28/04/2026
The role of the Audiovisual Media Services Directive in promoting media literacy
The Audiovisual Media Services Directive (AVMSD) came into force in 2010 and governs the EU-wide coordination of national legislation on all audiovisual media providers, namely traditional TV broadcasts and on-demand services. The goals behind an EU-wide coordination of audiovisual media include providing rules to shape technological developments, creating a level playing field for emerging audiovisual media, preserving cultural diversity, protecting children and consumers, safeguarding media pluralism, combating racial and religious hatred, and guaranteeing the independence of national media regulators. The adoption of the AVMSD has marked the most significant policy-level step for media literacy. Through this Directive, media literacy was, for the first time, explicitly incorporated into European Union legislation.
Within the current EU legislative framework, the AVMSD outlines media literacy provisions, and the European Media Freedom Act offers a definition. The Digital Services Act supports these efforts by promoting transparency and user empowerment, though it does not explicitly frame it as media literacy.
According to the Council of the EU, since the revision of the AVMSD in 2018, the audiovisual and media landscape has changed to a significant extent, due to factors such as the rise of social media and video-sharing platforms, the increase of disinformation, misinformation, hate speech and hybrid threats, and the emergence of (generative) artificial intelligence. Similarly, the Commission notes that linear media services, such as television broadcasting, have been losing relevance, while influencers and new media content distribution methods have become a significant part of the European audiovisual media. Therefore, a call for evidence was launched by the European Commission in November 2025, as part of the Commission’s commitments in the European Democracy Shield, to collect feedback about the impact and the need to update the Directive.
EAVI was actively involved during the 2018 revision of the AVMSD, and contributed to maintaining the explicit recognition of media literacy in the Directive as an all-encompassing term that goes beyond technical and critical thinking skills.
Shortcomings and implementation challenges
Some of the AVMSD provisions have been subject to enforcement challenges. The AVMSD being a Directive obliges the Member States to adapt the provisions to their national regulations, taking into account national, cultural, and social contexts. However, setting minimum rules has also led to fragmentation; several Member States adopted different regulations regarding the prominence of services of general interest on video-sharing platforms. According to the European Parliament resolution on the implementation of the AVMSD, differing national approaches can increase regulatory complexity and compliance burdens for providers operating across borders.
Gaps in implementation are significant challenges as well. For example, several Member States failed to meet the deadlines for transposing the Directive into national law, which delayed its effective implementation. In addition, enforcement capacities differ considerably among national regulators. As a result, it is concerning that the Directive might be applied inconsistently across the EU.
Another concern relates to the Directive’s reliance on self-regulation and co-regulation mechanisms. The AVMSD encourages industry actors to develop and implement voluntary codes of conduct, particularly in areas such as advertising practices and the protection of minors. However, these voluntary frameworks have proven insufficient and lack robust oversight. As a result, their effectiveness is questionable, including in situations where harmful forms of marketing continue to target children despite such guidelines.
Furthermore, the Council of the EU, in its Council Conclusions on the assessment of the legal framework for audiovisual media services and video-sharing platform services, acknowledges that the development of video-sharing platform services has created new opportunities for individuals to exercise freedom of expression and access information. At the same time, it recognises that the rapid expansion of these services has introduced significant risks for both users and society more broadly. EAVI regrets that freedom of expression has also been instrumentalised by actors such as X, to legitimise the spread of harmful narratives. The Council invites the Commission to evaluate the AVMSD’s rules and their application to online platforms, and to assess whether current provisions protecting the public from harm and other societal risks arising from audiovisual content available on such platforms are sufficient. Specifically, the Council suggests a higher level of protection for children and young people, stricter obligations for video-sharing platforms such as YouTube and TikTok, and the reinforcement of reliable and pluralistic media to combat disinformation (The Council of the EU, 2025).
The key points to be debated during the 2026 revision include ensuring sufficient protection for viewers, especially younger ones, when viewing audiovisual content online, and the growing importance of new media players, such as influencers on video-sharing platforms.
EAVI’s contribution to the consultation and policy recommendations:
As part of the upcoming revision, EAVI recommends the following:
- Strengthening media literacy obligations for video-sharing platforms (Article 28b). Article 28b establishes an important foundation by requiring, under the control of Member States, that video-sharing platform providers protect users from harmful content and provide media literacy measures and tools. However, these obligations should be further clarified and operationalised. The revised Directive should introduce more concrete requirements and guidance to ensure that media literacy tools are visible, accessible, and effective. In doing so, it should adopt stronger ‘protection by empowerment’ and ‘by design’ approaches, ensuring that users are equipped with the media literacy skills necessary to understand, and navigate content. Existing legal gaps should be addressed to ensure that VSPs and new media actors, including influencers, contribute to promoting media literacy and protecting users’ rights in a complementary manner with other obligations set out under the Digital Services Act.
- Strengthening Member States’ obligations and measurement standards (Article 33a). Article 33a requires Member States to promote and develop media literacy skills, but its current formulation leaves significant room for uneven implementation. The revised Directive should therefore provide clearer and more actionable guidance for national media literacy strategies and ensure greater consistency across the Union. In particular, it should introduce common EU indicators to assess media literacy levels, and ensure that media literacy is addressed as a standalone topic in the European Commission implementation reports. In this context, EAVI calls on the European Commission to provide Member States with indicators to measure media literacy levels more accurately, in a unified European approach. The revised version of the AVMSD should also rely on existing studies and frameworks, namely EAVI’s “Study on Assessment Criteria for Media Literacy Levels” and the Council of Europe’s CDMSI’s “National Media and Information Literacy (MIL) Strategies, Practical Steps and Indicators”.
- Legal interaction with other EU legislation and the definition of media literacy. The revision of the AVMSD should ensure consistency and complementarity with other relevant EU legislation, including the Digital Services Act, the Artificial Intelligence Act, and the European Media Freedom Act. There should be a clear, consistent definition of media literacy. The current definition embedded in the European Media Freedom Act and commonly used in EU legislation should be further developed to reflect its broader human dimension and go beyond the acquisition of technical and critical thinking skills. Media literacy encompasses individuals’ capacity to understand, interpret, and interact with media environments, as well as the attitudes, values, and behavioural and emotional factors that shape how they perceive and engage with content, including their ability to recognise and respond to emotional triggers and vulnerabilities exploited by social media business models.
- Promoting media pluralism and access to reliable information. The revised Directive should further strengthen provisions to safeguard media pluralism and ensure the prominence of general-interest content. Ensuring that citizens, including children, have easy access to diverse, reliable, and high-quality information is a key condition for informed participation in democratic life.
- Adopting a whole-of-society approach. Effective media literacy policies require the active involvement of a broad range of stakeholders. Member States should therefore be encouraged to foster cooperation with civil society, academia, educators, media organisations, and other relevant actors in the development and implementation of media literacy initiatives.
- Ensuring a lifelong learning and inclusive approach to media literacy. While the protection of minors remains a priority, the AVMSD should recognise media literacy as a lifelong learning process that addresses the needs of all age groups, notably elderly populations and vulnerable groups. Moreover, media literacy strategies should be adapted to the diversity of communities, taking more fully into account national, cultural, and social contexts. On that specific point, EAVI supports the AVMSD being a Directive, as it allows Member States to tailor policies and implementation measures to their specific contexts, while ensuring a common European framework.
Next steps
Stronger media literacy provisions help foster democratic resilience, reduce the impact of disinformation, and empower citizens to be protected from harmful content in the audiovisual and media environment. Therefore, the ongoing public consultation, which remains open until 1 May, constitutes a critical opportunity to ensure that these objectives are effectively embedded in the revised AVMSD. In the meantime, the European Parliament is preparing its position. Discussions are underway with a “draft report on a new strategy for media literacy and digital learning”, as well as a draft report “on the impact of social media and the online environment on young people”.
EAVI calls for the considerations outlined in this paper, particularly the strengthening of media literacy provisions, to be fully integrated into the revision process, and will participate in the consultation to ensure a robust, evidence-based approach to protecting users and promoting informed engagement with audiovisual and media content.
References
European Commission (2025). Revision of the Audiovisual Media Services Directive – AVMSD. https://digital-strategy.ec.europa.eu/en/policies/revision-avmsd
European Commission (2025). Media Literacy. https://digital-strategy.ec.europa.eu/en/policies/media-literacy
European Commission (2025). Commission seeks views and information for the evaluation of the Audiovisual Media Services Directive. https://digital-strategy.ec.europa.eu/en/news/commission-seeks-views-and-information-evaluation-audiovisual-media-services-directive
European Union (2018). Consolidated text: 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). EUR-Lex. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02010L0013-20181218
The Council of the European Union (2025). Council conclusions on assessment of the legal framework for audiovisual media services and video-sharing platform services. https://data.consilium.europa.eu/doc/document/ST-7710-2025-INIT/en/pdf
European Parliament (2023). European Parliament resolution of 9 May 2023 on the implementation of the revised Audiovisual Media Services Directive (2022/2038(INI)). https://www.europarl.europa.eu/doceo/document/TA-9-2023-0134_EN.html
Society of Audiovisual Authors (2020). Member States fail to meet the Audiovisual Media Services Directive deadline. https://www.saa-authors.eu/articles/member-states-fail-to-meet-the-audiovisual-media-services-directive-deadline
Dongo, Daria and Penna, Andrea (2023). ‘Audiovisual Media Services Directive’ and protection of minors from junk food marketing. Food Times. https://www.foodtimes.eu/planet/audiovisual-media-services-directive-and-protection-of-minors-from-junk-food-marketing/
Pinho, Jane and Höring, Rose (2025). The European Commission calls for evidence ahead of its 2026 evaluation and review of the Audiovisual Media Services Directive. Global Policy Watch. https://www.globalpolicywatch.com/2025/12/the-european-commission-calls-for-evidence-ahead-of-its-2026-evaluation-and-review-of-the-audiovisual-media-services-directive/
Related Posts
28/04/2026
The role of the Audiovisual Media Services Directive in promoting media literacy
The Audiovisual Media Services Directive (AVMSD) came into force in 2010 and governs the EU-wide coordination of national legislation on all audiovisual media providers, namely traditional TV broadcasts and on-demand services. The goals behind an EU-wide coordination of audiovisual media include providing rules to shape technological developments, creating a level playing field for emerging audiovisual media, preserving cultural diversity, protecting children and consumers, safeguarding media pluralism, combating racial and religious hatred, and guaranteeing the independence of national media regulators. The adoption of the AVMSD has marked the most significant policy-level step for media literacy. Through this Directive, media literacy was, for the first time, explicitly incorporated into European Union legislation.
Within the current EU legislative framework, the AVMSD outlines media literacy provisions, and the European Media Freedom Act offers a definition. The Digital Services Act supports these efforts by promoting transparency and user empowerment, though it does not explicitly frame it as media literacy.
According to the Council of the EU, since the revision of the AVMSD in 2018, the audiovisual and media landscape has changed to a significant extent, due to factors such as the rise of social media and video-sharing platforms, the increase of disinformation, misinformation, hate speech and hybrid threats, and the emergence of (generative) artificial intelligence. Similarly, the Commission notes that linear media services, such as television broadcasting, have been losing relevance, while influencers and new media content distribution methods have become a significant part of the European audiovisual media. Therefore, a call for evidence was launched by the European Commission in November 2025, as part of the Commission’s commitments in the European Democracy Shield, to collect feedback about the impact and the need to update the Directive.
EAVI was actively involved during the 2018 revision of the AVMSD, and contributed to maintaining the explicit recognition of media literacy in the Directive as an all-encompassing term that goes beyond technical and critical thinking skills.
Shortcomings and implementation challenges
Some of the AVMSD provisions have been subject to enforcement challenges. The AVMSD being a Directive obliges the Member States to adapt the provisions to their national regulations, taking into account national, cultural, and social contexts. However, setting minimum rules has also led to fragmentation; several Member States adopted different regulations regarding the prominence of services of general interest on video-sharing platforms. According to the European Parliament resolution on the implementation of the AVMSD, differing national approaches can increase regulatory complexity and compliance burdens for providers operating across borders.
Gaps in implementation are significant challenges as well. For example, several Member States failed to meet the deadlines for transposing the Directive into national law, which delayed its effective implementation. In addition, enforcement capacities differ considerably among national regulators. As a result, it is concerning that the Directive might be applied inconsistently across the EU.
Another concern relates to the Directive’s reliance on self-regulation and co-regulation mechanisms. The AVMSD encourages industry actors to develop and implement voluntary codes of conduct, particularly in areas such as advertising practices and the protection of minors. However, these voluntary frameworks have proven insufficient and lack robust oversight. As a result, their effectiveness is questionable, including in situations where harmful forms of marketing continue to target children despite such guidelines.
Furthermore, the Council of the EU, in its Council Conclusions on the assessment of the legal framework for audiovisual media services and video-sharing platform services, acknowledges that the development of video-sharing platform services has created new opportunities for individuals to exercise freedom of expression and access information. At the same time, it recognises that the rapid expansion of these services has introduced significant risks for both users and society more broadly. EAVI regrets that freedom of expression has also been instrumentalised by actors such as X, to legitimise the spread of harmful narratives. The Council invites the Commission to evaluate the AVMSD’s rules and their application to online platforms, and to assess whether current provisions protecting the public from harm and other societal risks arising from audiovisual content available on such platforms are sufficient. Specifically, the Council suggests a higher level of protection for children and young people, stricter obligations for video-sharing platforms such as YouTube and TikTok, and the reinforcement of reliable and pluralistic media to combat disinformation (The Council of the EU, 2025).
The key points to be debated during the 2026 revision include ensuring sufficient protection for viewers, especially younger ones, when viewing audiovisual content online, and the growing importance of new media players, such as influencers on video-sharing platforms.
EAVI’s contribution to the consultation and policy recommendations:
As part of the upcoming revision, EAVI recommends the following:
- Strengthening media literacy obligations for video-sharing platforms (Article 28b). Article 28b establishes an important foundation by requiring, under the control of Member States, that video-sharing platform providers protect users from harmful content and provide media literacy measures and tools. However, these obligations should be further clarified and operationalised. The revised Directive should introduce more concrete requirements and guidance to ensure that media literacy tools are visible, accessible, and effective. In doing so, it should adopt stronger ‘protection by empowerment’ and ‘by design’ approaches, ensuring that users are equipped with the media literacy skills necessary to understand, and navigate content. Existing legal gaps should be addressed to ensure that VSPs and new media actors, including influencers, contribute to promoting media literacy and protecting users’ rights in a complementary manner with other obligations set out under the Digital Services Act.
- Strengthening Member States’ obligations and measurement standards (Article 33a). Article 33a requires Member States to promote and develop media literacy skills, but its current formulation leaves significant room for uneven implementation. The revised Directive should therefore provide clearer and more actionable guidance for national media literacy strategies and ensure greater consistency across the Union. In particular, it should introduce common EU indicators to assess media literacy levels, and ensure that media literacy is addressed as a standalone topic in the European Commission implementation reports. In this context, EAVI calls on the European Commission to provide Member States with indicators to measure media literacy levels more accurately, in a unified European approach. The revised version of the AVMSD should also rely on existing studies and frameworks, namely EAVI’s “Study on Assessment Criteria for Media Literacy Levels” and the Council of Europe’s CDMSI’s “National Media and Information Literacy (MIL) Strategies, Practical Steps and Indicators”.
- Legal interaction with other EU legislation and the definition of media literacy. The revision of the AVMSD should ensure consistency and complementarity with other relevant EU legislation, including the Digital Services Act, the Artificial Intelligence Act, and the European Media Freedom Act. There should be a clear, consistent definition of media literacy. The current definition embedded in the European Media Freedom Act and commonly used in EU legislation should be further developed to reflect its broader human dimension and go beyond the acquisition of technical and critical thinking skills. Media literacy encompasses individuals’ capacity to understand, interpret, and interact with media environments, as well as the attitudes, values, and behavioural and emotional factors that shape how they perceive and engage with content, including their ability to recognise and respond to emotional triggers and vulnerabilities exploited by social media business models.
- Promoting media pluralism and access to reliable information. The revised Directive should further strengthen provisions to safeguard media pluralism and ensure the prominence of general-interest content. Ensuring that citizens, including children, have easy access to diverse, reliable, and high-quality information is a key condition for informed participation in democratic life.
- Adopting a whole-of-society approach. Effective media literacy policies require the active involvement of a broad range of stakeholders. Member States should therefore be encouraged to foster cooperation with civil society, academia, educators, media organisations, and other relevant actors in the development and implementation of media literacy initiatives.
- Ensuring a lifelong learning and inclusive approach to media literacy. While the protection of minors remains a priority, the AVMSD should recognise media literacy as a lifelong learning process that addresses the needs of all age groups, notably elderly populations and vulnerable groups. Moreover, media literacy strategies should be adapted to the diversity of communities, taking more fully into account national, cultural, and social contexts. On that specific point, EAVI supports the AVMSD being a Directive, as it allows Member States to tailor policies and implementation measures to their specific contexts, while ensuring a common European framework.
Next steps
Stronger media literacy provisions help foster democratic resilience, reduce the impact of disinformation, and empower citizens to be protected from harmful content in the audiovisual and media environment. Therefore, the ongoing public consultation, which remains open until 1 May, constitutes a critical opportunity to ensure that these objectives are effectively embedded in the revised AVMSD. In the meantime, the European Parliament is preparing its position. Discussions are underway with a “draft report on a new strategy for media literacy and digital learning”, as well as a draft report “on the impact of social media and the online environment on young people”.
EAVI calls for the considerations outlined in this paper, particularly the strengthening of media literacy provisions, to be fully integrated into the revision process, and will participate in the consultation to ensure a robust, evidence-based approach to protecting users and promoting informed engagement with audiovisual and media content.
References
European Commission (2025). Revision of the Audiovisual Media Services Directive – AVMSD. https://digital-strategy.ec.europa.eu/en/policies/revision-avmsd
European Commission (2025). Media Literacy. https://digital-strategy.ec.europa.eu/en/policies/media-literacy
European Commission (2025). Commission seeks views and information for the evaluation of the Audiovisual Media Services Directive. https://digital-strategy.ec.europa.eu/en/news/commission-seeks-views-and-information-evaluation-audiovisual-media-services-directive
European Union (2018). Consolidated text: 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). EUR-Lex. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02010L0013-20181218
The Council of the European Union (2025). Council conclusions on assessment of the legal framework for audiovisual media services and video-sharing platform services. https://data.consilium.europa.eu/doc/document/ST-7710-2025-INIT/en/pdf
European Parliament (2023). European Parliament resolution of 9 May 2023 on the implementation of the revised Audiovisual Media Services Directive (2022/2038(INI)). https://www.europarl.europa.eu/doceo/document/TA-9-2023-0134_EN.html
Society of Audiovisual Authors (2020). Member States fail to meet the Audiovisual Media Services Directive deadline. https://www.saa-authors.eu/articles/member-states-fail-to-meet-the-audiovisual-media-services-directive-deadline
Dongo, Daria and Penna, Andrea (2023). ‘Audiovisual Media Services Directive’ and protection of minors from junk food marketing. Food Times. https://www.foodtimes.eu/planet/audiovisual-media-services-directive-and-protection-of-minors-from-junk-food-marketing/
Pinho, Jane and Höring, Rose (2025). The European Commission calls for evidence ahead of its 2026 evaluation and review of the Audiovisual Media Services Directive. Global Policy Watch. https://www.globalpolicywatch.com/2025/12/the-european-commission-calls-for-evidence-ahead-of-its-2026-evaluation-and-review-of-the-audiovisual-media-services-directive/
Related Posts
28/04/2026
The role of the Audiovisual Media Services Directive in promoting media literacy
The Audiovisual Media Services Directive (AVMSD) came into force in 2010 and governs the EU-wide coordination of national legislation on all audiovisual media providers, namely traditional TV broadcasts and on-demand services. The goals behind an EU-wide coordination of audiovisual media include providing rules to shape technological developments, creating a level playing field for emerging audiovisual media, preserving cultural diversity, protecting children and consumers, safeguarding media pluralism, combating racial and religious hatred, and guaranteeing the independence of national media regulators. The adoption of the AVMSD has marked the most significant policy-level step for media literacy. Through this Directive, media literacy was, for the first time, explicitly incorporated into European Union legislation.
Within the current EU legislative framework, the AVMSD outlines media literacy provisions, and the European Media Freedom Act offers a definition. The Digital Services Act supports these efforts by promoting transparency and user empowerment, though it does not explicitly frame it as media literacy.
According to the Council of the EU, since the revision of the AVMSD in 2018, the audiovisual and media landscape has changed to a significant extent, due to factors such as the rise of social media and video-sharing platforms, the increase of disinformation, misinformation, hate speech and hybrid threats, and the emergence of (generative) artificial intelligence. Similarly, the Commission notes that linear media services, such as television broadcasting, have been losing relevance, while influencers and new media content distribution methods have become a significant part of the European audiovisual media. Therefore, a call for evidence was launched by the European Commission in November 2025, as part of the Commission’s commitments in the European Democracy Shield, to collect feedback about the impact and the need to update the Directive.
EAVI was actively involved during the 2018 revision of the AVMSD, and contributed to maintaining the explicit recognition of media literacy in the Directive as an all-encompassing term that goes beyond technical and critical thinking skills.
Shortcomings and implementation challenges
Some of the AVMSD provisions have been subject to enforcement challenges. The AVMSD being a Directive obliges the Member States to adapt the provisions to their national regulations, taking into account national, cultural, and social contexts. However, setting minimum rules has also led to fragmentation; several Member States adopted different regulations regarding the prominence of services of general interest on video-sharing platforms. According to the European Parliament resolution on the implementation of the AVMSD, differing national approaches can increase regulatory complexity and compliance burdens for providers operating across borders.
Gaps in implementation are significant challenges as well. For example, several Member States failed to meet the deadlines for transposing the Directive into national law, which delayed its effective implementation. In addition, enforcement capacities differ considerably among national regulators. As a result, it is concerning that the Directive might be applied inconsistently across the EU.
Another concern relates to the Directive’s reliance on self-regulation and co-regulation mechanisms. The AVMSD encourages industry actors to develop and implement voluntary codes of conduct, particularly in areas such as advertising practices and the protection of minors. However, these voluntary frameworks have proven insufficient and lack robust oversight. As a result, their effectiveness is questionable, including in situations where harmful forms of marketing continue to target children despite such guidelines.
Furthermore, the Council of the EU, in its Council Conclusions on the assessment of the legal framework for audiovisual media services and video-sharing platform services, acknowledges that the development of video-sharing platform services has created new opportunities for individuals to exercise freedom of expression and access information. At the same time, it recognises that the rapid expansion of these services has introduced significant risks for both users and society more broadly. EAVI regrets that freedom of expression has also been instrumentalised by actors such as X, to legitimise the spread of harmful narratives. The Council invites the Commission to evaluate the AVMSD’s rules and their application to online platforms, and to assess whether current provisions protecting the public from harm and other societal risks arising from audiovisual content available on such platforms are sufficient. Specifically, the Council suggests a higher level of protection for children and young people, stricter obligations for video-sharing platforms such as YouTube and TikTok, and the reinforcement of reliable and pluralistic media to combat disinformation (The Council of the EU, 2025).
The key points to be debated during the 2026 revision include ensuring sufficient protection for viewers, especially younger ones, when viewing audiovisual content online, and the growing importance of new media players, such as influencers on video-sharing platforms.
EAVI’s contribution to the consultation and policy recommendations:
As part of the upcoming revision, EAVI recommends the following:
- Strengthening media literacy obligations for video-sharing platforms (Article 28b). Article 28b establishes an important foundation by requiring, under the control of Member States, that video-sharing platform providers protect users from harmful content and provide media literacy measures and tools. However, these obligations should be further clarified and operationalised. The revised Directive should introduce more concrete requirements and guidance to ensure that media literacy tools are visible, accessible, and effective. In doing so, it should adopt stronger ‘protection by empowerment’ and ‘by design’ approaches, ensuring that users are equipped with the media literacy skills necessary to understand, and navigate content. Existing legal gaps should be addressed to ensure that VSPs and new media actors, including influencers, contribute to promoting media literacy and protecting users’ rights in a complementary manner with other obligations set out under the Digital Services Act.
- Strengthening Member States’ obligations and measurement standards (Article 33a). Article 33a requires Member States to promote and develop media literacy skills, but its current formulation leaves significant room for uneven implementation. The revised Directive should therefore provide clearer and more actionable guidance for national media literacy strategies and ensure greater consistency across the Union. In particular, it should introduce common EU indicators to assess media literacy levels, and ensure that media literacy is addressed as a standalone topic in the European Commission implementation reports. In this context, EAVI calls on the European Commission to provide Member States with indicators to measure media literacy levels more accurately, in a unified European approach. The revised version of the AVMSD should also rely on existing studies and frameworks, namely EAVI’s “Study on Assessment Criteria for Media Literacy Levels” and the Council of Europe’s CDMSI’s “National Media and Information Literacy (MIL) Strategies, Practical Steps and Indicators”.
- Legal interaction with other EU legislation and the definition of media literacy. The revision of the AVMSD should ensure consistency and complementarity with other relevant EU legislation, including the Digital Services Act, the Artificial Intelligence Act, and the European Media Freedom Act. There should be a clear, consistent definition of media literacy. The current definition embedded in the European Media Freedom Act and commonly used in EU legislation should be further developed to reflect its broader human dimension and go beyond the acquisition of technical and critical thinking skills. Media literacy encompasses individuals’ capacity to understand, interpret, and interact with media environments, as well as the attitudes, values, and behavioural and emotional factors that shape how they perceive and engage with content, including their ability to recognise and respond to emotional triggers and vulnerabilities exploited by social media business models.
- Promoting media pluralism and access to reliable information. The revised Directive should further strengthen provisions to safeguard media pluralism and ensure the prominence of general-interest content. Ensuring that citizens, including children, have easy access to diverse, reliable, and high-quality information is a key condition for informed participation in democratic life.
- Adopting a whole-of-society approach. Effective media literacy policies require the active involvement of a broad range of stakeholders. Member States should therefore be encouraged to foster cooperation with civil society, academia, educators, media organisations, and other relevant actors in the development and implementation of media literacy initiatives.
- Ensuring a lifelong learning and inclusive approach to media literacy. While the protection of minors remains a priority, the AVMSD should recognise media literacy as a lifelong learning process that addresses the needs of all age groups, notably elderly populations and vulnerable groups. Moreover, media literacy strategies should be adapted to the diversity of communities, taking more fully into account national, cultural, and social contexts. On that specific point, EAVI supports the AVMSD being a Directive, as it allows Member States to tailor policies and implementation measures to their specific contexts, while ensuring a common European framework.
Next steps
Stronger media literacy provisions help foster democratic resilience, reduce the impact of disinformation, and empower citizens to be protected from harmful content in the audiovisual and media environment. Therefore, the ongoing public consultation, which remains open until 1 May, constitutes a critical opportunity to ensure that these objectives are effectively embedded in the revised AVMSD. In the meantime, the European Parliament is preparing its position. Discussions are underway with a “draft report on a new strategy for media literacy and digital learning”, as well as a draft report “on the impact of social media and the online environment on young people”.
EAVI calls for the considerations outlined in this paper, particularly the strengthening of media literacy provisions, to be fully integrated into the revision process, and will participate in the consultation to ensure a robust, evidence-based approach to protecting users and promoting informed engagement with audiovisual and media content.
References
European Commission (2025). Revision of the Audiovisual Media Services Directive – AVMSD. https://digital-strategy.ec.europa.eu/en/policies/revision-avmsd
European Commission (2025). Media Literacy. https://digital-strategy.ec.europa.eu/en/policies/media-literacy
European Commission (2025). Commission seeks views and information for the evaluation of the Audiovisual Media Services Directive. https://digital-strategy.ec.europa.eu/en/news/commission-seeks-views-and-information-evaluation-audiovisual-media-services-directive
European Union (2018). Consolidated text: 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). EUR-Lex. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02010L0013-20181218
The Council of the European Union (2025). Council conclusions on assessment of the legal framework for audiovisual media services and video-sharing platform services. https://data.consilium.europa.eu/doc/document/ST-7710-2025-INIT/en/pdf
European Parliament (2023). European Parliament resolution of 9 May 2023 on the implementation of the revised Audiovisual Media Services Directive (2022/2038(INI)). https://www.europarl.europa.eu/doceo/document/TA-9-2023-0134_EN.html
Society of Audiovisual Authors (2020). Member States fail to meet the Audiovisual Media Services Directive deadline. https://www.saa-authors.eu/articles/member-states-fail-to-meet-the-audiovisual-media-services-directive-deadline
Dongo, Daria and Penna, Andrea (2023). ‘Audiovisual Media Services Directive’ and protection of minors from junk food marketing. Food Times. https://www.foodtimes.eu/planet/audiovisual-media-services-directive-and-protection-of-minors-from-junk-food-marketing/
Pinho, Jane and Höring, Rose (2025). The European Commission calls for evidence ahead of its 2026 evaluation and review of the Audiovisual Media Services Directive. Global Policy Watch. https://www.globalpolicywatch.com/2025/12/the-european-commission-calls-for-evidence-ahead-of-its-2026-evaluation-and-review-of-the-audiovisual-media-services-directive/
