Why? 

TV MARKET: 25,77%
The top 4 players in the TV market reach an audience share of 25,77% in Moldova, indicating a medium concentration risk. These are: 

Stețco Family (Cinema 1 and 7TV) with an audience share of 10.53%, Dan Pascari (One TV and Star TV) with an audience share of 5.83%, Renata Kellnerova (PROTV) with a 4.79% audience share, and Teleradio-Moldova (Moldova 1 and Moldova 2) with an audience share of 4.62%. The audience shares were calculated based on the data provided by TV MR MLD, representative of Nielsen in Moldova, for the first half of 2024. The audience shares were not available for TVR Moldova and for TV Gagauzia. 

PRINT MARKET: 72,77%

Only 6 print media were monitored in this study and due to the absence of readership data circulation, numbers from the National Book Chamber were used to select the print media. Subscription data for 2023 and half of 2024 (Jan-Jun) were provided by the Moldovan Post Office (Poșta Moldovei). In 2024 the biggest numbers of subscribers were attributed to Ziarul de Garda (364,832 - 29,58%), KP in Moldova (211,990 - 17,19%), Observatorul de Nord (148,923 - 12,07%) and Unghiul (108,567 - 8,80%). Cumulatively these top 4 players amount to 72,77% of subscribers in the first half of 2024. These data, when used as a proxy for audience share, would indicate a high risk of audience concentration in the Moldovan print market.

RADIO MARKET: 37%
The audience shares for the Radio were provided by Xplane ‘Consumer Target Index 2024 - spring wave’, a result of a survey conducted among the Urban population of the Republic of Moldova aged 12-65 years.

The top 4 players in the radio market reach an audience share of 37% in Moldova, indicating a medium risk. These are: 

The Lozovan family with 15,90% of the audience share which they reach through their three radio stations: Hit FM, Radio Roks, and Radio Relax; Ceslav Ciuhrii with 8,10% of the audience share which he reaches through Radio Noroc; The Guțum Family with 7,20% of the audience share which they reach through the radio stations Evropa Plus, Radio 21, and Radio.MD; The Kiriakou Family with 5,80% of shares which they reach through Kiss FM.

It is important to note that at least 5 brands of the Russian Evropeyskaya Mediagruppa (EMG) are active in the Moldovan radio market but have different ownership structures and likely operate on a franchise. Further investigation into their operations is recommended but is beyond MOM’s scope. These brands are: Evropa Plus, Avtoradio, RetroFM, Novoe Radio, and Radio 7FM, and cumulatively these radio stations have an audience share of 14,80% which is quite significant.

INTERNET MARKET: Missing data
MOM examined 17 online news media platforms, selected primarily based on Gemius Audience data. However, precise audience share calculations faced two key challenges: prominent news websites, such as Jurnal.md, did not participate in the Gemius measurement system, making their audience data unavailable; and the analysis included regional news outlets like gagauzinfo.md and gagauznews.com, which lack standardized audience metrics, making it difficult to accurately assess their reach and impact. These limitations highlight a significant gap in the available data on the online media landscape in Moldova. This is particularly concerning as online media are gaining increasing influence over the process of shaping public opinion. Without clear and comprehensive audience measurements for the online media market, there is a high risk to media pluralism in Moldova, as the true scale and impact of individual platforms remain unclear. The lack of reliable audience data for key online news sources, combined with the growing importance of online media in the public discourse, presents a significant challenge in assessing the level of media concentration and the diversity of voices in the Moldovan information space.

Why? 

Financial data, revenues, operating profit, and advertising shares of companies active in radio and television broadcasting were obtained from the Audiovisual Council. Some companies have provided this data in response to MOM information requests. Financial data are for 2023, this data was only sporadically available for online media, hence the concentration in the online market is not computable.

TV MARKET: 73.52%

The television market in Moldova appears to have a high risk of concentration with the market share of the top 4 players reaching 73.52%.

The Public Broadcaster Teleradio Moldova alone has a market share of nearly 42%. However, the calculations based on the private broadcasters also indicate a high risk of concentration with the top 4 reaching a market share of 74,18%. These are Renata Kellnerova with PROTV (21,49%), Jurnal Trust Media with Jurnal TV (21,19%), Media Alternativa with TV8 (20.05%), and the Stețco Family with Cinema 1 and 7TV (11,45%). 

RADIO MARKET: 53,50%

The radio market in Moldova shows a high risk of concentration with the top 4 players reaching a market share of 53,50%. In the private radio market, without the broadcasters that operate Television stations (i.e. Noroc Media and Euronet Media were removed), the top 4 players are: The Lozovan family through his radio stations Hit FM, Radio Relax, and Radio Roks reaches 19,36% market share; The Kiriakou Brothers through Kiss FM reached a market share of 14,94%; Jurnal Trust Media comes third with 10,92% market share of Jurnal FM; and Maria Covalenco through Radio Plai reaches a market share of 8,27%.

This calculation does not include broadcasters that operate Television stations. The revenues of Noroc Media and Vocea Basarabiei do not distinguish between radio and television. Similarly, Public Broadcasters revenues were also removed from the equation, because they do not provide outlet-specific revenue data, except Radio Chisinau operated by Pajur Alba LLC. When all the broadcasters are considered, the risk of concentration appears even higher with the top 4 reaching 86,70% market share. These would be Teleradio Moldova with 70,80% market share, Euronet Media (Vocea Basarabia with 7,80%, Romanian Radio Broadcasting (Radio Chisinau) with 5,34% and the Lozovan Family with 2,77% market share.  

PRINT MARKET: 70,41%

The print market data is based on only 6 companies investigated in the MOM database. Revenue for the full market is not publicly available. The top 2 players in print reach a market share of 70,41% which is indicative of a high risk of concentration. These are Ziarul de Gardă (Alina Radu and Aneta Grosu) with a market share of 56,54% and Observatorul de Nord (Elena Cobașneanu) with a market share of 13,86%. 

Why?

The main law regulating media ownership in Moldova is the Code on Audiovisual Media Services (CAMS), which applies specifically to audiovisual media service providers (TV and radio stations). The CAMS contains several provisions aimed at preventing media monopolies and ensuring pluralism:

• A single beneficial owner can own a maximum of 2 TV and/or 2 radio stations.
• Any person who owns more than 50% of a broadcasting licensee can own no more than 20% of another broadcasting licensee.
• Political parties, trade unions, and religious groups are prohibited from holding shares in broadcasting licensees.
• There is a 25% audience share cap - a person is deemed to have a dominant position in shaping public opinion if their weighted audience share exceeds 25% of the significant market.

However, the legislation does not contain specific regulations for print and online media to ensure ownership transparency and prevent concentration. There have been some recent amendments to the CAMS, such as lowering the audience share threshold for dominance from 35% to 25% and empowering the Audiovisual Council to suspend licenses in case of failure to remedy dominant situations. The legislation does not address vertical integration or cross-ownership across different media sectors (e.g. a single owner controlling TV, print, and online). While the Audiovisual Council and Competition Council have some oversight powers, their independence has been called into question due to recent legislative changes that increased political control over these bodies.

The media legislation in Moldova contains some specific thresholds and limits to prevent horizontal concentration in the audiovisual sector, but significant gaps remain, especially for print and online media, as well as concerns around the independence of regulatory authorities. Hence the risk to media pluralism in the field of regulatory safeguards to prevent media ownership concentration (horizontal) is assessed as medium.

Regulatory Safeguard Score:

10,5 out of 20 = Medium Risk (52%).

1 = media-specific regulation/ authority

0.5 = competition-related regulation/ authority

Why?

MOM database comprises 44  media outlets controlled by 33 companies, three of them are Public broadcasters, including the Romanian Public Broadcaster and the regional public broadcaster of the  Autonomous Territorial Unit of Gagauzia. The TOP 8 companies have a market share of 84,13%,  which is indicative of a high risk of concentration. The top 8 are active across Online, TV, and Radio markets with not a single company in the Top 8 owning Print media.

The revenues of three companies were not available: The companies are Interact Media LLC, AO PILIGRIM-DEMO, and AO „Centrul comunitar anticriză”. These companies did not respond to the MOM information requests.

Why?

The key legal framework regulating media ownership in Moldova is the Code on Audiovisual Media Services (CAMS), which specifically applies to audiovisual media service providers, covering television and radio stations. The CAMS contains several provisions aimed at preventing high levels of horizontal concentration within the audiovisual sector, such as limits on the maximum number of licenses a single beneficial owner can hold and restrictions on cross-ownership between broadcasting licensees.

However, the legislation does not address the issue of vertical integration or cross-ownership across different media sectors, such as a single entity controlling both television, print, and online media outlets. This represents a significant gap in the regulatory framework, as the growing convergence and integration of various media platforms increases the risk of excessive concentration of media ownership and influence.

While Moldova's laws do contain some sector-specific and competition-based safeguards against high degrees of cross-ownership in the audiovisual media sphere, these measures fall short of providing a comprehensive regulatory system to prevent concentrated media control across all media types, including print and online.

Moreover, concerns have been raised about the independence and effectiveness of the regulatory authorities tasked with overseeing media ownership, such as the Audiovisual Council and the Competition Council. The use of extraordinary measures, such as the suspension of broadcasting licenses by the Commission for Exceptional Situations (dissolved end of 2023 has also been criticized for bypassing the established regulatory framework and undermining the principles of transparency and due process.

Overall, the current legal and institutional arrangements in Moldova do not appear to provide sufficient and effective safeguards against the risk of high degrees of cross-media ownership concentration. 

Regulatory Safeguard Score: 4 out of 8 – Medium Risk (50%)

1 = media-specific regulation/ authority

0.5 = competition-related regulation/ authority

Why?

Ownership structures of all registered legal entities in Moldova are available at the Government Portal of Data., additionally, information about the Broadcast media can be found on the website of the Audiovisual Council of the country. MOM Sample comprises 44  media outlets, 33 media companies, and 43 individual owners. In addition to desk research MOM contacted media outlets to invite them to proactively participate in the project; based on their response and availability of data every outlet, company and owner are ranked by transparency.

• Active Transparency means company/channel informs proactively and comprehensively about its ownership, data is constantly updated and easily verifiable. 26 outlets, 20 companies, and 17  owners were ranked as Actively Transparent, i.e. 56.25% of the entire sample.  
• Passive Transparency means upon request, ownership data is easily available from the company/channel.  2 outlets, 1 company, and 1 owner were ranked as Passively Transparent, i.e. 3,57 % of the entire sample. These entities have replied to the request of information by MOM.
• Data Publicly Available means ownership data is easily available from other sources, e. g. public registries, etc. 13 outlets, 11 companies, and 13 owners were ranked as Data Publicly Available, i.e. even if the websites didn’t inform them publicly of the owners that could be found in the public records, this transparency ranking was used in 33,04% of cases. 
• Data Unavailable means ownership data is not publicly available, company/channel denies the release of information or does not respond, no public record exists. 1 outlet and 1 owner were marked with Data Unavailable or 1,79 % of the cases.
• Active Disguise means that in addition to unavailability of true data, ownership is disguised, e. g. through bogus companies, etc. 3 outlets, 2 companies, and 1 owner were marked with Active Disguise or 5,36% of the total sample

MOM Information requests were sent out by registered mail and email between 9 and 11 September 2024, reminder emails were sent out on 9 October 2024. 12 companies have provided detailed replies to our requests in written form or by email. 

As a pilot project, MOM researched the social media influencer market in Moldova, including 12 social media actors in the list. The information on 11 of them was publicly available, and only Cătălin Lungu is marked as passively transparent; he provided the information in response to MOM's request. 

Why?

The media ownership transparency safeguards in Moldova are primarily focused on the audiovisual (TV and radio) sector. Audiovisual media service providers (MSPs) are legally required to annually publish and submit reports to the Audiovisual Council (AC) containing information on their beneficial owners, shareholders and ownership structure, management, editorial policy, and funding sources. The AC is obliged to publish these reports on its website to ensure public access. The AC also has the power to impose fines on MSPs for failing to submit complete and accurate reports or for not publishing them on time. The AC monitors compliance with these transparency requirements and can reject incomplete or erroneous reports.

In contrast, there are no legal requirements for print and online media to disclose ownership, funding, and editorial information. The transparency of print and online media depends on voluntary self-regulation measures, such as those outlined in the Journalist's Code of Ethics, which encourages media outlets to publicly disclose their address, editorial policies, contact details, owners/beneficiaries, and sources of funding.

While the Audiovisual Council has taken steps to improve the transparency of ownership information for TV and radio stations, including introducing a new annual reporting template and rejecting incomplete reports, there have been some challenges, such as instances where state security agencies have claimed information on media ownership is classified, undermining transparency. Additionally, the effectiveness of the existing transparency measures depends on the independence and capacity of the regulatory authorities to enforce them consistently.

Overall, the media ownership transparency framework in Moldova is primarily focused on the audiovisual sector, leaving significant gaps for print and online media, where ownership and funding information are not subject to mandatory disclosure requirements. Hence the risk related to ownership transparency is assessed as medium. 

Regulatory Safeguard Score: 2,5 out of 5 - Medium Risk (50%).

1 = media-specific regulation/ authority

0.5 = competition-related regulation/ authority

Why?

Politicians from the Republic of Moldova, with some exceptions, do not appear to be direct owners of media outlets. However, their influence in this field remains visible. One of the country's most watched TV stations, Exclusiv TV, is owned by the wife of a socialist deputy, Ludmila Furculița, while other TV stations employ people in key positions who have previously worked with or collaborated alongside politicians or media institutions controlled by political figures. Some media owners have also had, to varying degrees, past links to the political environment, parties, or politicians.

In certain cases, although there is no concrete evidence, there are suspicions that the owners of media institutions are acting as proxies, and the true beneficiaries do not appear in ownership transparency registers but are from the political sphere. At the same time, there are TV stations that are state-owned, and the appointments of the individuals managing them are made by the ruling politicians. The unregulated online domain freely allows any politician to register online media outlets without notifying any state institution and even without establishing a formal company.

Despite the authorities' efforts to block several media resources connected to the Russian Federation, there is still press content that is directly controlled by Russia in the Moldovan market. For instance, Sergey Rudnov, a Russian businessman and family friend of President Vladimir Putin, indirectly controls the periodical Komsomolskaya Pravda in Moldova, which is legally managed by a local company founded by the publication's employees. Other media institutions that spread propaganda often have politically affiliated owners.

According to national legislation, political parties or enterprises created by them cannot hold the status of beneficial owner in a private media service provider. They also do not have the right to own shares, voting rights, or capital in companies managing media outlets. If a person holding an elected position in a party's governing bodies is a founder or shareholder in a commercial/non-commercial audiovisual media company, they cannot have voting rights within that entity. Similar restrictions apply to individuals holding positions in the legislative, executive, or judicial branches of public administration.

However, there is no law limiting the direct or indirect ownership or control of mass media by politicians. Among the press institutions examined in this project, none are officially owned by any politician, but they are under the influence or control of political figures. For example, the Exclusiv TV station is owned by Ludmila Furculița, the wife of socialist deputy Corneliu Furculița. Similarly, he also previously controlled NTV Moldova, whose activities have since been halted. The Gagauzinfo portal is controlled by the former governor (Bashkan) of the autonomous Gagauz region, Irina Vlah. Additionally, the public television station in Comrat is controlled through people placed in its leadership by the fugitive oligarch Ilan Șor.

In the Republic of Moldova, there are several media outlets that are unofficially controlled by politicians or politically exposed persons. Their influence can be observed in the editorial policy and content of these press institutions, with the respective politicians frequently appearing in news, interviews, and reports, often in a positive light, while their political opponents may be quoted without being given a right of reply. In most cases, the role of such media outlets is to polish the image of the politician or political party behind them, serving as platforms for promoting their agenda and denigrating their opponents. In some instances, these media institutions may present information objectively on non-political subjects to create an appearance of impartiality.

Some media outlets do publish editorial policies that guarantee their independence and impartiality. In the case of television and radio stations, these media institutions enjoy legal protections, as Moldova's Audiovisual Code provides a legal basis for editorial independence, requiring public broadcasters to ensure impartiality and a clear separation between editorial and commercial interests. Another mechanism for promoting editorial independence is the Press Council, which provides guidelines and codes of conduct to uphold journalistic ethics and editorial autonomy. However, this self-regulatory mechanism lacks the authority to impose sanctions, and its influence depends on the willingness of media organizations to comply with its recommendations.

Many media institutions have internal editorial policies that declare their commitment to independence, transparency, and journalistic integrity, with many being signatories to the Journalist's Deontological Code. Nevertheless, in practice, these principles can be disregarded if owners or other stakeholders exert influence over editorial decisions. In other cases, media institutions do not even have formal editorial statutes, and the journalistic content they publish is biased, dictated by the interests of owners or other factors of influence.

Score: 2,63 High Risk

Why?

TV Distribution Networks

In the Republic of Moldova, TV stations are available, for a fee, through the networks of service distributors and free of charge through Multiplex A (which allows the reception of some TV stations using an antenna), as well as on the websites of some TV stations (e.g. Jurnal TV, Moldova 1).

According to the Statistical Report on the Development of the Electronic Communications Market in the Republic of Moldova published by the National Agency for Regulation in Electronic Communications and Information Technology (ANRCETI), in the period April-June 2024, there were 35 providers of paid audiovisual program transmission and retransmission in Moldova, of which 8 providers through IPTV technology and 27 providers through coaxial cable based on CATV or DVB-C technology. In June 2024, there were 687,800 subscribers in the Republic of Moldova, with a penetration rate reaching 62.4% of total households. According to the ANRCETI report, SA Moldtelecom holds 53.6% of the market, SRL TV-Box (StarNet) - 20.5% of the market, and SA Orange Moldova - 18.7% of the market.

SA Moldtelecom is state-owned and managed by a general director, selected through a competition by a competition commission that includes members of the SA Moldtelecom Council. SA Orange is a foreign-owned company, owned by the international Orange group. SRL TV-Box is affiliated with businessman Alexandru Machedon.

Radio Distribution Networks

Radio stations can be received free of charge in the Republic of Moldova, on FM frequencies, as well as online, on the websites of radio stations or in mobile applications.

Print Media Distribution Networks

In the Republic of Moldova, the main distributor of print media is the state postal service - Poșta Moldovei, which has national coverage (except for the Transnistrian region). At the end of 2023, Poșta Moldovei increased the distribution price for periodicals by 341%, jeopardizing the continued publication of newspapers. A small number of newspapers are sold through the distribution network of the private enterprise Moldpresa, which has kiosks mainly in urban areas.

Online

According to ANRCETI data, at the end of June 2024, there were 870,318 fixed Internet subscribers. SA Moldtelecom held a 48.8% share of the total number of fixed Internet subscribers connected based on FTTx technology, followed by SRL Starnet Soluții - 23.6% and SA Orange Moldova, with a share of 13.6%. Other providers hold a 14.0% share of the total number of fixed Internet subscribers connected based on FTTx technology. Also, in the Republic of Moldova, at the end of June 2024, there were 2,769,278 SIM card holders who allow the use of the Internet through smartphones.

The advertising market is dominated by television. A 2022 study showed that television stations held a market share of over 50%. The same study showed that at that time there were three advertising agencies: Casa Media, Exclusiv Sales House, and Nova TV-Grup, which sold advertising time for 22 TV channels. Casa Media was owned by Dorin Pavelescu, a businessman considered close to the fugitive oligarch Vladimir Plahotniuc, who has since fled the country. He previously owned several TV and radio stations. Exclusiv Sales House is owned by Ludmila Furculița, the wife of socialist deputy Corneliu Furculița, who is also the owner of the Exclusiv TV television station. Nova TV-Grup is owned by Valentina Stețco. Her family is also involved in the management of two TV stations: Cinema 1 and 7TV. Casa Media and Exclusiv Sales House have been accused several times of dividing the advertising market, and the issue has also been investigated by the Competition Council. There are no studies on the advertising market in 2024. However, some data collected by the MOM Moldova team shows that the two large companies that previously operated, Exclusiv Sales House and Casa Media, have disappeared from the market. In their place, two new companies have emerged: Sales Platform, founded and managed by Svetlana Caraseni, who previously managed the Exclusiv Sales House company, and Media Division, founded and managed by Octavian Hanganu, former commercial director at Casa Media. Another important player in this field in 2024 remained Nova TV-Grup, which is said to have increased its market share.

In the Republic of Moldova, TV audience measurement is carried out by the company "TV MR MLD", the official representative of the international research network The Nielsen Company in the Republic of Moldova. Starting in 2024, the audience of TV stations was to be measured by the Kantar Media company, which won the tender announced by the Council for this purpose. However, the MOM Moldova team found that although Kantar Media had won, the offer for audience measurement would be too expensive for the Moldovan market, so until funds are found, the local representative of Nielsen will continue to operate. There is no audience data for radio stations. The MOM Moldova team used data provided by the marketing research company Xplane to select the radio stations monitored. At the same time, there is no collective tool to measure the audience for the online environment, as the international measurement platform Gemius is accessible to all who pay an annual fee. Thus, the audience of some important websites is not publicly known. Data on the number of subscribers to periodicals are also not publicly available, and the MOM Moldova team obtained them through a request for information addressed to Poșta Moldovei. Although periodicals must indicate the circulation in each newspaper, there is no certainty that the indicated figures correspond to the truth.

Score: 6/12 = 2 Medium Risk

Why?

The study "Legal Analysis: Evaluation of the Audiovisual Legislation of Moldova in Relation to the Audiovisual Media Services Directive, the European Media Freedom Act, the Digital Services Act, and Other Relevant International Standards" indicates that it is unclear whether there are special rules regarding state advertising in the legislation of the Republic of Moldova. "State advertising does not appear to be addressed in the Advertising Law." The national legislation of the Republic of Moldova should be amended to include the rules and principles introduced by the European Media Freedom Act regarding state advertising, the experts recommended. This requires the introduction of a definition of state advertising. The European Media Freedom Act emphasizes that "the internal market is distorted by the non-transparent allocation of public funds used for advertising purposes, which can be preferentially allocated to national providers or can be used to covertly favor and subsidize certain media institutions that publish content favorable to the government. Regulation in this area is fragmented and limited."

In 2023, Poșta Moldovei increased the price of newspaper distribution by 340%, and the Government decided to reimburse part of the distribution costs through a support mechanism for press distribution, with the allocated funds being transferred to the accounts of Poșta Moldovei. The monitoring and transparency of the process is ensured by the Association of Independent Press, and the criteria for evaluating the files of periodical publications are transparent.

The budget of the Public Institution "Teleradio-Moldova" Company is formed from subsidies from the state budget and its own revenues. The share of state subsidies is considerable. In 2023 it was 88.3%. The executive director of Gagauziya Radio Televizionu (GRT) and their deputies develop the draft budget, and the Supervisory Board approves it, after which the document is sent for examination to the Executive Committee of Gagauzia, and then to the People's Assembly of Gagauzia for adoption.

The "Teleradio-Moldova" Company was founded by the Parliament and carries out its activity under its control. The activity of the public company is overseen by the Supervisory and Development Council, formed of seven members, appointed by the Parliament for a single six-year term. Three members are proposed by the parliamentary factions, respecting the proportional representation of the parliamentary majority and opposition. Four members are proposed by representative civil society organizations. The Council approves the statute of the public company, the rules of operation and organization, proposals to modify the budget, and proposes to the Parliament the candidacy for the position of general director of the company. The company is led by a general director, proposed by the Supervisory and Development Council and voted by the Parliament. The general director is appointed for a 7-year term, which cannot be renewed. The current general director of TRM, Vlad Țurcanu, was voted in December 2021 by the parliamentary majority of the Action and Solidarity Party (PAS). PAS amended the legislation in November 2021 to place "Teleradio-Moldova" under parliamentary control, from under the control of the Coordinating Council of Audiovisual.

The People's Assembly of Gagauzia is the founder of GRT. In this capacity, the People's Assembly approves the company's annual budget, appoints and dismisses the members of the Supervisory Board. The role of the People's Assembly as a founder was strengthened in March 2016 through legislative changes that, however, were criticized by experts as undermining the independence of the public broadcaster in Gagauzia.

In March 2024, the Parliament approved a law envisaging the creation of a media subsidization fund. Subsidies will be granted to media institutions from a special fund, which will be "fed" with allocations from the state budget, donations and grants from citizens or companies, as well as any other sources allowed by law. Annually, the Ministry of Culture will establish the priority areas for subsidizing media institutions, based on opinions received from public authorities, civil society organizations in the field of the press, etc. Subsequently, the finalized and consulted list will be approved by the minister and published on the Ministry of Culture's website. Based on the approved list of priority areas for subsidization, the ministry will organize a media project competition to be subsidized from the state budget.

The evaluation of the files in the subsidization competition will be ensured by the Council of Experts, which will operate under the Ministry of Culture. The Council will be composed of seven members: four will be appointed by the Press Council, and one member each will represent the Ministry of Culture, the Ministry of Education and Research, and the Ministry of Finance. The meetings of this body are public. The term of office of a member is five years. The same person cannot hold the position of member for more than two consecutive terms.

In March 2024, the Parliament approved a law envisaging the creation of a media subsidization fund. Subsidies will be granted to media institutions from a special fund, which will be "fed" with allocations from the state budget, donations and grants from citizens or companies, as well as any other sources allowed by law. Annually, the Ministry of Culture will establish the priority areas for subsidizing media institutions, based on opinions received from public authorities, civil society organizations in the field of the press, etc. Subsequently, the finalized and consulted list will be approved by the minister and published on the Ministry of Culture's website. Based on the approved list of priority areas for subsidization, the ministry will organize a media project competition to be subsidized from the state budget.

The evaluation of the files in the subsidization competition will be ensured by the Council of Experts, which will operate under the Ministry of Culture. The Council will be composed of seven members: four will be appointed by the Press Council, and one member each will represent the Ministry of Culture, the Ministry of Education and Research, and the Ministry of Finance. The meetings of this body are public. The term of office of a member is five years. The same person cannot hold the position of member for more than two consecutive terms.

Score: 13/6 = 2,16 Medium Risk

Sources:

"About the new media subsidization fund, in plain language" (2024), cji.md, accessed on November 11, 2024

"Draft normative acts" (2024), parlament.md, accessed on November 11, 2024

LEGAL ANALYSIS: ASSESSMENT OF MOLDOVAN AUDIOVISUAL LEGISLATION IN RELATION TO THE AUDIOVISUAL MEDIA SERVICES DIRECTIVE, EUROPEAN MEDIA FREEDOM ACT, DIGITAL SERVICES ACT, AND OTHER RELEVANT INTERNATIONAL STANDARDS, Prepared for Freedom House, by Deirdre Kevin, CommSol, April 2024, freedomhouse.org, accessed on November 11, 2024

Why?

The current legal framework in Moldova does not contain an express definition of the principle of net neutrality. However, the guarantees derived from this concept are ensured through the Electronic Communications Law No. 241/2007, which underwent amendments in 2020 to incorporate some EU standards in this area.

The Electronic Communications Law establishes the obligation for internet service providers (ISPs) to process all traffic equally, without discrimination, restriction, or interference, regardless of the sender, recipient, content, applications, or services used. The National Agency for the Regulation of Electronic Communications and Information Technology (NARECIT) is responsible for implementing this law and enforcing net neutrality norms.NARECIT has supervisory powers and can impose sanctions, including fines, on ISPs for violations of net neutrality rules, such as blocking, slowing down, modifying, or interfering with internet traffic. The effectiveness of the enforcement mechanisms is mixed, as while financial penalties can deter violations, there are challenges related to constant monitoring and swift implementation of corrective measures.

The net neutrality rules apply to all providers of public electronic communications networks and services, covering both broadband and mobile services. ISPs are allowed to implement reasonable traffic management measures that are transparent, non-discriminatory, and proportionate, based on technical quality of service requirements, and not for commercial reasons. Exceptions are allowed to comply with legislation, maintain network integrity and security, and address temporary or exceptional network congestion.

In summary, while Moldova has regulatory provisions on net neutrality through the Electronic Communications Law, the legal framework does not contain an express definition of the principle. The existing regulations and enforcement mechanisms appear to be in place, but their effectiveness in practice seems to be limited. A more comprehensive and robust net neutrality framework, with clear definitions and stronger enforcement, may be necessary to fully safeguard the principle in Moldova.

Score: 9 out of 11  = 81% Low Risk

Why?

While Moldova lacks legal gender quotas for media companies, women maintain a strong presence in managerial and key editorial positions across the industry. Analysis shows that female representation averages over 40% across all media sectors when it comes to editorial, managerial, and ownership positions.  

The television sector demonstrates the highest level of female leadership in editorial positions, with women occupying over 69%. The radio market, however, shows the lowest female representation among all media sectors. In assessing women's representation in top management, the study included female members of supervisory boards of public broadcasters (Moldova 1, Radio Moldova, TVR Moldova, and Radio Chisinau). Private media organisations typically operate without supervisory boards.

According to multiple sources, leading news media in Moldova generally do not have formal policies specifically aimed at balanced representation of women in newsrooms. While women make up nearly two-thirds of Moldova's media workers (which is about double the world average), this high representation isn't backed by formal institutional policies.

Score: 2,16 = Medium Risk