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05. 01. 2016


ANEM took part in public debate on the Draft Instruction concerning the time of broadcasting of "forced environment reality programs". In late December 2015 ANEM submitted to the Regulatory Body for Electronic Media (REM) its written comments and suggestions, proposing changes to the mentioned Draft Instruction.

In Suggestions ANEM pointed to the following fact - Instruction, as a bylaw, specifies the manner in which the Regulator applies the provisions of the law or other regulations pertaining to the obligations regarding the program content, but does not determine that any program content is unsuitable for persons under the age of 18, nor prescribe obligations of providers of media services. Therefore, ANEM proposed that the Draft should be rephrased so as to confirm the previous rules - that the categorization of programs is an obligation of media service providers, while REM, at the request of the media service provider, gives an opinion on the compliance of a program content with the rules on the protection of minors - but to closely regulate that in case of inadequate program categorization REM would find, but not in each case, "forced environment reality programs" unsuitable for persons under 18 years of age. At the same time, it is necessary to define which programs are considered by REM to be "forced environment reality programs"; however, it does not mean just specifying a list of such programs broadcast so far. Also, ANEM suggested that the Instruction should be related to Article 68, paragraphs 2 and 6 of Law on electronic media, instead to the Rulebook on the protection of the rights of minors in the field of providing of media services, and gave concrete suggestions on how the Instruction should be formulated in that case. ANEM also indicated another option - to change the Rulebook in such a way as to determine that the categorization of the mentioned programs is conducted by the Regulatory body, but in accordance with criteria suggested by ANEM.

ANEM's Suggestions (available only in Serbian)

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