MONITORING MEDIA

PLURALISM IN THE DIGITAL ERA

APPLICATION OF THE MEDIA PLURALISM
MONITOR IN THE EUROPEAN UNION,
ALBANIA, MONTENEGRO, THE REPUBLIC OF
NORTH MACEDONIA, SERBIA & TURKEY IN
THE YEAR 2021
Country report: Slovakia

Marína Urbániková, Masaryk University

Research Project Report

Issue -
June 2022
TABLE OF CONTENTS
1. About the project 4
1.1. Overview of the Project 4
1.2. Methodological notes 4

2. Introduction 6

3. Results of the data collection: Assessment of the risks to media 8

pluralism
3.1. Fundamental Protection (28% - low risk) 9
3.2. Market Plurality (68% - high risk) 11
3.3. Political Independence (57% - medium risk) 14
3.4. Social Inclusiveness (54% - medium risk) 16

4. Pluralism in the online environment: assessment of the risks 19

5. Conclusions 22

6. Notes 24

7. References 25

Annexe I. Country Team

Annexe II. Group of Experts
© European University Institute 2022
Chapters © Marína Urbániková, 2022

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Views expressed in this publication reflect the opinion of individual authors and not those of
the European University Institute.

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ISBN:978-92-9466-303-0
doi:10.2870/946133

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

1.2. Methodological notes

Authorship and review

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

Fundamental Protection Market Plurality Political Independence Social Inclusiveness

Protection of freedom of Transparency of media Political independence of Access to media for
expression ownership media minorities
Protection of right to News media Editorial autonomy Access to media for
information concentration local/regional
communities and for
community media
Journalistic profession, Online platforms Audiovisual media, online Access to media for
standards and protection concentration and platforms and elections women
competition enforcement
Independence and Media viability State regulation of Media Literacy
effectiveness of the media resources and support to
authority media sector
Universal reach of Commercial & owner Independence of PSM Protection against illegal
traditional media and influence over editorial governance and funding and harmful speech
access to the Internet content
Table 1: Areas and Indicators of the Media Pluralism Monitor

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The digital dimension

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

The calculation of risk

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

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

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2. Introduction

Country overview: Slovakia is a landlocked Central European country with a territory of 49,035 square
kilometres and a population that exceeds 5.4 million. Its capital is Bratislava, with a population of over
430,000.

Languages: The official language is Slovak. There are nine minority languages recognised by law:
Bulgarian, Croatian, Czech, Hungarian, German, Polish, Roma, Ruthenian, and Ukrainian.

Minorities: According to the country's 2021 census (ŠÚSR, 2022d), the majority of the inhabitants
have Slovak nationality (84%), with the most numerous national minority being Hungarian (8%),
followed by Roma (1%), Czech (0.5%), Ruthenian (0.4%), and Ukrainian (0.2%). However, it is
assumed that many Roma people chose not to declare their ethnic identity in the census and that the
Roma minority is, in fact, much larger; it is estimated at 440,000 (8%) (MVSR, 2019). The Hungarian
minority is concentrated mainly along the southern border with Hungary, while Roma people
predominantly live in the eastern part of the country. The Bratislava region, which is situated in the
west, is by far the richest of the country’s eight regions, with a gross domestic product (GDP) that is
almost double that of the Košice region in the east, which is second.

Economic situation: The Slovak economy grew by 3% in 2021, according to the Slovak Statistical
Office (ŠÚSR, 2022a). However, the losses from 2020, the first year of the pandemic, have not yet
been erased: the total value of the GDP at constant prices continued to lag behind the pre-COVID-19
period by 1.5%. For 2022, the Slovak Ministry of Finance expects a GDP growth of 3.5 % (MFSR
2022). Due to rising energy prices, supply chain bottlenecks, the COVID-19 pandemic, and geopolitical
tensions, inflation is a concern. Inflation increased to 3.2% in 2021, the highest it has been in nine
years (ŠÚSR, 2022b), and it is expected to reach 6% in 2022 (MFSR 2022). The unemployment rate
increased to 6.8% in 2022 (ŠÚSR, 2022c).

Political situation: Slovakia is a parliamentary representative democratic republic with a multi-party

system. Its political landscape is fragmented and, on average, six to seven parties are represented in
the Parliament. The current government was formed in 2020, when the elections ended the eight-year
rule of the left-wing Smer-SD party and brought to power a conservative-populist centre-right
movement named OĽANO. A political crisis brought on by the murder of investigative journalist Ján
Kuciak and his fiancée Martina Kušnírová precipitated the shift in government. As of 2019, the
presidency is held by Zuzana Čaputová – who is female, liberal, and pro-European.

Media market: Slovakia has a dual system of public and commercial broadcasting. The public service
broadcaster, Radio and Television Slovakia (RTVS) has a relatively strong position; its most popular TV
and radio channels are among the market leaders. There are seven nationwide daily newspapers
(including two tabloids) and two nationwide press agencies that represent the written press landscape.
Commercial TV stations and digital-born news portals remain the dominant news sources (Newman &
et al., 2021). Czech and Hungarian media are also important players due to the shared historical
background and language similarities with the Czech Republic and the presence of a significant
Hungarian minority.

Regulatory environment: The Ministry of Culture creates the national media policies and drafts most

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 media legislation. It also keeps the register of printed media. The major regulatory body is the Council
for Broadcasting and Retransmission, which executes state regulation in the field of radio and TV
broadcasting, retransmission, and on-demand audio-visual media services. Ethical self-regulation is
performed by the Print-Digital Council of the Slovak Republic for the journalism industry and the
Advertising Standards Council for advertising. The Slovak Syndicate of Journalists, the main journalists'
professional association, plays a peripheral role because it lacks authority in the journalistic community.

COVID-19: In 2021, more than 14,000 people died from complications related to COVID-19 in Slovakia,
compared to 2,250 people in 2020 (MIRRISR, 2022). Besides the death toll, COVID-19 had a severe
economic impact, including upon the media sector; although, the year 2021 was marked by a modest
economic recovery compared to 2020. No particular restrictions upon the freedom of expression have
been introduced in response to the COVID-19 pandemic, and the ones that have arisen from the state
of emergency and that might have had an impact on fundamental rights and freedom (mainly freedom
of movement and freedom of assembly) have been regularly scrutinized by the public as well as the
non-governmental sector. The first wave of the COVID-19 pandemic raised a legally controversial issue
of whether it is necessary for the Public Health Authority of the Slovak Republic to obtain information
from telecommunications companies about their customers and, if so, to what extent. Following the
presidential veto, the scope of data that can be processed by the Public Health Authority and the
duration of their retention was limited by the new Act No. 452/2021 Coll., on Electronic
Communications (Štarha, Gašparovič & Rievajová, 2021).

War in Ukraine: The Russian invasion of Ukraine brough significant changes to the Slovak media
sector. As the war has further increased the already high circulation of disinformation, propaganda, and
hoaxes, the Slovak Parliament hastily passed an amendment to Act No. 69/2018 Coll., on
Cybersecurity to allow the National Security Authority to shut down sources of “malicious content”
(Slovak Spectator, 2022a). In the past, the proposals to give the National Security Authority the power
to block websites have been rejected due to fundamental rights concerns; these concerns persist with
regard to the new Act as well. For instance, the description of harmful content that can be blocked by
the National Security Authority includes "serious disinformation" but the Act does not further define the
term. In addition, the National Security Authority decides on blocking on its own initiative and at its own
discretion. As a result, several websites that spread Russian propaganda (e.g., Hlavné Správy) have
been blocked (NBÚ, 2022). One of the authors contributing to the disinformation outlet Hlavné Správy
was, together with other persons, arrested and charged for taking bribes and conducting espionage for
Russia (Slovak Spectator, 2022b). Please, note that the report covers data referring to the year 2021.
The impact of war in Ukraine is not reflected in the overall scores and scores for different areas.

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

According to MPM 2022, the main risks to media pluralism in Slovakia lie in the area of Market plurality
(this domain displays a high-risk score). The areas of Political independence and Social inclusiveness
remain of concern as well. Although the score, in both cases, falls in the medium-risk zone, it is approaching
the threshold of the high-risk zone. Fundamental protection is the only domain that displays a low level of
risk for media pluralism. While the overall risk level in each key domain remains the same, there were some
changes in individual indicators compared to 2021. The assessment of the risks for pluralism in the online
environment provides slightly more favourable results than the overall pluralism assessment. This applies to
the domains of Political independence and Market plurality in particular.

In the domain of Fundamental protection (28%), four out of five indicators displayed low risk. The
remaining one — Universal reach of traditional media and access to the Internet — showed to be a medium
risk, mostly due to the low share of households covered by broadband Internet and the decrease in the
percentage of the population covered by the signal of public service channels.

Market plurality scored the highest risk of all the four domains (68%). In particular, News media
concentration and Online platforms concentration and competition enforcement were high-risk areas. In this
regard, the lack of legislation that requires the disclosure of information about the ultimate owners of news
media, leaky safeguards against ownership concentration, and the slow economic recovery after the
COVID-19 pandemic, are the main threats to media pluralism in Slovakia.

Political independence displayed medium risk (57%), with two indicators exceeding the high-risk

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threshold: Political independence of media and Independence of PSM governance and funding. In both
areas, long-term unresolved problems at RTVS, the Slovak public service broadcaster, play an important
role. Moreover, the lack of safeguards that prevent politicians from owning media companies and the
proliferation of disinformation websites pose further risks.

In the domain of Social inclusiveness (54%), Protection against illegal and harmful speech and Access to
media for women were identified as the most problematic (both scored high risk). Media literacy and Access
to media for local/regional communities and community media should be given attention as well, as these
areas displayed medium risk.

3.1. Fundamental Protection (28% - 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.

In the domain of Fundamental protection (28%), four out of five indicators displayed low risk (as in the
previous year). The only exception was the indicator for the Universal reach of traditional media and access
to the Internet. Compared to last year, the risk assessment deteriorated from to medium risk from low,
mostly due to the low share of households covered by broadband Internet and the decrease in the
percentage of population covered by the signal of public service channels.

Similar to last year, Protection of freedom of expression showed to be a low risk (26%) because the
Slovak legal provisions adhere to international human rights standards (see Act No. 460/1992 Coll.,
Constitution of the Slovak Republic; Act No. 23/1991 Coll., that introduces The Charter of Fundamental
Rights and Freedoms). Nonetheless, defamation is still defined as a criminal offence; it may be punished
with up to two years of imprisonment and in case it causes "large-scale damage", e.g. loss of employment
or divorce, offenders face up to eight years in prison (see Act No. 300/2005 Coll., Criminal Code). The

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length of the prison sentence makes the Slovak defamation legislation one of the strictest in Europe
(Griffen, 2017). Although accusations of defamation have been rare in recent years and have not led to
convictions, in the past, politicians and judges used it as an avenue for responding to criticism (Griffen,
2017; Hanák, 2016). Thus, the legislation in its current form creates the potential for abuse and may lead to
a chilling effect on journalists (see Hanák, 2016 for an analysis).

In the area of Protection of right to information, the risk was assessed as low (19%), the same as last
year. Access to information is governed by Act No. 211/2000 Coll., on Free Access to Information. Although
the right to information is generally respected, according to the reports of several NGOs (Transparency
International Slovakia, 2021; Aliancia Fair Play, 2021), occasionally, public administration bodies arbitrarily
deny access to information. Public administration bodies and public companies often take a very different
approach to the provision of information, and, as pointed out by Transparency International Slovakia (2021),
in many cases, citizens can only access information made available by a court decision, which usually takes
years. Moreover, Slovakia has not yet transposed the EU Directive on Whistleblowing (Directive
2019/1937). On a more positive note, a newly-established independent Office for the Protection of
Whistleblowers began operation in 2021 (based on Act No. 54/2019 Coll., on the Protection of
Whistleblowers).

Journalistic profession, standards and protection showed to be a low risk (28%), with no annual
change. Although the Slovak journalists' working conditions are generally rather favourable, several issues
deserve attention. First, attacks and threats to the physical safety of journalists are rare but still occur (see
European Centre for Press and Media Freedom, 2021a and 2021b). Regarding the prosecution of crimes
against journalists, the case against the two persons accused of ordering and organizing the 2018 murder of
the investigative journalist Ján Kuciak and his fiancée was still pending in 2021. In June 2021, the Slovak
Supreme Court ordered a new trial, finding that the 2020 verdict did not adequately examine all of the
available evidence (CPJ, 2021). Second, some journalists are in a vulnerable position due to the
widespread practice of avoiding standard employment contracts in order to cut costs (which applies to the
public service medium, too). Many journalists work as "external collaborators" or "freelancers" (i.e., self-
employed persons), even though they work exclusively for a single newsroom and very often provide
newsroom stability for many years. This adds to job insecurity and can also be used as a source of pressure
because these contracts can be terminated at any time (see the case of long-term journalists working for the
public service broadcaster RTVS; Reporters Without Borders, 2021). Third, the Slovak Syndicate of
Journalists, the main journalists' professional association in Slovakia, is not effective. It lacks authority in the
journalistic community, it does not engage in public debates on current issues regarding journalists and
journalism, and the membership rate among active journalists is very low. Thus, a collective voice and
defense are missing for when there is an attack against journalists or the journalistic community. Fourth, the
lack of a specific anti-SLAPP (strategic lawsuits against public participation) legislation also contributes to
the vulnerability of Slovak journalists. In 2021, one suspicious case was reported in this regard (European
Centre for Press and Media Freedom, 2021c).

Independence and effectiveness of the media authority scored as a low risk (15%), the same as in the
previous year. Regulatory authorities for audio-visual media services are generally independent of the
government and public and private bodies. Procedures are designed to minimize the risk of political or
economic interference, but, due to the political culture in Slovakia, these are not always effective. Regarding
the key regulatory body, the Council for Broadcasting and Retransmission, politically motivated nominations
have occurred in the past years. Even though the current Parliament introduced some changes in the
procedure (e.g., live-streamed public hearing of the candidates in front of the Parliamentary committee), the

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selection of candidates remains solely in the hands of the Parliament, and the risk of political nominations
persists.

Compared to last year, the score for Universal reach of traditional media and access to the
Internet increased to a medium risk (50%) from a low risk (25%). This is because the population covered by
the signal of public service channels decreased from 98% to 94% in the case of the main radio channel and
[1]
from 95% to 94% in the case of the TV channels (RVR, 2021 and 2022). Only 75% of households are
covered by broadband Internet, well below the EU average of 87% (European Commission, 2021a). Also,
regarding net neutrality, ownership concentration of the Internet service providers (ISPs) cannot be
assessed because there are no comprehensive data on the market shares of the main players.

3.2. Market Plurality (68% - high risk)

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

Market plurality is the only domain that was assessed as high risk in Slovakia, even though the score
improved compared to last year (to 68% from 79%). Specifically, News media concentration and Online
platforms concentration and competition enforcement continue to be high-risk areas (the same as the
previous year). On the other hand, in the case of Transparency of media ownership and Commercial &
owner influence over editorial content, the risk assessment improved to medium risk from high risk, mostly
due to the promising new media legislation currently being debated in Parliament that is expected to bring

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more transparency into media ownership structures. The Media viability indicator has seen an improvement
to medium risk from high risk as well, which reflects the modest economic recovery of the Slovak media
sector from the impact of the COVID-19 pandemic.

Transparency of media ownership was shown to be a medium risk (56%) because Slovakia still lacks a
law that would require the disclosure of information on the ultimate owners of news media. The ownership
structure of many media organisations is, therefore, opaque. This is, to some extent, remedied by Act No.
315/2016 Coll., on the Register of Public Sector Partners, the main purpose of which is to identify the end-
users of the benefits of the entities that receive public funds (including many major media organisations).
These entities are listed in a publicly available online register that contains details on the actual owners. The
Ministry of Culture prepared new media legislation in 2021 (as of December 2021, the draft has been
debated in the Parliament), according to which all of the media should be listed in the register mentioned
above (Denník N, 2021b). Also, the proposed law requires that the media publish a list of investors and
donors, and prohibit anonymous donations. Due to this promising development, the risk score decreased to
medium (56%) in the current year, from high (78%) in the previous year.

Like last year, News media concentration displays a high-risk score (79%). The current regulatory
safeguards against the high degree of horizontal and cross-media concentration of ownership in the media
sector do not cover native digital media and do not take into account the ultimate owners of the media
companies. Consequently, the rules are relatively easy to circumvent. Moreover, the data on market share
(based on revenues) in individual sectors are not collected and published, and it is, therefore, not possible
to evaluate the level of concentration of ownership and the efficiency of the measures aimed at its
prevention. The audience/readership concentration in the newspaper, audio-visual, and radio sectors is high
because the audience/readership share of the top four media owners exceeds 60%.

There have been no changes in the area of Online platforms concentration and competition
enforcement either. It remained in the high-risk zone (77%), as in the previous year. When it comes to
online platforms, the concentration of ownership is difficult to assess because there are no data for online
advertising revenue share or online audience share. Also, media-specific limitations are set for traditional
media only and not for native digital media/platforms. The same applies to the concentration of the digital
advertising market. The Antimonopoly Office enforces supervision under the general rules derived from Act
No. 187/2021 Coll., on the Protection of Competition. Furthermore, Slovakia has yet to transpose EU
Directive 2019/790; financial agreements between digital intermediaries and news-media producers to
remunerate the publishers and contribute to their financing are not in place. No particular form of taxation for
digital services has been introduced or scheduled.

Compared to last year, the assessment of Media viability improved to medium risk from high (the
score decreased to 64% from 83%). This reflects a modest economic recovery from the impact of the
COVID-19 pandemic. Even though the pandemic struck the Slovak media sector hard in 2020, according to
the industry associations, the financial situation improved in 2021 and revenues rose slightly. However, the
overall economic conditions remain challenging, and the media sector has not yet fully recovered. There
have been (some) salary cuts, or at least the salaries stagnated after the cuts taken in 2021. The audio-
visual sector and the major TV companies, in particular, seem to be better off due to the increased
advertising demand (HNonline, 2021). According to the WARC Adspend database forecast for 2021, the
annual advertising expenditure is expected to rise in all the media sectors, but it is still roughly at the level of
2019 (with the exception of the Internet advertising, which increased more significantly; however, this is a
broad category that is not restricted to news websites and specific data on advertising revenues in the case

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of online news media is not available, and, moreover, the revenues from online advertising go, to a large
extent, to digital intermediaries). The economic condition of the media sector, as a whole, is difficult to
determine because there is no data for revenues and revenue trends for 2021. In addition, the increase in
advertising revenue is expected to be lower than the overall GDP increase (ŠÚSR, 2022a). Finally, the
fragile economic situation of the news media is not helped by the absence of public support schemes for
this sector.

In the case of Commercial & owner influence over editorial content, the score (65%) is comparable to
last year (70%). However, a slight decrease meant a shift to the medium-risk zone from the high-risk zone.
Several risk factors can be identified. Slovakia lacks a mechanism (legal or self-regulatory) that would grant
journalists specific social protection in the case of changes to ownership or the editorial line (journalists are
only protected via general provisions of Act No. 311/2001 Coll., Labour Code). It also lacks regulatory
safeguards to ensure that decisions regarding appointments and dismissals of the editor-in-chief are not
influenced by commercial interest. Also, although there is no systematic data or reports on the commercial
influences on editorial content, anecdotal evidence (e.g., see the case of the magazine Trend; O médiách
2020a and 2020b) and the ownership structure of the Slovak media, give rise to concerns. The vast majority
of the key Slovak media outlets are in the hands of the local (i.e., Czech and Slovak) oligarchs. These
groups and businessmen have interests in many industries and politics. Given the difficult economic
situation in the media market, it seems likely that at least some of these owners bought the media outlets to
support their activities and interests outside the media field (in the past, some admitted it openly; see
Denník N, 2015). On a positive note, laws and self-regulatory measures that prohibit advertorials and
disguised advertisement are in place and are fairly effective.

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3.3. Political Independence (57% - 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 domain of Political independence continues to be in the medium-risk zone; however, the risk score
increased to 57% compared to 41% last year. Unlike the previous year, two indicators exceed the high-risk
threshold: Political independence of media and Independence of PSM governance and funding. This is
mainly the result of long-term unresolved problems at RTVS, the Slovak public service broadcaster, and the
increased activity of disinformation platforms.

Political independence of media has deteriorated since last year and shifted to the high-risk zone (71%)
from the medium-risk zone (46%). This is mainly due to ongoing concerns about the independence of the
public-service broadcaster RTVS (Reporters Without Borders, 2021; Urbániková, 2021). Change is not in
the offing. A proposal of the Ministry of Culture to depoliticize the election of the Director-General (the next
election is due in 2022) by transferring the electoral power from the Parliament to the RTVS Council was
opposed by the junior coalition party, Sme rodina (Denník N, 2021c). Boris Kollár, the party leader who also
serves as the Speaker of the National Council of the Slovak Republic, declared that the election of the
Director-General should be solely in the hands of the Parliament (Denník N, 2021c). At the same time, he
owns two of the four radio stations with the highest audience share in Slovakia. Instead of solving this
conflict of interest, he bought the second radio station in 2021 (Refresher, 2021c). There are no regulatory
safeguards that would prevent a conflict of interest in the media sector or effectively limit the direct or
indirect control of media outlets by politicians, political parties, and partisan groups. Also, the political
independence of town hall (i.e., local/regional) media is of concern because these are funded and owned by

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local/regional authorities, and their content is often blatantly skewed in favour of the current local/regional
political representation (Transparency International Slovakia, 2022). Furthermore, fake-news websites and
disinformation promoted by online media continued to proliferate in 2021. On the other hand, there are no
reports (by scholars, NGOs, or media outlets) that newspapers or the major commercial TV stations are
politically controlled.

Like last year, Editorial autonomy displayed a medium risk score (63%). On a positive note, self-regulatory
measures that stipulate editorial independence from political interference are included in the Code of Ethics,
and all of the major media outlets, including press agencies, signed on to it. In the monitored period, no
major incidents were reported by the Print-Digital Council of the Slovak Republic, the self-regulatory body in
the area of journalistic ethics. On a more negative note, there are no legal safeguards that would guarantee
autonomy when appointing and dismissing editors-in-chief. In the past years, political interference into the
appointments and dismissals of key personnel was discussed as part of the situation at RTVS, the public
service broadcaster, because the top managers who were directly responsible for the news content were
replaced within weeks of the new Director-General being elected by the Parliament in 2017 and taking office
(for details, see Urbániková, 2021). In general, there are no serious signals that the majority of the legacy
media would be troubled by political influence (although the conduct of RTVS raises some concerns).

As in 2021, Audio-visual media, online platforms and elections scored low risk (21%). The regulatory
and self-regulatory framework for the fair representation of different political actors and viewpoints is in
place, and it is effective most of the time. There are, however, concerns regarding neutrality and balance in
the case of the public-service broadcaster RTVS — this was also noted during the 2020 electoral campaign
(MEMO 98 and GLOBSEC, 2020). There were no municipal, regional, parliamentary, or presidential
elections held in Slovakia in 2021.

State regulation of resources and support to the media sector displayed a low risk score (33%). Like
last year, a general lack of transparency regarding state advertising remains an issue. There is no specific
legislation that would stipulate the rules for the distribution of state advertising to media outlets.

Independence of PSM governance and funding continued to be problematic and scored as a high risk
(97%). The assessment is more negative than last year, when it was considered a medium risk. This
reflects several long-term serious issues for PSM in Slovakia and the lack of political will on the side of the
current political representation to address them. The current legal regulation does not guarantee the
independence of the Director-General of RTVS and board members from political influence as these are
elected directly by the Parliament. The law itself would not necessarily be problematic if the political actors
were willing to select candidates based on professional and not political criteria. The top political
representatives of the previous government under the rule of which the current Director-General was
elected openly admitted before the election that their choice would be in line with their political interest
(Urbániková, 2021). A change is not on the horizon because one of the current coalition parties vetoed the
legislative proposal to depoliticize the election of the Director-General (which is due in 2022) and declared
that the election of the Director-General should stay solely in the hands of the Parliament (Denník N,
2021c). At the same time, the funding of RTVS is inadequate (it was lamented by the Supreme Audit Office
of the Slovak Republic; Denník N, 2021d), the licence fee has not been increased since 2003, and the
broadcaster is, to a significant extent, financially dependent on a direct contract with the Ministry of Culture.
This further deepens RTVS's dependence on political power. The lack of funding affects the online activities
of RTVS as well. Moreover, an "online public service mission" does not exist as a legal concept and is not
defined in law.

Page 15 The Centre for Media Pluralism and Media Freedom is co-financed by the European Union
3.4. Social Inclusiveness (54% - medium risk)
The Social Inclusiveness area focuses on the access to media by specific groups in society: minorities, local
and regional communities, women and people with disabilities. It also examines the country’s media literacy
environment, including the digital skills of the overall population. Finally, it also includes new challenges
arising from the uses of digital technologies, which are linked to the Protection against illegal and harmful
speech.

In the domain of Social inclusiveness (54%), two out of five indicators displayed high risk: Access to
media for women and Protection against illegal and harmful speech (unchanged from last year). In the case
of Access to media for local/regional communities and community media, the risk assessment improved to
medium risk from high, mostly due to the proposed new law that introduces the concept of community
media to Slovak law and regulates the conditions of their operation (TA3/TASR, 2021). The risk assessment
also improved for Access to media for minorities (to low risk from medium), primarily due to a more positive
evaluation of RTVS's national-minorities broadcasting by the RTVS Council (RTVS, 2021). Media literacy
remains in the medium-risk zone.

The risk score for Access to media for minorities decreased to low risk from medium in the current year
(to 24% from 44%). Only public service media are legally required to grant proportional airtime access to
national minorities (see section 5, para. 1, letter g) of Act No. 532/2010 Coll., on the Radio and Television of
Slovakia); this does not apply to commercial media. Risk reduction primarily reflects an improved
assessment of the RTVS's performance in this regard by the RTVS Council. While its tone was openly
critical in previous years, the recent report noted only minor problems related to broadcasting for national
minorities. It also welcomed a report and the conception of broadcasting for national minorities produced by
RTVS (RTVS, 2021). In addition, Slovakia has a well-developed and implemented legal framework for
providing media content to people with disabilities; the statistics on adherence are regularly published (RRV,
2021).

Access to media for local/regional communities and community media scored as a medium risk
(44%), an improvement compared to last year's high-risk score (75%). This reflects the fact that, although

Page 16 The Centre for Media Pluralism and Media Freedom is co-financed by the European Union
the legal framework for community media is missing (i.e., community media are not recognised by law), a
change seems to be on its way. As of December 2021, the Parliament is currently discussing a new law that
was drafted by the Ministry of Culture (i.e., Act on media services) that introduces the concept of community
media into Slovak law and regulates the conditions of their operations (TA3/TASR, 2021). Among other
things, the proposed Act on media services implements the Audiovisual Media Services Directive
2018/1808 that should have been transposed by September 2020.

As in the previous year, Access to media for women scored high risk (82%). Women are severely
underrepresented in executive positions and on the management boards of both public service media and
commercial media, and comprehensive gender equality policies are lacking (even in public service
medium). Besides, male experts seem to be more often invited to comment on political and other relevant
matters and events than female experts, although no systematic data are available on this topic. Such bias
is, to some extent, attributable to the lower representation of women in politics and the public space;
however, this is rarely considered problematic, and systematic efforts to achieve equitable representation
for women in the media are lacking.

Media literacy remains in the medium-risk zone (50%). The key issues are the same as in the previous
year: the media literacy policy is underdeveloped, outdated, and it is not among the priorities of the current
political leadership. Although media literacy is a compulsory cross-cutting subject in primary and secondary
education, there is some evidence that, in practice, it is not being implemented in the curriculum (Bielčiková,
2021). Activities to enhance media literacy are limited and often depend on EU funding, so they are not
sustainable in the long term.

The assessment in the area of Protection against illegal and harmful speech has not changed since the
preceding year and it scored as a high risk (71%). Disinformation is widespread in Slovakia; according to
the GLOBSEC report (2021a), Slovakia "is one of the CEE countries most susceptible to conspiracy
theories and disinformation." This has become even more evident during the COVID-19 pandemic (see
GLOBSEC, 2021b for specific examples of conspiracies and disinformation and their prevalence among
Slovak citizens). As the war in Ukraine has further increased the already high circulation of disinformation,
propaganda, and hoaxes, in February 2022, the Slovak Parliament hastily passed an amendment to Act No.
69/2018 Coll., on Cybersecurity to allow the National Security Authority to shut down sources of “malicious
content” (Slovak Spectator, 2022a). In the past, the proposals to give the National Security Authority the
power to block websites have been rejected due to fundamental rights concerns; these concerns persist
with regard to the new Act as well (for instance, the description of harmful content that can be blocked by
the National Security Authority includes "serious disinformation" but the Act does not further define the term;
in addition, the National Security Authority decides on blocking on its own initiative and at its own
discretion). Also, the dissemination of disinformation can be prosecuted under Section 361 of Act No.
300/2005 Coll., Criminal Code. Although a legal framework for sanctioning disinformation exists, what is
missing is a coherent national policy and measures against the spread of disinformation, as well as an
information security strategy; the existing policies are insufficient, not up-to-date, and not comprehensive
(see, e.g., the Conception of the Slovak Republic for the Fight against Hybrid Threats, 2018). This might
change soon because the Ministry of Defence is currently preparing the Action Plan for the Coordination of
Countering Hybrid Threats 2022-2024 (MOSR, 2021). There are numerous NGO activities and initiatives to
fight disinformation, but civil society does not have the support of the state. In addition, there is no specific
regulatory framework to counter online hate speech, and the existing law (see para. 337 and 421-424 of Act
No. 300/2005 Coll., Criminal Code) is ineffective. Efforts to remove hate speech from social media have had
limited success. According to the 6th evaluation of the Code of Conduct on Countering Illegal Hate Speech

Page 17 The Centre for Media Pluralism and Media Freedom is co-financed by the European Union
Online, in Slovakia, the rate for the elimination of hate posts on Facebook, Twitter, Instagram, Youtube, and
other social media platforms fell to 47% in 2021 from 94% in 2020 (European Commission, 2021b). Also,
the speed of elimination decreased (European Commission, 2021b), both probably due to staff shortage
and the increase of hate speech, hoaxes, and conspiracy theories related to the COVID-19 pandemic
(DigiQ, 2021).

Page 18 The Centre for Media Pluralism and Media Freedom is co-financed by the European Union
4. Pluralism in the online environment: assessment of the risks

The assessment of the risks for pluralism in the online environment gives slightly more favourable results
than the overall pluralism assessment. This applies to the domains of Political independence and Market
plurality in particular.

To start, Fundamental protection scored as a low risk with almost the same result as the overall score for
this domain (29% for digital media compared to 28% in total). Freedom of expression is clearly defined by
law, and it applies to the online environment as well, without any limits or exceptions. Freedom of
expression online is well respected; there were no reports (by scholars, NGOs, or media outlets) of a
violation in 2021, and the COVID-19 pandemic has not brought about any deterioration in this regard.

On the other hand, the online safety of journalists is a concern. Online harassment and abuse come from
different actors, especially from audience members (e.g., insults and threats via e-mail or social media) and
political actors (e.g., see European Centre for Press and Media Freedom, 2021d).

The data retention obligations for Electronic Telecommunications Operators and Internet Service Providers
are transparent and fully comply with the international human rights standards. Regulatory safeguards
regarding net neutrality are well implemented in practice and regularly monitored by the Regulatory
Authority for Electronic Communications and Postal Services. On a less positive note, the ownership
concentration of the Internet service providers (ISPs) cannot be assessed because there is no
comprehensive data for the market shares of the main players. Also, the share of households covered by
broadband Internet is well below the EU average (75% compared to 87%; European Commission, 2021a).

Page 19 The Centre for Media Pluralism and Media Freedom is co-financed by the European Union
In the dimension of Market plurality, the online media environment displayed lower risk (61%; medium risk)
than the media market overall (68%; high risk). To start with the transparency of media ownership, media-
specific legal provisions that require the disclosure of ownership details do not apply to native digital media.
Moreover, Slovakia still lacks a law that requires the disclosure of information about the ultimate owners of
news media (this applies to both legacy and native digital media). This is, to some extent, remedied by Act
No. 315/2016 coll. on the register of public sector partners, the primary purpose of which is to identify the
end-users of the benefits of the entities that receive public funds (including many major media
organisations). These entities are listed in a publicly available online register that includes details on the
actual owners. The Ministry of Culture prepared new media legislation in 2021 (as of December 2021, the
draft has been debated in the Parliament), according to which all media, including native digital, should be
entered in the register mentioned above (Denník N; 2021b). In the case of native digital media, the current
lack of transparency of ownership is particularly worrying because of the trend for the increase of biased
content, fake news, and disinformation by news websites with unclear ownership structure and funding,
which continued in 2021.

Also, native digital media are not covered by the regulatory safeguards that have been put in place to buffer
the high degree of horizontal and cross-media concentration in the news media sector. This means that
there are no set limitations for native digital media, nor are these media outlets considered when evaluating
threshold or other limitations set for traditional media (only digital branches of the traditional media are taken
into consideration). Thus, unlike traditional media, in the case of native digital media, there is no media-
specific administrative authority that oversees compliance with the ownership limitations and hears relevant
complaints. There is also no sanctioning mechanism. The Antimonopoly Office carries out the supervision
under the general rules derived from Act No. 187/2021 Coll., on the Protection of Competition without taking
into account specificities and the digital evolution of the media sector. The actual level of ownership
concentration in the online news media sector is difficult to assess because there is no data about their
market shares or advertising revenue. Based on the limited data on the Top 10 most visited Slovak
websites, the top four online news websites achieve an audience/reach share of 50% (IAB Slovakia, 2021).

Furthermore, Slovakia has yet to transpose EU Directive 2019/790; financial agreements between digital
intermediaries and news media producers to remunerate the publishers to contribute to their financing are
not in place. This is important because the Slovak audience access the online media mainly via a side-door
(via social media and search engines; IAB Slovakia, 2021). In economic terms, online news media are, in
general, more viable than their traditional counterparts, also because the year 2021 witnessed an extreme
growth of 32% in Internet advertising spending and the online sector became the strongest advertising
medium for the first time (IAB Slovakia, 2022). In addition, Slovak digital media are quite inventive and
successful in developing non-traditional advertising-based revenue streams. The most prominent news sites
have been charging for their content and setting the paywalls since 2011; in fact, Slovakia has been at the
forefront of these efforts (Baker, 2012).

When it comes to commercial influence on digital media, the legal regulation that stipulates the obligation to
avoid the influence of commercial interests applies only to radio and TV broadcasting (i.e, Act No. 308/2000
Coll., on Broadcasting and Retransmission). In this case, compliance is regularly monitored by the Council
for Broadcasting and Retransmission. Both in traditional and digital media, disguised advertisement is
banned by law (Act No. 250/2007 Coll., on Consumer Protection). Regarding self-regulation, commercial
interference is also prohibited by both the Journalist's Code of Ethics and the Code of Ethics for Advertising
Practice. There are no systematic data or reports on the commercial influences upon editorial content in the
monitored period, but this does not necessarily mean that there were no such efforts.

Page 20 The Centre for Media Pluralism and Media Freedom is co-financed by the European Union
In the dimension of Political independence, online media are less at-risk of being politically controlled than
the media sector in general (47% compared to 57%; medium-risk zone). The leading native digital media
are largely free from political influence. However, the worrying trend of the increased activity of news
websites with unclear ownership structures and the funding that produce biased content, fake news,
disinformation, and, in some cases, extremist propaganda, continued in 2021. These online media do not
adhere to journalistic standards or ethical codes of conduct, and their stories often do not have an
identifiable author. Typically, the presented views align with the extreme right or pro-Russian political
parties.

Besides, the risk also lies in the lack of regulation regarding political advertising on online platforms. Act No.
181/2014 Coll., on Electoral Campaign does not apply to news websites and broadcasting carried out
exclusively via the Internet (RVR, 2019). This also means that political parties and candidates who compete
in elections are not obliged to report separately on campaign spending on online platforms. This is, at least
partially, remedied by the estimation of the costs of the online advertising campaign provided by
Transparency International Slovakia, which are based on the analyses of the transparent accounts of
individual political parties (Transparency International Slovakia, 2020).

In the dimension of Social inclusiveness, the risk score for the online media environment somewhat
exceeds the risk identified for the total media sector (61% compared to 54%); still, in both cases, it falls
within the medium-risk zone. The digital skills of the Slovak population are average (54% of the population
has basic or above basic overall digital skills, and 19% have low overall digital skills; Eurostat, 2019). This,
together with the lack of a systematic, comprehensive, and up-to-date media literacy policy, and the
burgeoning activities of dis- and misinformation online media, leads the Slovak population to face a serious
risk for succumbing to disinformation and conspiracies (see part 3.IV for more detailed comment). These
drawbacks became fully apparent in the context of the COVID-19 pandemic. According to the Police Force
report on disinformation in Slovakia in 2021 (Police Force, 2022), most of the hoaxes spread in 2021 were
related to COVID-19, and they affected the vaccination level in Slovakia and resulted in verbal and physical
attacks against state representatives.

Page 21 The Centre for Media Pluralism and Media Freedom is co-financed by the European Union
5. Conclusions
Fundamental Protection scored as a low risk (28%). In general, the protection of the freedom of
expression and the right to information follow international human rights standards. On a more critical note,
legislation on defamation is still among the strictest in Europe (Griffen, 2017): it is a criminal offence and
may be punished with up to eight years of imprisonment (see Act No. 300/2005 Coll., Criminal Code). Also,
although the Slovak journalists' working conditions are generally rather favourable, attacks and threats
against the media do occur. Moreover, many journalists are in a vulnerable position due to the widespread
practice of avoiding standard employment contracts. On top of that, the Slovak Syndicate of Journalists, the
main professional association for journalists in Slovakia, does not effectively fulfil its role.
Recommendations for the government:

Amend the Criminal Code to decriminalise defamation or at least reduce the possible prison
sentence

Enact a specific anti-SLAPP (strategic lawsuits against public participation) legislation to

prevent vexatious lawsuits against journalists

Recommendations for the journalists:

Renew and strengthen (or newly establish) the professional association of journalists that
would act as a respected voice for journalists and journalism in Slovakia

Recommendations for the National Labour Inspectorate:

Monitor compliance with the labour law in the media sector, with a focus on the performance of
illegal work (i.e., dependent work carried out outside an employment relationship)

Market Plurality scored a high risk (68%). Slovakia still lacks a law that would require the disclosure of
information on the ultimate owners of news media (although, a legislative change is on the way). The
current regulatory safeguards against a high degree of horizontal and cross-media concentration of
ownership in the media sector do not cover native digital media and they do not consider the ultimate
owners of the media companies. The data on the market shares within individual media sectors are not
collected and published. The COVID-19 pandemic struck the Slovak media sector hard in 2020; the
financial situation improved in 2021, and revenues have risen slightly, but the media sector has yet to
recover fully.

Recommendations for the government:

Enact a law that requires the disclosure of information on the ultimate owners of news media

Political Independence scored as a medium risk (57%). Independence of PSM governance and funding
continues to be problematic. Change is not in the offing because the legislative effort of the Ministry of

Page 22 The Centre for Media Pluralism and Media Freedom is co-financed by the European Union
culture conducted in 2021 to depoliticize the election of the Director-General failed. Also, PSM funding
remains inadequate. At the same time, no regulatory safeguards prevent political representatives from
owning media companies (and some are taking advantage of it). Moreover, the worrying trend of the
increased activity of news websites with unclear ownership structures and funding, which produce biased
content, fake news, and disinformation, continued in 2021.

Recommendations for the government:

Amend the Act on the Radio and Television of Slovakia to depoliticise the election of the
Director-General and the members of the Council of RTVS; increase the licence fees; and
ensure sufficient, stable, and reliable funding for RTVS

Require the Council for Broadcasting and Retransmission to regularly carry out/commission
rigorous empirical analyses of the neutrality and the objectivity of the news and current affairs
programmes of RTVS; undertake studies of its conduct and its fulfilment of its public-service
mission; and provide funding for these purposes

Enact a law to prevent political representatives from owning media companies to prevent
conflicts of interests

Adopt the rules for fair and transparent distribution of state advertising and introduce a
monitoring mechanism

Social Inclusiveness scored as a medium risk (54%). The PSM's performance in broadcasting for national
minorities improved compared to the preceding year. Also, although a legal framework for community media
is missing (community media are not recognised by law), a legislative change seems to be on its way. On a
more negative note, women are severely underrepresented in executive positions and on media
organisations' management boards, and comprehensive gender equality policies are lacking. The media
literacy policy is underdeveloped and outdated, and that is one of the reasons why disinformation is
widespread in Slovakia, which has become even more evident during the COVID-19 pandemic.

Recommendations for the government:

Develop and implement an up-to-date and comprehensive action plan to increase media literacy
and digital skills

Develop and implement a comprehensive action plan to tackle the rise of disinformation media

Recommendations for media organisations:

Develop and implement comprehensive gender equality policies to cover both personnel issues
and programming content

Page 23 The Centre for Media Pluralism and Media Freedom is co-financed by the European Union
6. Notes
[1] Please note that as regards the PSM signal coverage, an error occurred in the Media Pluralism
Monitor (MPM) 2021 report and the analysis produced incorrect scores for this specific variable (see
Corrigendum in https://cmpf.eui.eu/mpm2021-results/). Thus, the year-on-year increase in risk score is
the result of an erroneous assessment in the previous year.

Page 24 The Centre for Media Pluralism and Media Freedom is co-financed by the European Union
7. References
Act No. 452/2021 Coll., on Electronic Communications, Slov-lex (Legal and information portal), Ministry of
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16, 2022].
Act No. 187/2021 Coll., on the Protection of Competition, Slov-lex (Legal and information portal), Ministry of
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Page 25 The Centre for Media Pluralism and Media Freedom is co-financed by the European Union
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Page 29 The Centre for Media Pluralism and Media Freedom is co-financed by the European Union
ANNEXE I. COUNTRY TEAM

First name Last name Position Institution MPM2022 CT

Leader

Marína Urbániková Assistant Professor Masaryk University X

ANNEXE II. GROUP OF EXPERTS

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

First name Last name Position Institution

Ivan Antala President Association of Radio Stations of

Slovakia

Ľuboš Kukliš Chief Executive Council for Broadcasting and

Retransmission of Slovakia

Ján Hacek Associate Professor; Head of Comenius University

Department of Journalism

Alžbeta Calpaš Mordinová Lawyer Association of Television

Broadcasters of Slovakia

Alena Pániková Chairperson The Print-Digital Council of the

Slovak Republic

Peter Hanák Journalist; PhD candidate in media Aktuality.sk; Charles University

studies (Charles University)
 Research Project Report doi:10.2870/946133
Issue - ISBN:978-92-9466-303-0
QM-07-22-563-EN-N
June 2022

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