Nearly three years after the adoption of the Montenegro Media Strategy 2023-2027, a review of its implementation by the Centre for Civic Education (CCE) points to a pronounced gap between legislative and substantive progress. While most key legislative activities have been completed, the objectives that depend on the implementation of regulations and changes in practice – RTCG’s independence, effective self-regulation, the socio-economic position of media employees and, in particular, the safety of journalists – remain significantly behind schedule, with some indicators even deteriorating compared with the 2021 baseline.
The Media Strategy, adopted in October 2023, set four strategic and 15 operational objectives, with the ambition of improving freedom of expression, the quality of information, the position of journalists and the functioning of the media market.
Progress has been made at the formal legal level. In 2024, three key media laws were adopted – the Law on Media, the Law on Audiovisual Media Services and the Law on the Public Media Service of Montenegro, while the Agency for Electronic Media was transformed into the Agency for Audiovisual Media Services (AMU). This brought a significant part of the regulatory framework into line with the EU acquis.
Progress is also visible in the area of media literacy, which has been introduced as an elective subject in primary schools and is also present in some secondary schools. Montenegro rose from 33rd to 26th place in the 2026 Media Literacy Index, its best result since the index was introduced. However, the National Council for Media Literacy, which was due to be established by the end of 2024, has not been formally constituted, and not all planned measures to combat hate speech and disinformation have been implemented.
The main problems begin when the focus shifts from adopting regulations to implementing them.
The independence of the Public Media Service remains one of the most contentious issues. The election of some RTCG Council members in 2026 was accompanied by serious objections from civil society organisations concerning the documentation submitted by certain candidates and the selection procedure. Parliament voted on the candidates individually, contrary to the legally prescribed procedure, opening the door to political influence. The Delegation of the European Union called on the competent authorities during the process to promptly and thoroughly investigate allegations of irregularities, stressing the importance of a transparent RTCG Council selection process for media freedom and the rule of law, but no adequate institutional examination of those allegations followed.
Nor has the socio-economic position of media employees improved significantly. Negotiations on the Sectoral Collective Agreement for the information, printing and publishing sector began only in June 2026, almost three years after the planned deadline, while more than half of journalists still earn less than the average salary.
The most serious departure from the Strategy’s objectives is in the area of journalists’ safety. Montenegro’s Journalists’ Safety Index has been declining continuously and stood at 3.14 on a scale of 1 to 7 for 2025. Last year, 33 attacks and incidents of pressure against media workers were recorded, the highest number since records began and 40% more than a year earlier. By mid-June 2026, a further 13 cases had been registered, including three SLAPP lawsuits and three threats to life and physical safety. In July 2026, the European Commission also noted that isolated attacks on journalists continue to occur, alongside growing concern about the influence of media owned by companies from Serbia on the media landscape. Journalists’ safety is not a secondary indicator of the Media Strategy, but one of the fundamental conditions for free and professional journalism. Legislative progress has little meaning if journalists are simultaneously working in an environment of growing threats, attacks and other forms of pressure.
CCE also points to the problem of insufficient transparency in the implementation of the Strategy. For a number of planned activities and indicators – equal treatment of participants in the media market, systematic data collection on that market, informing citizens about the possibility of filing complaints about media performance, as well as some indicators concerning the quality and accessibility of media content – publicly available sources contain no reliable data on the level of implementation. CCE notes that this does not necessarily mean that a particular activity has not been carried out, but it does mean that its implementation is not sufficiently transparent and verifiable, even though the Strategy itself provides for continuous monitoring, evaluation and reporting on its implementation.
CCE therefore calls on the Ministry of Culture and Media to ensure regular, detailed and publicly available reporting on the implementation of individual activities, indicators and expenditure, and to focus the remaining implementation period of the Strategy primarily on areas where legislative changes have not produced the expected results – depoliticisation of the Public Media Service, effective self-regulation, decent socio-economic conditions for media workers and, above all, their safety.
CCE stresses that the success of the Media Strategy will not be measured solely by the number of laws adopted, but by whether journalists are safer, the media more independent, institutions more accountable and citizens better informed. For now, the gap between regulation and practice remains its weakest point.
Željka Zvicer, Programme Associate