Despite the European Commission's recommendation 1 to Member States to approve the opening of accession negotiations with Bosnia and Herzegovina (BiH) and the adoption of the Reform Agenda, 2025 did not bring substantial progress in legislative and institutional reforms related to freedom of expression and media freedoms. Key challenges remained the same as in previous years: slow and insufficiently transparent work on regulations, a lack of political and institutional consensus, and the fragmentation of competences that makes it difficult to adopt and implement comprehensive solutions. This is particularly evident in the long-standing stalemate surrounding the law on the public broadcasting system and the law on electronic media and communications.

 

At the same time, the European regulatory framework in the digital sphere is rapidly changing, while BiH continues to lag behind in aligning with EU standards. The legislative framework in the area of media and digital services only partially reflects current reform trends, while alignment with the 2018 Audiovisual Media Services Directive and new requirements, including the European Media Freedom Act, remains insufficient. At the same time, initiatives that carry the risk of further narrowing the space for freedom of expression emerged in 2025, such as announcements of measures aimed at “combating disinformation”, especially in the Republika Srpska.

 

The findings of this study confirm the assessments of the 2025 Progress Report of the European Commission: no progress has been reported in the area of freedom of expression and media, while BiH remains at an early stage of preparedness, with troubling signs of deterioration. This is reflected in the repetition of the same recommendations year after year, from the adoption of the law on transparency of media ownership and the finalization of the law on electronic communications and electronic media, to the stabilization of the public broadcasting system, ensuring financial sustainability and political independence of public broadcasters, and strengthening the protection of journalists and media staff.

 

The aim of this report is to provide an overview of key legislative, institutional and policy developments in the area of media freedoms in 2025, analyse their impact on the work of the media and the position of journalists, and identify the main challenges and potential directions for action. The report was prepared on the basis of primary and secondary data, through an analysis of existing policies in BiH, with data collected from competent institutions and through ten interviews with relevant interviewees, including legal experts, media representatives, and representatives of institutions.

 

The report represents the first monitoring study in a three-part series of reports dedicated to monitoring legislative and institutional reforms in the area of freedom of expression and media freedom. It is based on the first report, “Protection of Media Freedoms in Bosnia and Herzegovina: Steps towards European Integration”, issued in January 2025, which provided a comprehensive overview of the relevant legislative framework, as well as the degree of its compliance with international standards and standards of the European Union.

 

Compared to the first report, the monitoring of progress focuses on changes, new initiatives and the practical effects of the legislative and institutional processes that took place during 2025.

 

The first part of this report lays out legislative changes in the previous year, focusing on criminal legislation and laws governing freedom of access to information. It also analyses the proposed and implemented measures in the process leading to the adoption of laws in the area of communications and electronic media, as well as the regulations and decisions of the Communications Regulatory Agency, the Law on Transparency of Ownership, and the Law on the Public Broadcasting System of BiH.

 

The second part of the report is addresses new challenges in the area of media freedoms, including regressive initiatives and measures such as the adoption of a law on “foreign agents” in the RS, which was later repealed, the announcement of the establishment of a disinformation department in the RS, and concrete cases of legal harassment of journalists in BiH. This part also analyses the dynamics of adoption of media laws at different levels, including the process of drafting the Law on Media in the Republika Srpska, as well as progress in the area of institutional protection of journalists.