INDUSTRIES, MEDIA | EU Commission issues guidelines for VLOPs on general features of declaration form pursuant to Art. 18(1) of the EU Media Freedom Act

On 6 February 2026, the EU Commission announced the issuance of new guidelines (Guidelines) targeting providers of Very Large Online Platforms (VLOPs) and concerning the implementation of the declaration of functionality for media service providers pursuant to Article 18 (1) of Regulation (EU) 2024/1083 (EU Media Freedom Act), a recently adopted EU regulation aimed at safeguarding media independence and pluralism across the EU.

Article 18 of the EU Media Freedom Act establishes a set of safeguards that must be granted to media service providers when a VLOP intends to apply moderation measures, such as the removal of content or restrictions on its visibility. These safeguards include, inter alia, the obligation to notify media service providers in advance of the intention to remove content and to allow them a period of 24 hours to respond before the measure is implemented.

In order to benefit from these safeguards, however, media service providers must first submit a declaration pursuant to Article 18(1) of the EU Media Freedom Act. The Guidelines provide practical indications on how VLOPs should implement the declaration functionality and on how media service providers should complete and manage their declarations. They also outline procedures for VLOPs to consult competent regulatory authorities where doubts arise and allow for the involvement of civil society organizations, including fact-checking organizations, in reviewing declarations.

Notably, the Guidelines specify that the declaration functionality should form an integral part of the VLOP’s infrastructure and should be easily accessible to media service providers. Providers should also be able to monitor and manage the status of their declarations through their platform accounts and update, amend or withdraw them at any time without disproportionate burdens.

The Guidelines further provide that declarations should be made publicly available in an easily accessible and machine-readable format. In addition, VLOPs should ensure the availability of a human contact point for exchanges with media service providers, national regulatory authorities and relevant civil society organisations.

Newsletter n. 116 – March 2026