 2024) and now threatens the existence of rather small
local and regional media offerings (Beaufort & Schulz-Tomančok, 2024). The Concordia Press Club has
long been calling for a reform of both the funding system and the allocation of state advertising in favour of
journalistic quality – regardless of the platform (Resei & Kraus, 2023). Whether a new fund endowed with 20
million euros per year will change the funding policy remains to be seen. It is based on the Quality
Journalism Promotion Act (Qualitäts-Journalismus-Förderungs-Gesetz, 2023), approved by the European
Commission in November 2023.

§ 54 of the Telecommunications Act (Bundesgesetz, mit dem ein Telekommunikationsgesetz erlassen wird
transparent and non-
[Federal Act enacting the Telecommunications Act]) guarantees impartial,
discriminatory spectrum allocation in accordance with EU requirements.

Independence of public service media is at medium risk (52%). The reason why the risk level fell from
high to medium in the previous year is due to changes in the questionnaire: The two questions on the legal
provisions for ensuring that the appointment procedures of the Director General and the management are
independent of political influences have been combined into one question; likewise, the two questions on

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the practice of the appointment procedures of the Director General and the management have been
combined into one. Two new questions were also added last year: the question about political influences on
the editorial line and the question about regulatory safeguards ensuring that State funds granted to PSM do
not exceed what is necessary to provide the public service (which was previously part of the indicator
“Competition enforcement”).

For many years, MPM has been criticized that the provisions of § 20 (1) ORF Act give the federal and state
governments a great deal of power in appointing the members of the Foundation Council: 15 of its 35
members are appointed by the federal government, six of them considering the proportionate strength of the
political parties represented in parliament. In addition, each of the nine Austrian federal provinces nominates
one representative. Another six members are delegated by the ORF’s Audience Council, the majority of
whose members are, in turn, appointed by the Federal Chancellor (§ 28 (3) ORF Act). Overall, these rules
enable the government to appoint at least a simple majority of the 35 members of the Foundation Council. A
simple majority is sufficient for most of its decisions, including appointing the Director-General and the
directors. In October 2023, the Constitutional Court annulled several of the provisions on the composition
influence on PSB
the two bodies, which provide a major gateway for political
and appointment of
management, as unconstitutional, as they violate the requirement of
independence and pluralistic
composition of these bodies enshrined in Art I para 2 of the Federal Constitutional Act on Guaranteeing the
Independence of Broadcasting. The unconstitutional provisions will expire at the end of March 31, 2025.
The legislator has until then to adopt new regulations.

While the appointment procedures for the Foundation and Audience Council, the Director-General and the
directors are strongly influenced by the governing parties (Vogt, 2021), the ORF’s editorial statute (ORF,
2022) can be considered as an important safeguard for strengthening politically independent journalism. It
stipulates that the editorial assembly must be informed and heard during appointment procedures of editors-
in-chief and managing editors. The editorial assembly has the right to submit proposals for such decisions.

Due to the increasing number of users who watch ORF programmes exclusively online and free of charge,
the ORF was threatened with a budget gap of an estimated 70 million euros from 2024. Following a ruling
by the Constitutional Court in 2022, which called on the government to close this loophole, a ‘household
levy’ was introduced in January 2024 to replace the previous PSB fee. The amendment to the ORF Act also
lifted some restrictions on the public service broadcaster’s Internet presence but imposed some new ones.
For example, the total number of text contributions on the start and overview website may not exceed 350
per calendar week (!), and only 30% of all online articles may be text-based. Experts doubt that these
restrictions can alleviate the enormous economic pressure on the commercial media, considering that online
advertising revenues of more than 2 billion euros go to the global platforms, while ORF's online advertising
revenue amounts to 19.5 million euros.

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  Focus on the digital environment

In the digital environment, the risk to Political Independence is even higher (62%) than the overall
risk. There are two outstanding reasons for this.

(e.g.,

‘media-party parallelism’

kontrast.at, unzensuriert.at,

is experiencing a revival. However,

First, the number of digital native media with a more or less transparent closeness to political actors is
rapidly growing. Those media outlets are owned by parliamentary clubs of political parties, ex-MPs,
and/or party-affiliated donors
zur-sache.at, exxpress.at,
zackzack.at, neuezeit.at, wochenblick.at, materie.at, YouTube channel ‘FPÖ TV’). It seems that the
traditional
they do not
necessarily have to aim for a high frequency of use to make an impact but frequent sharing of their
content through social media. Political control over the digital native media market thus seems to be
increasing. The right-wing exxpress.at reached more than 15% of Austrian internet users in the first
half of 2023 (oewa.at), but there is a lack of awareness of the problem in political and regulatory
debate (Bonavida & Winter, 2022; Knittelfelder, 2021). The problem is exacerbated by the fact that
digital native media are hardly entitled to any subsidies, including the ‘Fund to Promote Digital
Transformation’. Party media and party-affiliated media, on the other hand, are eligible for funding
because they also have a (small) foothold offline. This must be considered counterproductive for the
promotion of the political independence of the media.

this time,

Second, although the 2022 amendment to the Federal Act on the Financing of Political Parties has
brought more transparency and stricter rules for campaign financing and heavier sanctions for
violations, costs for online advertising only have to be reported as a lump sum (§ 4 (3): “expenses for
… advertisement and advertising … on the Internet”). Concerning the last parliamentary election in
2019, the Court of Audit published the accountability reports of all parliamentary parties. The lists of
election campaign costs are not very detailed; the costs of social media campaigns are not reported,
and no distinction is made between advertising spending for online editions of traditional media, digital
native news media and platforms such as Facebook and Google. Google’s Transparency Report and
Meta’s Ads Library, implemented in March and April 2019, provide online ad repositories that allow for
the monitoring of political advertising activities.

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3.4. Social Inclusiveness (49% - 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 disinformation and
hate speech.

Social Inclusiveness is ranked as being at medium risk (49%). The 5% increase compared to the previous
year is mainly due to shortcomings in political measures to support local media, the representation of
minorities in the media and protection against disinformation and hate speech.

The only exception is the indicator for Local/regional and community media, which still represents a low
but increasing risk (21% compared to 10% in the previous year). There are four reasons for this:

A significant number of television and radio frequencies are related to regional or local service areas
(‘Versorgungsgebiete’), and access to these frequencies is regulated via public tendering (§§ 30 (1)
and 54 (1b) Bundesgesetz, mit dem ein Telekommunikationsgesetz erlassen wird [Federal Act enacting
the Telecommunications Act]).

The public broadcaster operates regional broadcasting studios in all nine federal states, which provide
nine regionally broadcast radio programmes and TV newscasts (§§ 3 (2) and 5 (5) ORF Act).

Subsidies for private radio and television companies are contingent upon providing local or regional
programmes and promoting local and regional identities (Seethaler & Beaufort, 2017). However, the
situation in the newspaper sector is becoming increasingly challenging. This is mainly because the
highly concentrated structure of the local and regional media markets, uncertainties about postal
delivery, and the limited funding opportunities for local print media nourish fears of major closures of
local media in the short or medium term, which would lead to ‘news deserts’ in some areas if there is no
adequate political response to these problems (Beaufort & Schulz-Tomančok, 2024).

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Austria has a well-established system of community media. Broadcasting laws, however, still
lack
consistent legal recognition of community media as a third broadcasting sector in terms of function,
mode of operation and financing – even though they perform a wide range of valuable public functions,
they are firmly anchored in their respective local environment and operate independently from any
interference from the government, political parties and religious institutions (Biringer et al., 2022).
Community broadcasters have voluntarily committed to the Code of Ethics, which they have been
allowed to join since 2021. There is a separate promotion fund for non-commercial local radio and TV
broadcasters endowed with five million euros annually, the conditions of which are more demanding
than for commercial broadcasting regarding democratic functions (Seethaler & Beaufort, 2017).
Unfortunately, § 54 Telecommunications Act does not provide sufficient details about
licensing
processes and criteria concerning reserving TV or radio frequencies for community media. As a result,
the number of three community TV and 14 radio stations has stagnated for years.

The indicator Representation of minorities in the media shows a medium risk (61%). The 5% increase
compared to the previous year is attributable to the fact that the public service broadcaster, as a whole,
does not have a comprehensive diversity policy covering both policy covering both personnel issues and
programming content. Only one of its radio stations, the rather small FM4, explicitly pursues a diversity
the
policy in personnel matters and programming (ORF, 2023b, pp. 44-46). This question is part of
questionnaire for the first time this year. Nevertheless, PSM law guarantees the representation of the six
legally recognized minority groups and requires an ‘appropriate’ share of airtime (§§ 5 (1) and 4 (1) ORF Act
). Albeit the law does not provide any framework for the assessment of ‘appropriateness’, the public service
broadcaster complies with the spirit of the law to a considerable extent. This does not apply to minorities,
which are not recognised by law.

In the private broadcasting sector, commercial television and radio stations do not provide any airtime for
minorities, whereas the much smaller and financially weaker non-commercial community TV and radio
stations broadcast programmes in more than 40 different languages, making no differences in access to
airtime for legally recognized and not recognized minorities. About a third of all community programme
producers are from a migrant background (Verband Freier Radios Österreich, 2019). This potential and
know-how can be considered worthy of support, as access to broadcasting time for minorities not legally
recognised is more a question of editorial orientation than legal
instruments such as “reserved airtime”.
Considering that 26.4% of the people living in Austria have a migration background, more should be done to
safeguard proportionate access to media for minorities.

The 2020 Amendments to the ORF Act (§ 5 (2)) and the Audiovisual Media Services Act (§ 30 (3)) aim to
improve the accessibility of TV and video content in accordance with the state of technical development and
economic reasonableness. They affect all AV media content (broadcasting, on-demand services, video
sharing platforms) and provide a gradual but continuous increase in accessibility (sign language, written or
spoken subtitles, audio description). The new regulations require operators to create phased plans to
implement accessibility measures. Only providers of local television programmes and those with an annual
turnover of less than 500,000 euros are exempt. In addition, the Digital Transformation Fund approved in
December 2021 offers a financial incentive to increase the proportion of accessible media content. How well
the new measures will work remains to be seen. In recent years, only the public service broadcaster has
continuously improved the accessibility of media content for hearing and visually impaired people – though
there is still an imbalance between the extent of media access for hearing impaired people (relatively well
developed: in 2022, 46.8% of all programme hours of the four PSM TV channels provided subtitles) and

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visually impaired people (rather poorly developed: 7.4% of programme hours provided audio description)
(ORF, 2023a). In the private-commercial sector, ‘Puls 4’, part of the ProSiebenSat.1 group, offered subtitles
and sign language for 0.07% of its programmes in 2022 (Puls 4, 2023). Community media work towards
including people with special needs by making studios and equipment accessible.

The indicator Gender equality in the media is ranked as being at medium risk (50%). The 8% lower figure
compared to the previous year is mainly because – according to the continuous monitoring by APA-DeFacto
– the proportion of female politicians on ORF’s two main TV news programmes reached an all-time high of
37% in 2022 (based on the speaking time of politicians) (APA, 2023). However, women’s policy issues have
become less and less important since 2018/19 – which also applies to newspaper reporting, in which
women make up about a third of
the increased
representation of women must not conceal the fact that they are still underrepresented. No data exist for
private broadcasting. In recent years, several databases of women with expertise in several fields have
been established by the ORF and civil society initiatives such as FEMtech, Frauendomäne, Die
Expertinnen, and Frauennetzwerk Medien.

the actors in pictures (Pernegger, 2023). However,

In general, Austrian PSM law (§ 4 (1) ORF Act) provides a (rather vague) policy regarding equal
representation of several groups like women, disabled persons, acknowledged religious groups, etc.
Consequently, gender equality in programming content has not been monitored internally at ORF for long.
In 2020, the then-General Director introduced the so-called ‘50:50 challenge’, which aimed to encourage
programme-makers to voluntarily measure the share of women and men in their programmes, with equal
issues,
representation as a goal. Unfortunately, this initiative was dropped soon. Concerning personnel
since 2010, PSM law (§§ 30a, et seqq. ORF Act) provides a framework for actively ensuring gender equality
by stipulating a gender mainstreaming plan and requesting the ORF to continuously assess the status quo
of gender equality in the organization. The set target of a 45% share of women was achieved in 2019, but
the proportion has stagnated since then – with a strong downward trend in the two highest employment
groups. At the end of 2022, the gender pay gap was 12.0% (ORF, 2023a).

The share of women among PSM executives is 60%, and among the members of the Foundation Council,
34%. At the leading commercial broadcasters, the percentage of women on management boards or teams
is 45%, but no women are in the executive ranks. Only 12% of the editors-in-chief of the eight most relevant
media across all four sectors (audiovisual, radio, newspapers, digital native) are women.

Media literacy indicates a medium but slightly reduced risk (47%). Since 2023, ‘Basic digital education’ has
been compulsory at Austrian regular secondary schools and the lower stage of secondary academic school.
The focus here is on teaching children media literacy, reflective internet use, and playful access to digital
technology. Unfortunately, the media education project mediamanual.at, which has organized the popular
‘Media Literacy Award’ every year since 2001, will end its work in 2024 after the Federal Ministry of
Education, Science and Research no longer renewed its financial support. On the other hand, there are a lot
of corporate and civil society initiatives, and there is a strong commitment of community media to media
literacy through the development of critical and creative thinking and active participation in media content
production. However, a comprehensive governmental strategy fostering the development of media literacy
in all sections of society (as first recommended by the Directive 2010/13/EU of the European Parliament
and of the Council of 10 March 2010) is still missing. In line with the Audiovisual Media Services Directive
EU 2018/1808, RTR has published the most important legal principles and a few selected initiatives and
online services on its homepage since the fall of 2020. 88% of the Austrian population has basic or above
basic overall digital skills.

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Only a few uncoordinated initiatives have been launched in recent years regarding media literacy activities
in
targeting vulnerable groups. As the most important forerunners, APA launched the project ‘TopEasy’
2017, and ORF started to publish news in simple language during the COVID-19 crisis—on TV (ORF III),
radio, online, and on the teletext pages. This was followed by daily newspapers 'Kurier' and 'Kleine Zeitung'.
Civil society initiatives are rare (e.g., ‘barrierefrei aufgerollt’).

  Focus on the digital environment

In the digital environment, Social Inclusion has a medium risk (58%), which is higher than for the
media in general, as Protection against disinformation and hate speech is associated with an
almost high risk (65%).

“Protection from disinformation” is a separate 2022-2024 government programme chapter. Still, the
government is, at best, just beginning to develop some cornerstones of a national strategy, for
example, by presenting an action plan to combat deep fakes in May 2022. However, none of the
announced measures have yet been implemented. A comprehensive political strategy is missing, and
so are comprehensive studies on the impact of disinformation. As reported by the Digital News Report
2023, more than every third respondent (37.1%) expresses general concerns about being able to
distinguish between facts and false reports on the Internet: this means an increase of 6% compared
to 2022 (Gadringer et al., 2023).

After all, there is a limited number of fact-checking initiatives, most founded only in the last two years.
In this respect, no assessment can be made of their impact. For example, in November 2022, the
Austrian Press Agency APA (in cooperation with AIT Austrian Institute of Technology) started its
activities as part of the German-Austrian Digital Media Observatory (GADMO); APA is part of the
IFCN. In the media sector, the PSM channel ORF 2 has launched the edutainment programme ‘Fakt
oder Fake‘ [Fact or Fake], in which fake news and disinformation are publicly debunked, the news
magazine ‘profil’ and the ‘Kleine Zeitung’ have established fact-checking platforms, but there are only
a few investigative platforms, such as ‘DOSSIER’. NGOs that work on media literacy have been
shifting their efforts towards disinformation. They include BAIT, a fact-check channel for young people
on TikTok; Mimikama, a 2012-founded education-focused association; and Kobuk, a voluntary media
monitoring blog. While Kobuk focuses on traditional media, the Mimikama platform sets the record
straight about fake news on social media sites and encourages users to report fake news. The
software company Polycular runs the game ‘Escape Fake‘, which uses augmented reality techniques
to motivate young people to become aware of fake news and deal with this problem.

The 2021 Act on Measures to Protect Users on Communications Platforms, as the most important
part of a bundle of new and amended legal provisions aiming to combat hate speech on the Internet,
has been replaced by the Digital Services Act (DSA); the accompanying regulation of which came into
force by February 17, 2024 (DSA-Begleitgesetz). Although some provisions had been criticized as
potentially restricting freedom of expression, the Communications Platforms Act represented the first
comprehensive attempt to combat hate speech on online platforms. The effects of this change in the
legal situation will only become apparent in the future.

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Already in 2017 and on behalf of the Austrian Federal Government, the NGO ‘ZARA – Civil Courage
& Anti-Racism-Work’ has set up an online option for reporting hateful content that has been published
or sent online, a special reporting tool for journalists was established in May 2021 (in collaboration
with the Press Club Concordia), and in February 2022, the ‘Zentrale Abfragestelle für Social Media
und Online-Provider’ [Central Inquiry Point for Social Media and Online Providers] at the Federal
Criminal Police Office started regular operations (after two years of trial operation). ZARA also offers
psycho-social and legal counselling for persons affected by or witnessing online hate. A particular
legal aid fund was established via crowdfunding, which allows for supporting victims of online hate
speech who want to take a case to court, but it is being used to a lesser extent than expected. Since
the opening of the counselling centre, 11,514 hate instances have been reported (as of August 2023)
(Zara, 2023).

However, after a few years of experience, experts are increasingly sceptical of these measures.
ZARA’s experiences show that many victims of online hate do not want to file a complaint, although
the hate they have encountered can be assessed as illegal. Some shy away from taking a case to
court. Others fear that too many people in their environment could find out about the incriminating
incidents by reporting them. For others, deleting the incriminating content is a priority, and they feel
that the entire process of filing a report and the criminal proceedings is too long, too complex, or too
stressful. For younger victims, in particular, legal guardians want to protect children from too much
additional stress due to their duty of precautionary care, which is why they do not want to take legal
action. According to a survey by Statistics Austria,
ten people in Austria have
encountered content online in the last three months that they perceive as hostile or humiliating (Der
Standard - Redaktion, 2023). Experts are therefore calling for more and more efficient measures in
the fight against hate speech (Fiala, 2022). In media practice, most newsrooms lack structures and
clear guidelines for dealing with these problems; only a few media outlets have taken measures
recently to professionalize their community management departments.

three out of

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4. Conclusions

Despite the democratically adequate quality of important foundations of the Austrian media system, the
MPM 2024 reveals a number of deficits – some of which have been identified over many years – where
there is an urgent need for political action. The MPM results make it clear that, in the absence of measures
to combat the risks identified, the severity of these risks continues to grow. The MPM 2024 demonstrates
this, particularly, with the extremely high risks to media pluralism due to ever-increasing concentration
tendencies and the declining viability of the media market.

In the Fundamental Protection area,

a comprehensive policy framework to ensure media professionals' physical and digital safety is urgently
needed, including newsroom guidelines for dealing with (sexual) harassment offline and online – and
also within media organisations.

journalists, especially part-time employees and
The same applies to the social protection of
freelancers, and the protection of journalists from abusive lawsuits (SLAPPs), as demanded by the
Austrian Press Club Concordia and numerous NGOs.

The Press Council, as the most significant self-regulation instrument, should oversee all media sectors
and be equipped with efficient sanctioning powers.

To support Market Plurality,

a state funding system is needed that (1.) provides PBS with the necessary digital expansion
opportunities and leaves enough room for an up-to-date redefinition of the public service mandate, (2.)
supports private commercial media companies in expanding their digital infrastructure in the long term
in such a way that they can maintain their added value even despite global competition, (3.) enables
the search for new cooperation opportunities to jointly develop and use the possibilities of digital
technologies to produce high-quality and investigative journalism, and last but not least (4.) offers local
media services, non-commercial community media and digital native startups a real chance to serve
local communication spaces as essential places for revitalizing democracy.

This restructuring of the funding system should be accompanied by specific incentive systems but also
legal provisions to promote media diversity, particularly in local areas where political scientists see the
nuclei of democracy.

For transparency, the shortcomings in the provisions on transparency of media ownership (concerning
the disclosure of the ultimate ownership structures and some currently existing exceptions to the rules)
should be rectified. This is all the more important as the number of online news media with more or less
covert proximity to political parties is rapidly growing.

Concerning Political Independence,

Political actors should avoid any intervention or attempt

to influence media outlets’ management

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policies and editorial decisions. Notably, according to the ruling of the Constitutional Court, a new and
comprehensive regulation of the appointment procedures of the ORF’s Foundation and Audience
influence and
Council members, which restricts governmental
enhances transparency and public participation, is urgently needed.

interference and partisan political

As far as state advertising is concerned, disclosure of advertising expenditures and allocation criteria is
recommended.

Editorial statutes (including a right to have a say in the appointment and dismissal of chief editors)
should be mandatory for all media outlets to ward off external influences on journalistic work.

To promote Social Inclusiveness,

the granting of state subsidies should be related to safeguards that ensure mandatory quotas for
women among executives and management boards and establishing a comprehensive diversity policy
covering both programming content and personnel issues in media undertakings.

The ongoing changes in the media environment underline the need for a comprehensive policy strategy
(including an adequate budget and funding structure) to promote media literacy in the sense of a
reflective, creative and self-determined use of media throughout life, which is in accordance with the
Directive (EU) 2018/1808 of the European Parliament and the Council.

level are to support

Considering the spread of fake news and conspiracy theories, the most important measures at the
national
fact-checking initiatives, promote content moderation systems in
newsrooms, and finance research projects that aim at developing strategies to empower people in all
age groups to be able to tell the difference between disinformation and legitimate criticism.

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5. References

Please note that the Legal Information System of the Republic of Austria (www.ris.bka.gv.at) provides only a
selection of Austrian Laws in English translation. In cases where no translation is provided, the English titles
do not represent official translations and are given in square brackets after the original German title.
#doublechek (2023). Ein Justiz-Übergriff und die Folgen [A judicial overreach and its consequences]. 
oe1.orf.at, August 7, 2023.
https://oe1.orf.at/artikel/704001/Ein-Justiz-Uebergriff-und-die-Folgen
Amnesty International (2023). Neues Gesetz zum Schutz von Whistleblower*innen in Österreich ist
mangelhaft [New law to protect whistleblowers in Austria is inadequate]. amnesty.at, February 1, 2023.
https://www.amnesty.at/presse/neues-gesetz-zum-schutz-von-whistleblower-innen-in-oesterreich-ist-
mangelhaft/
APA (2023). 2022 war ein “ZiB”-Jahr, in dem FPÖ-Chef Herbert Kickl rar war [2022 was a “ZiB” year in
which FPÖ leader Herbert Kickl was rare]. derstandard.at, May 16, 2023.
https://www.derstandard.at/story/2000146452466/2022-war-ein-zib-jahr-in-dem-fpoe-chef-herbert
APA News & Horizont Redaktion (2023). Medienhaus-Wien-CEO Kaltenbrunner: Steuern ‘relativ gelassen’
auf ‘große Katastrophe’ zu [Medienhaus Wien CEO Kaltenbrunner: We are heading ‘relatively calmly’
towards a ‘major catastrophe’]. horizont.at, April 18, 2023. 
https://www.horizont.at/medien/news/kaltenbrunner-steuern-relativ-gelassen-auf-grosse-katastrophe-
zu-91239
Beaufort, M., & Schulz-Tomancok, A. (2024). Austria. In S. Verza et al. (Eds.), Uncovering news deserts in
Europe: Risks and opportunities for local and community media in the EU (pp. 8-13). European University
Institute.
https://cmpf.eui.eu/wp-content/uploads/2024/02/CMPF_Uncovering-news-deserts-in-Europe_LM4D-final-
report.pdf
Berka, W., Heindl, L., Höhne, T., & Koukal A. (2019). Mediengesetz Praxiskommentar [Media Act: Practical
commentary]. 4th ed. Wien: LexisNexis.
Binder, S. (2022). Andy Kaltenbrunner: “Für manche Medien wird es trotz Fördermillionen nicht reichen”
[“For some media, despite millions in funding, it won’t be enough”]. horizont.at, December 28, 2023. 
https://www.horizont.at/medien/news/andy-kaltenbrunner-fuer-manche-medien-wird-es-trotz-neuer-
foerdermillionen-nicht-reichen-90243
Biringer, K., Peissl, H., & Seethaler, J. (2022). Public value of community media in Austria. Journal of
Alternative and Community Media, 7(1), 45-65.
https://intellectdiscover.com/content/journals/10.1386/joacm_00104_1
Bloomberg Tax (2023). Understanding Digital Services Taxes & the OECD. bloombergtax.com, January 4,
2023.
https://pro.bloombergtax.com/brief/understanding-digital-services-taxes-the-oecd/
Bonavida, I., & Winter, J. (2022). Parteimedien: Schlagzeilen mit Schlagseite [Party media: headlines with a
slant]. profil.at, November 28, 2022.
https://www.profil.at/oesterreich/parteimedien-schlagzeilen-mit-schlagseite/402239649
Bundesgesetz gegen Kartelle und andere Wettbewerbsbeschränkungen (Kartellgesetz) [Federal Act against
Cartels and Other Restraints of Competition (Cartel Law) (2005 & rev. 2021).
https://www.ris.bka.gv.at/GeltendeFassung.wxe?Abfrage=Bundesnormen&Gesetzesnummer=20004174&S
howPrintPreview=True
Bundesgesetz über die Förderung des qualitätsvollen Journalismus in Medien des Print- und Online-
Bereichs (Qualitäts-Journalismus-Förderungs-Gesetz – QJF-G) [Federal Act on the Promotion of High-
Quality Journalism in Print and Online Media (Quality Journalism Promotion Act] (2023).
https://www.ris.bka.gv.at/GeltendeFassung.wxe?Abfrage=Bundesnormen&Gesetzesnummer=20012459

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Bundesgesetz über die Wiener Zeitung GmbH und Einrichtung einer elektronischen Verlautbarungs- und
Informationsplattform des Bundes – WZEVI-Gesetz [Federal Act on the Wiener Zeitung GmbH and the
Establishment of an Electronic Publication and Information Platform of the Federal Government] (2023).
https://www.ris.bka.gv.at/Dokumente/BgblAuth/BGBLA_2023_I_46/BGBLA_2023_I_46.pdfsig
Bundesgesetz vom 23. Jänner 1974 über die mit gerichtlicher Strafe bedrohten Handlungen
(Strafgesetzbuch – StGB [Federal Act of January 23, 1974, on Acts Punishable by Law (Criminal Code –
StGB)]) (1974 & rev. 2023).
https://www.ris.bka.gv.at/GeltendeFassung.wxe?Abfrage=Bundesnormen&Gesetzesnummer=10002296
Bundesgesetz, mit dem das Bundesgesetz zur Gewährleistung einer globalen Mindestbesteuerung für
Unternehmensgruppen erlassen wird und die Bundesabgabenordnung sowie das
Unternehmensgesetzbuch geändert werden (Mindestbesteuerungsreformgesetz – MinBestRefG) [Federal
Act enacting the Federal Act to ensure global minimum taxation for groups of companies and amending the
Federal Fiscal Code and the Commercial Code (Minimum Taxation Reform Act)] (2023).
https://www.ris.bka.gv.at/Dokumente/BgblAuth/BGBLA_2023_I_187/BGBLA_2023_I_187.html
Bundesgesetz, mit dem das Bundes-Verfassungsgesetz geändert und ein Informationsfreiheitsgesetz
erlassen wird [Federal Act amending the Federal Constitutional Act and enacting a Freedom of Information
Act] (2024).
https://www.ris.bka.gv.at/Dokumente/BgblAuth/BGBLA_2024_I_5/BGBLA_2024_I_5.pdfsig
Bundesgesetz, mit dem das Koordinator-für-digitale-Dienste-Gesetz erlassen und das KommAustria-
Gesetz, das E-Commerce-Gesetz, das Allgemeine bürgerliche Gesetzbuch, das Urheberrechtsgesetz, das
Gerichtsgebührengesetz, das Mediengesetz, die Strafprozeßordnung 1975, das Staatsanwaltschaftsgesetz,
das Bundesgesetz über die justizielle Zusammenarbeit in Strafsachen mit den Mitgliedstaaten der
Europäischen Union, das Auslieferungs- und Rechtshilfegesetz und das Telekommunikationsgesetz 2021
geändert werden (DSA-Begleitgesetz – DSA-BegG) [Federal Act enacting the Coordinator for Digital
Services Act and amending the KommAustria Act, the E-Commerce Act, the General Civil Code, the
Copyright Act, the Court Fees Act, the Media Act, the Code of Criminal Procedure 1975, the Public
Prosecution Act, the Federal Act on Judicial Cooperation in Criminal Matters with the Member States of the
European Union, the Extradition and Mutual Legal Assistance Act and the Telecommunications Act 2021
(DSA Accompanying Act] (2023).
https://www.ris.bka.gv.at/Dokumente/BgblAuth/BGBLA_2023_I_182/BGBLA_2023_I_182.html
Bundesgesetz, mit dem das Urheberrechtsgesetz, das Verwertungsgesellschaftengesetz 2016 und das
KommAustria-Gesetz geändert werden (Urheberrechts-Novelle 2021 – Urh Nov 2021) [Federal Act
amending the Copyright Act, the Collecting Societies Act 2016 and the KommAustria Act (Copyright
Amendment 2021] (2021).
https://www.ris.bka.gv.at/Dokumente/BgblAuth/BGBLA_2021_I_244/BGBLA_2021_I_244.html
Bundesgesetz, mit dem ein Bundesgesetz über das Verfahren und den Schutz bei Hinweisen auf
Rechtsverletzungen in bestimmten Rechtsbereichen erlassen wird (HinweisgeberInnenschutzgesetz –
HSchG) [Federal law by which a federal law on the procedure and protection in the event of information on
legal violations in certain areas of law (Whistleblower Protection Act] (2023).
https://www.ris.bka.gv.at/Dokumente/BgblAuth/BGBLA_2023_I_6/BGBLA_2023_I_6.html
Bundesgesetz, mit dem ein Telekommunikationsgesetz erlassen wird (Telekommunikationsgesetz 2003 –
TKG 2003) [Federal Act enacting the Telecommunications Act (Telecommunications Act)] (2003 & rev.
2018).
https://www.ris.bka.gv.at/GeltendeFassung.wxe?Abfrage=Bundesnormen&Gesetzesnummer=20002849&F
assungVom=2018-05-31
Bundesministerium für Finanzen (2024). Brunner: Steuereinnahmen aus Digitalsteuer stiegen 2023 auf 103
Millionen Euro [Brunner: Tax revenue from digital tax increased to 103 million euros in 2023]. Press release,

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January 15, 2024. https://www.bmf.gv.at/presse/pressemeldungen/2024/jaenner/digitalsteuer-2023.html
Craufurd Smith, R., & Stolte, Y (2014). The transparency of media ownership in the European Union and
neighbouring states: Report on a project by Access Info Europe and the Open Society Program on
Independent Journalism.
https://www.access-info.org/wp-
content/uploads/Transparency_of_Media_Ownership_in_the_EU-09-26-2014.pdf
Dave (2022). Chats with Schmid: No charges, but a bad image for ‘Presse’ publishers. 
24hoursworlds.com, November 3, 2022. https://24hoursworlds.com/international/284126
Der Standard – Redaktion (2023). Ein Drittel der Bevölkerung berichtet von Hass im Netz [A third of the
population reports hate on the net]. derstandard.at, October 24, 2023.
https://www.derstandard.at/story/3000000192440/drittel-der-bevoelkerung-berichtet-von-hass-im-netz
Digitalsteuergesetz 2020 [Digital Tax Act 2020] (2020 & rev. 2022).
https://www.ris.bka.gv.at/GeltendeFassung.wxe?Abfrage=Bundesnormen&Gesetzesnummer=20010780
Dossier (2022). Politik und Medien: Eine Abrechnung [Politics and the media: A reckoning]. DOSSIER, No 8
(10/2022). https://www.dossier.at/dossiers/politik-und-medien/
European Commission (2022). Commission Recommendation (EU) 2022/1634 of 16 September 2022 on
internal safeguards for editorial independence and ownership transparency in the media sector.
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32022H1634
European Digital Rights (EDRi) (2022). Copyright: European Court of Justice strictly limits the use of upload
filters. EDRi blog, 4 May 2022:
https://edri.org/our-work/copyright-european-court-of-justice-strictly-limits-the-use-of-upload-filters/
European Parliament and Council (2010). Directive 2010/13/EU of the European Parliament and of the
Council of 10 March 2010 on the coordination of certain provisions laid down by law, regulation or
administrative action in Member States concerning the provision of audiovisual media services (Audiovisual
Media Services Directive).
https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A32010L0013
European Parliament and Council (2016). Directive (EU) 2016/680 of the European Parliament and of the
Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data
by competent authorities for the purposes of the prevention, investigation, detection or prosecution of
criminal offences or the execution of criminal penalties, and on the free movement of such data, and
repealing Council Framework Decision 2008/977/JHA.
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32016L0680
European Parliament and Council (2018). Directive (EU) 2018/1808 of the European Parliament and of the
Council of 14 November 2018 amending Directive 2010/13/EU on the coordination of certain provisions laid
down by law, regulation or administrative action in Member States concerning the provision of audiovisual
media services (Audiovisual Media Services Directive) in view of changing market realities.
https://eur-lex.europa.eu/eli/dir/2018/1808/oj
European Parliament and Council (2019a). Directive (EU) 2019/790 of the European Parliament and of the
Council of 17 April 2019 on copyright and related rights in the Digital Single Market and amending Directives
96/9/EC and 2001/29/EC. https://eur-lex.europa.eu/eli/dir/2019/790/oj
European Parliament and Council (2019b). Directive (EU) 2019/1937 of the European Parliament and of the
Council of 23 October 2019 on the protection of persons who report breaches of Union law.
https://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32019L1937
European Parliament and Council (2022). Council Directive (EU) 2022/2523 of 14 December 2022 on
ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic
groups in the Union.
https://eur-lex.europa.eu/eli/dir/2022/2523/oj

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Federal Act Enacting Provisions for Private Radio Broadcasting (Private Radio Broadcasting Act – PrR-G)
(2001 & rev. 2023).
https://www.ris.bka.gv.at/Dokumente/Erv/ERV_2001_1_20/ERV_2001_1_20.html
Federal Act on Audiovisual Media Services (Audiovisual Media Services Act – AMD-G) (2001 & rev. 2023).
https://www.ris.bka.gv.at/Dokumente/Erv/ERV_2001_1_84/ERV_2001_1_84.html
Federal Act on Measures to Protect Users on Communication Platforms (Communication Platforms Act –
KOPl-G) (2020). [expired]
Federal Act on the Austrian Broadcasting Corporation (ORF Act) (1984 & rev. 2023).
https://www.ris.bka.gv.at/Dokumente/Erv/ERV_1984_379/ERV_1984_379.html
Federal Act on the Establishment of an Austrian Communications Authority (‘KommAustria’) (KommAustria
Act – KOG) (2001 & rev. 2022).
https://www.ris.bka.gv.at/Dokumente/Erv/ERV_2001_1_32/ERV_2001_1_32.html
Federal Act on the Financing of Political Parties (Political Parties Act 2012) (2012 & rev. 2022).
https://www.ris.bka.gv.at/Dokumente/Erv/ERV_2012_1_56/ERV_2012_1_56.html
Federal Act on the Press and other Publication Media, dated 12th June 1981 (Media Act – MedienG) (1981
& rev. 2023).
https://www.ris.bka.gv.at/Dokumente/Erv/ERV_1981_314/ERV_1981_314.html
Federal Act on Transparency in Media Cooperation as well as of Advertising Orders and the Funding of
Media Owners of a Periodical Medium (Transparency in Media Cooperation and Funding Act – MedKF-TG)
(2023).
https://www.ris.bka.gv.at/Dokumente/Erv/ERV_2011_1_125/ERV_2011_1_125.html
Federal Constitutional Act of 10 July 1974 on Guaranteeing the Independence of Broadcasting (1974).
https://www.ris.bka.gv.at/Dokumente/Erv/ERV_1974_396/ERV_1974_396.html
Federal Constitutional Law (1930 & rev. 2024).
https://www.ris.bka.gv.at/Dokumente/Erv/ERV_1930_1/ERV_1930_1.html
Fiala, M. (2022) Der mühsame Kampf gegen Hass im Netz: Interview mit Nikolaus Forgó [The uphill battle
against hate online: Interview with Nikolaus Forgó]. horizont.at, September 5, 2022:
https://www.horizont.at/digital/news/kommunikationsplattformengesetz-der-muehsamekampf-gegenhass-im-
netz-89189
Fidler, H. (2023). Österreichs größte Medienhäuser [Austria‘s largest media companies]. derstandard.at,
July 27, 2023.
https://www.derstandard.at/story/3000000180498/oesterreichs-groesste-medienhaeuser-2023--vor-dem-
umbruch
Focus Marketing Research (2024). Jahresbilanz 2023 [Adbalance 2023].
https://www.focusmr.com/de/20325-2/
Forum Informationsfreiheit (2024). Informationsfreiheit – Expert:innen warnen vor Fehlern auf letzten Metern
[Freedom of information – experts warn of mistakes in the final metres]. informationsfreiheit.at, January 18,
2024.
https://www.informationsfreiheit.at/2024/01/18/informationsfreiheit-expertinnen-warnen-vor-fehlern-auf-
letzten-metern/
Frohner, A. (2022). Whistleblowing: Neue EU-Richtlinie fordert vertrauliche Meldekanäle [Whistleblowing:
New EU directive calls for confidential reporting channels]. EY.ai, January 4, 2022.
https://www.ey.com/de_at/forensic-integrity-services/whistleblowing-neue-eu-richtlinie-fordert-vertrauliche-
meldekanae
Fussenegger, G., & Robertson, V. (2020). The role of antitrust authorities regarding the digital economy.
Graz Law Working Paper Series, No 02-2020. Graz: University of Graz – Faculty of Law.
https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3701206

Page 34

The Centre for Media Pluralism and Media Freedom is co-financed by the European Union

Gadringer, S., Sparviero, S., Trappel, J., & Reichenberger, P. (2023). Digital news report: Austria 2023.
University of Salzburg. https://digitalnewsreport.at
Gasser, F. (2024) Informationsfreiheitsgesetz in Österreich: “Wir starten von einem schlechten Niveau”
[Freedom of Information Act in Austria: “We are starting from a low level”]. Zeit Online, February 18, 2024.
https://www.zeit.de/2024/08/informationsfreiheitsgesetz-amtsgeheimnis-abschaffung-markus-
hametner/komplettansicht
Hallin, D., & Mancini, P. (2004). Comparing media systems: Three models of media and
politics. Cambridge: Cambridge University Press.
Holoubek, M:, Kassai, K., & Traimer, M. (2014). Grundzüge des Rechts der Massenmedien [Fundamentals
of mass media law.]. Verlag Österreich.
Horizont Redaktion (2022). Medien-Digitalisierungsförderung passierte Ausschuss [Media digitization
funding passed committee]. horizont.at, March 9, 2022.
https://www.horizont.at/medien/news/mehrheitlich-angenommen-medien-digitalisierungsfoerderung-passiert
e-ausschuss-87618?utm_source=%2Fmeta%2Fnewsletter%2Fhorizontamabend&utm_medium=newsletter
&utm_campaign=nl1628&utm_term=f3e368d04ec3f765654dda0f3bb27552
iab Austria (2023). Umsetzung der Digitalsteuer: So gut, wie die Umfragewerte der Regierung
[Implementation of the digital tax: as good as the government’s poll ratings]. iab-austria.at, February 1,
2023. https://www.iab-austria.at/umsetzung-der-digitalsteuer-so-gut-wie-die-umfragewerte-der-regierung/
Kaltenbrunner, A., Lugschitz, R., Karmasin, M., Luef, S., & Kraus, D. (2020). Der österreichische
Journalismus-Report: Eine empirische Erhebung und eine repräsentative Befragung [The Austrian
journalism report: An empirical investigation and a representative survey]. Facultas.
Kienzl, S. (2023). Öffentliche Hand reduziert Werbeausgaben in Medien, pumpt aber mehr in Google und
Co. [Public sector reduces advertising expenditure in media, but pumps more into Google and Co.]. 
derstandard.at, June 15, 2023.
https://www.derstandard.at/story/3000000174739/oeffentliche-hand-reduziert-werbeausgaben-in-medien-
pumpt-aber-mehr-in-google-und-co
Knittelfelder, K. (2021). News from a different league: The rise of the digital party press in Austria. University
of Oxford, Reuters Institute.
https://reutersinstitute.politics.ox.ac.uk/sites/default/files/2021-12/RISJ%20paper_Klaus%20Knittelfelder_Mt
21_FINAL.pdf
KommAustria (2023). Durchsetzung von EU-Sanktionen im Medienbereich: Verwaltungsstrafbestimmung §
64 Abs. 3a AMD-G (Update vom 11. Oktober 2023) [Enforcement of EU sanctions in the media sector:
Administrative penalty provision § 64 para. 3a AMD-G (update of October 11, 2023)].
https://www.rtr.at/medien/aktuelles/veroeffentlichungen/Veroeffentlichungen/Sonstiges/Erlaeuterungen_zu_
Paragraf_64_Abs_3a_AMD-G.de.html
KommAustria (2023). KommAustria stellt in Sendung “Der Wegscheider” bei ServusTV Verletzungen des
Objektivitätsgebotes fest [KommAustria finds violations of the principle of objectivity in the program “Der
Wegscheider” on ServusTV]. Press release, OTS0053, January 2, 2023.
https://www.ots.at/presseaussendung/OTS_20230102_OTS0053/kommaustria-stellt-in-sendung-der-
wegscheider-bei-servustv-verletzungen-des-objektivitaetsgebotes-fest
Meier, K., Schützeneder, J., Avilés, J. A. G., et al. (2022). Examining the most relevant journalism
innovations: A comparative analysis of five European countries from 2010 to 2020. Journalism and Media, 
3(4), 698-714. https://doi.org/10.3390/journalmedia3040046
Momentum (2023). Spendingstudie 2022 und Prognose 2023 [Spending study 2022 and forecast 2023]. 
https://momentum.wien/?wpdmdl=10740&ind=1684148467214&masterkey=646211083ad22
ORF (2022). ORF-Redakteurstatut [ORF editorial statute].
https://zukunft.orf.at/rte/upload/2022/orf_redaktionsstatut.pdf

Page 35

The Centre for Media Pluralism and Media Freedom is co-financed by the European Union

ORF (2023a). ORF Jahresbericht 2022 [Annual report 2022].
https://zukunft.orf.at/rte/upload/2023/veroeffentlichungen/jb_2022_final.pdf
ORF (2023b) Vielfalt – Diversity ist kein Selbstzweck. Diversity ist jung [Diversity is not an end in itself.
Diversity is young]. In ORF (Ed.), Public Value-Bericht 2022/23 (pp. 44-46).
https://zukunft.orf.at/rte/upload/2023/aktuelles/public_value_bericht_2023_daten.pdf
ORF Enterprise (2019). Rahmenbedingungen für politische Werbung – orf.at und ORF Teletext [Framework
conditions for political advertising – orf.at and ORF Teletext].
https://enterprise.orf.at/fileadmin/data/03_ihre-buchung/allgemeine-
informationen/agb/Rahmenbedingungen_fuer_politische_Werbung_ORFat_und_ORF-Teletext.pdf
OSCE – Office for Democratic Institutions and Human Rights (ODIHR) (2019). Republic of Austria – Early
parliamentary elections, 29 September 2019: Needs assessment mission report.
https://www.osce.org/odihr/elections/austria/429095
Pernegger, M. (2023). Frauen – Politik – Medien: Jahresstudie 2022 [Women – politics – media: Annual
study 2022]. http://www.mediaaffairs.at/aktuellebeitraege/gesellschaft/frauenstudie2022.%20html
Presseclub Concordia (2023). Wiener Zeitung: Unwürdiges Ende, undurchsichtiger Neustart [Wiener
Zeitung: Unworthy end, opaque new start]. Press release, June 29, 2023.
https://concordia.at/wiener-zeitung-unwuerdiges-ende-undurchsichtiger-neustart/
Puls 4 (2023).Übermittlung eines Jahresberichtes Barrierefreiheit [Submission of an annual report on
accessibility].
https://downloads.prosiebensat1puls4.tv/puls24/barrierefreiheit/Barrierefreiheitsbericht_2022_PULS_24.pdf
Reda, F., & Keller, P. (2022). CJEU upholds Article 17, but not in the form (most) Member States imagined. 
Kluwer Copyright Blog, April 28, 2022.
http://copyrightblog.kluweriplaw.com/2022/04/28/cjeu-upholds-article-17-but-not-in-the-form-most-member-
states-imagined/
Reporters Without Borders (2023). World Press Freedom Index 2023 – Austria.
https://rsf.org/en/country/austria
Resei, C., & Kraus, D. (2023). Qualitätsjournalismus wichtiger denn je [Quality journalism is more important
than ever]. Kompetenz-online.at, November 28, 2023.
https://kompetenz-online.at/2023/11/28/qualitaetsjournalismus-wichtiger-denn-je/
Reuters (2024). Austrian regulator clears way for MFE stake in ProSieben. nasdaq.com, February 8, 2024.
https://www.nasdaq.com/articles/austrian-regulator-clears-way-for-mfe-stake-in-prosieben
RTR (2024). Digital Services Act der EU: KommAustria ab 17. Februar nationaler „Koordinator Digitale
Dienste“ [EU Digital Services Act: KommAustria national “Digital Services Coordinator”].
https://www.rtr.at/medien/presse/pressemitteilungen/Presseinformationen_2024/PI01162024KOA_DSA_KD
D.html#:~:text=Mit%20der%20EU%2DVerordnung%20%E2%80%9EDigital,versch%C3%A4rft.
Schmid, F. (2023). Geben und Nehmen, Bussis und Toben: Die Macht des Boulevards über die Politik [Give
and take, kisses and bluster: The power of the tabloids over politics]. derstandard.at, April 8, 2023.
https://www.derstandard.at/story/2000145312602/geben-und-nehmen-bussis-und-toben-die-macht-des-
boulevards
Seethaler, J. (2024). Austria: Losing long-term media market stability. In Schapals, A. K., & Pentzold, C.
(Eds.), Media compass: A companion to international media landscapes. Wiley.
Seethaler, J., & Beaufort, M. (2017). Community media and broadcast journalism in Austria: Legal and
funding provisions as indicators for the perception of the media’s societal roles. The Radio Journal:
International Studies in Broadcast & Audio Media, 15, 173-194.
https://intellectdiscover.com/content/journals/10.1386/rjao.15.2.173_1
Seethaler, J., & Beaufort, M. (2019). Recent developments on freedom and pluralism of media in Austria’. In
A. Giannakopoulos, A. (Ed.), Media, freedom of speech, and democracy in the EU and beyond (pp.

Page 36

The Centre for Media Pluralism and Media Freedom is co-financed by the European Union

116–130). Tel Aviv: S. Daniel Abraham Center for International and Regional Studies, Tel Aviv University.
https://europeanjournalists.org/wp-content/uploads/2019/07/Media-Freedom-of-Speech-and-Democracy-
min.pdf
Seethaler, J., & Melischek, G. (2006). Die Pressekonzentration in Österreich im europäischen Vergleich
[Press concentration in Austria: European perspectives], Österreichische Zeitschrift für Politikwissenschaft,
35(4), 337–360. https://doi.org/10.15203/ozp.896.vol35iss4
Seethaler, J., & Melischek, G. (2014). Phases of mediatization: Empirical evidence from Austrian election
campaigns since 1970. Journalism Practice, 8(3), 258–278. https://doi.org/10.1080/17512786.2014.889443
Seethaler, J., & Melischek, G. (2019). Twitter as a tool for agenda-building in election campaigns? The case
of Austria. Journalism, 20(8), 1087–1107. https://doi.org/10.1177/1464884919845460
Strobl, W. (2024). Wie Slapp-Klagen die Demokratie gefährden. [How SLAPPs jeopardise democracy]. 
derstandard.at, March 12, 2024.
https://www.derstandard.at/story/3000000211198/wie-slapp-klagen-die-demokratie-gef228hrden
Transparency International Austria (2023). World Whistleblowing Day 2023: Transparency fordert Reparatur
des Gesetzes und einen Kulturwandel! [World Whistleblowing Day 2023: Transparency calls for repair of the
law and a cultural change!]. Press release, June 23, 2023.
https://ti-austria.at/wp-content/uploads/2023/07/Presseaussendung-TI-Whistleblowing-Day-2023_23.06.pdf
Trappel, J., & Tomaz, T. (2021). Austria: Confirmed democratic performance while slowly digitalising. In J.
Trappel & T. Tomaz (Eds.), The Media for Democracy Monitor 2021: How leading news media survive
digital transformation, Vol. 1 (pp. 95–152).
http://norden.diva-portal.org/smash/record.jsf?pid=diva2%3A1557246&dswid=1561
U.S. Department of the Treasury (2021). Joint Statement from the United States, Austria, France, Italy,
Spain, and the United Kingdom, Regarding a Compromise on a Transitional Approach to Existing Unilateral
Measures During the Interim Period Before Pillar 1 is in Effect. Press release, October 21, 2021.
https://home.treasury.gov/news/press-releases/jy0419
Verband Freier Radios Österreich, Verband Community Fernsehen Österreich and COMMIT (2019). 20
Jahre on air: Community Medien – die etwas anderen Privatsender [20 years on air: Community Medien –
the somewhat different private broadcasters].
https://www.commit.at/fileadmin/Materialien/20Jahre_CommunityMedien_PV-Bericht.pdf
Vogt, J. (2021). Austria: Election of new ORF head shines spotlight on selection process: Appointment
raises recurring question over politicization of oversight bodies. International Press Institute –
Newsroom, November 11, 2021.
https://ipi.media/austria-election-of-new-orf-head-shines-spotlight-on-selection-process/
wts global (2024). Pillar Two: Country–by–country implementation status. https://wts.com/wts.com/hot-
topics/pillar-two/implementation-status/wtsglobal-pillar-two-country-by-country-implementation.pdf
Wurnitsch, M. (2023). Mikl-Leitner-Festspiele im ORF: Nichts gelernt [Mikl-Leitner festivities on ORF:
Nothing learned]. horizont.at, January 11, 2023.
https://www.horizont.at/medien/kommentar/noe-wahlkampf-mikl-leiter-festspiele-im-orf-nichts-gelernt-90348
ZARA (2023). 6. #GEGENHASSIMNETZ Bericht September 2022 – August 2023 [6th ‘AGAINST HATE ON
THE NET Report September 2022 – August 2023].
https://assets.zara.or.at/media/ghinbericht/6.GegenHassimNetz_Bericht.pdf

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ANNEXE I. COUNTRY TEAM

First name

Last name

Position

Institution

Josef

Seethaler

Deputy Director

Maren

Beaufort

Postdoc researcher

Austrian Academy of
Sciences, Institute for
Comparative Media &
Communication Studies

Institute for
Comparative Media and
Communication Studies
(CMC) at the Austrian
Academy of Sciences
and the University of
Klagenfurt

MPM2024 CT
Leader

X

ANNEXE II. GROUP OF EXPERTS

The Group of Experts is composed of specialists with a substantial knowledge and experience in the field of
media. The role of the Group of Experts was to review especially sensitive/subjective evaluations drafted by
the Country Team in order to maximize the objectivity of the replies given, ensuring the accuracy of the final
results.

First name

Last name

Position

Institution

Alfred

Grinschgl

Former Managing Director

Helga

Schwarzwald

Management

Austrian Regulatory Authority for
Broadcasting and
Telecommunications (RTR)

Association of Austrian Community
Broadcasters

Daniela

Daniela

Kraus

Zimmer

Legal expert in the Consumer Policy
Department at the AK Vienna

General Secretary

Press Club Concordia

Josef

Gruber

President

Chamber for Workers and
Employees, AK Vienna/Viewers'
and Listeners' Council ORF

Verband der Regionalmedien
(VRM) [Association of Regional
Media]

Research Project Report

Issue -

June 2024

doi:10.2870/98299

ISBN:978-92-9466-557-7

QM-02-24-664-EN-N

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