IRIS newsletter 2025-9
Publisher:
European Audiovisual Observatory
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E-mail: obs@obs.coe.int
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Executive Director: Pauline Durand-Vialle
Maja Cappello, Editor • Amélie Lacourt, Justine Radel, Sophie Valais, Diego de la Vega, Deputy Editors (European Audiovisual Observatory)
Documentation/Press Contact: Alison Hindhaugh
Tel.: +33 (0)3 90 21 60 10
E-mail: alison.hindhaugh@coe.int
Proofreading of machine translations:
Aurélie Courtinat • Paul Green • Udo Lücke • Marco Polo Sarl • Erwin Rohwer • Sonja Schmidt • Nathalie Sturlèse • Ulrike Welsch
Proofreading of original texts:
Amélie Lacourt, Alexandra Ross and Diego de la Vega • Linda Byrne • David Windsor • Aurélie Courtinat • Barbara Grokenberger
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Coordination: Cyril Chaboisseau, European Audiovisual Observatory
ISSN 2078-6158
© 2025 European Audiovisual Observatory, Strasbourg (France)
To promote inclusive language, we follow the guidelines of the Council of Europe.
Editorial
"Have you met Miss Norwood?" sounds like the title of a song by Rodgers and Hart, doesn't it? But the answer to that question can only be answered by a negative. Miss Norwood, or Tilly Norwood to be precise, is not a real person with whom you can shake hands, but just an AI-generated "actor". Is it the beginning of the end for serious thespians? Probably not, particularly in light of miss Norwood's "acting" skills. Nevertheless, this lovely AI-generated creature has caused a considerable stir in Hollywood and beyond.
Miss Norwood is just one of the most recent examples of AI's potential for disruption, but there are other examples closer to home. In Italy, the data protection authority has recently blocked ClothOff, a generative AI that creates false naked representations of real people, leading to the creation of sexually explicit content without the consent of those depicted. Access to such content also raises personality rights issues (same as Miss Norwood, by the way) but has also to be analysed in the wider context of the protection of minors online, which is a hotly debated topic nowadays. As an important example of this, the Luxembourgish media regulator has, for the first time, imposed a fine on the providers of an adult platform, for failing to implement adequate age verification measures in certain countries.
Meanwhile, influencers, while (still) mostly not AI-generated, remain at the heart of regulatory developments. The Spanish self-regulatory organisation Autocontrol has published a new code of conduct for influencers, while in central Europe, Slovenia’s new media law now sets out rules for content creators.
Last but not least, a Dutch court ordered Meta to give users the choice to view their feeds chronologically by default, reflecting a growing demand for transparency and user control in algorithmic environments.
Now, as regard Miss Norwood and the like, I'd rather keep on meeting Miss Streep and other great real-life actors, and I am sure you feel the same way!
Enjoy the read!
Maja Cappello, Editor
European Audiovisual Observatory
International
COUNCIL OF EUROPE
CoE: European Court of Human Rights
European Court of Human Rights: Violation of Big Tech’s free speech rights by Russia
The European Court of Human Rights’ judgment in the case, Google LLC and Others v. Russia, is the latest contribution to an emerging theme in its case-law: the right of online platforms to freedom of expression. In its judgment, delivered on 8 July 2025, the Court (Third Section) held that Russia had violated Google’s rights under Article 10 of the European Convention on Human Rights (ECHR) due to penalisations by the Russian courts for allowing the dissemination of certain content via its platforms and for refusing to allow the dissemination of other content. Background and facts In...
CoE: Parliamentary Assembly
PACE: Opinion on Draft Council of Europe Convention on the Co-Production of Audiovisual Works in the Form of Series
On 2 October 2025, the Parliamentary Assembly of the Council of Europe (PACE) adopted an Opinion on the Draft Council of Europe Convention on the Co-Production of Audiovisual Works in the Form of Series. PACE welcomed the finalisation of the draft Convention and commended its ambition to promote cross-border collaboration and cultural diversity, but considered that some issues required further consideration to enable the greatest number of member States to ratify the convention with confidence in its benefits, free from the fear of unintended consequences for their local ecosystems. The...
CoE: Parliamentary Assembly
PACE: resolutions on the protection of journalists in Ukraine and Gaza
On 1 October 2025, the Parliamentary Assembly of the Council of Europe (PACE) adopted a resolution entitled “Journalists matter: the need to step up efforts to liberate Ukrainian journalists held in captivity by the Russian Federation”. Since the start of the full-scale war of aggression in February 2022, over 800 crimes against media and media personnel have been documented as committed by the Russian Federation, including the killing of over one hundred media workers. Moreover, at least 26 media professionals and journalists are being unlawfully deprived of their liberty and held...
EUROPEAN UNION
EU: European Commission
European commission publishes 2025 edition of the European Media Industry Outlook
On 4 September, the European commission published the 2025 edition of the European Media Industry Outlook. The report explores demand and supply trends in the audiovisual, video games, extended reality and news media sectors with the aim to analyse their potential impact in the EU media markets. The report notes that even though linear services still holding slightly more than half of the revenues, the EU’s audiovisual market faces major shifts in viewing habits as YouTube rivals subscription video on-demand (SVoD) watch time. Non-EU players dominate SVoD, with EU providers only representing...
NATIONAL
Armenia
[AM] CTR sanctions broadcaster for transmitting films without the necessary rights and failing to ensure Armenian-language accessibility
On 26 September 2025, the Commission on Television and Radio of the Republic of Armenia (CTR) adopted Decision No. 114-A, imposing administrative fines on broadcaster Dzagedzor TV LLC for repeated infringements of the Law of the Republic of Armenia on Audiovisual Media (Audiovisual Media Law). The broadcaster was found to have transmitted foreign films without documents certifying the right (authorisation of the holder of copyright or related rights) to broadcast them and to have failed to accompany foreign-language films with an Armenian translation, as required by the Audiovisual Media Law. During...
Germany
[DE] Commission on Concentration in the Media authorises RTL's takeover of Sky
At its meeting on 9 September, the Kommission zur Ermittlung der Konzentration im Medienbereich (Commission on Concentration in the Media - KEK) approved, among other things, the acquisition of all shares in Sky Deutschland Fernsehen GmbH & Co. KG (Sky) and NBC Universal Global Networks Deutschland GmbH (NBCU) by RTL Deutschland GmbH (RTL). Although the takeover would give RTL a television audience share of around 23% in Germany and have further concentration-related consequences for related markets such as the video-on-demand, advertising and rights markets, the KEK did not identify any serious...
[DE] Constitutional complaint against new rbb state treaty rejected
In its decision of 23 July 2025, which was published on 21 August 2025, the First Senate of the Bundesverfassungsgericht (Federal Constitutional Court) rejected a constitutional complaint filed by Rundfunk Berlin-Brandenburg (rbb) concerning the reformed rbb-Staatsvertrag (rbb state treaty). The challenged provisions of the treaty concern the regionality and organisation of rbb as a multi-state broadcaster under federal responsibility. rbb is a public broadcaster jointly established by the federal states of Berlin and Brandenburg. It complained to the Federal Constitutional Court that its...
[DE]Rhineland-Palatinate state media law amended
On 11 September 2025, the Landtag (state parliament) of Rhineland-Palatinate debated the amendment to the Landesmediengesetz (state media law) at first reading. The bill was introduced by the three governing parliamentary groups of the SPD, Alliance 90/The Greens and the FDP as well as the CDU as the opposition group. It aims to comprehensively modernise the state media law, strengthen the diversity of Rhineland-Palatinate’s media landscape and promote editorial independence. Under the bill, press publishers will have greater opportunities to own shares in broadcasting companies, media...
Spain
[ES] New code of conduct for influencers by Autocontrol
Autocontrol, the Spanish organisation that promotes self-regulation in the advertising industry, has made certain amendments to the code of conduct on advertising through influencers, which came into force in October 2025. This update is part of the commitment of Law No.13/2022, of 7 July, on Audiovisual Communication (LGCA), to self-regulation and co-regulation codes, and continues a long tradition of self-regulation in the advertising sector in Spain. Although the Code of Conduct on advertising through influencers follows the lines of the previous 2021 code, which it replaces, Autocontrol...
France
[FR] Conseil d’Etat upholds €50 000 fine imposed on CNews for misrepresenting a survey on insecurity in France
The company responsible for the CNews television channel is seeking the annulment of a decision by the Autorité de régulation de la communication audiovisuelle et numérique (the French audiovisual regulator – ARCOM). Under the decision, the company was fined €50 000 following a sequence lasting approximately three minutes, broadcast on 26 September 2022 during the programme Face à l'info, relating to the results of an online survey of the world’s safest cities carried out by the Numbéo website, which publishes summaries based on data supplied...
[FR] Online platforms: connection threshold triggering the obligation to temporarily retain illegal content
Decree 2025-768 of 4 August 2025, issued for the application of Article VI of Law No. 2004-575 of 21 June 2004 on confidence in the digital economy, as amended by Article 48 of the "SREN" Law 2024-449 of 21 May 2024, repeals Decree No. 2022-32 of 14 January 2022 on the setting of a connection threshold above which online platform operators must contribute to the fight against the public dissemination of illegal content. The new decree confirms the number of connections (10 million unique visitors per month from French territory, calculated on the basis of the last calendar year), above...
[FR] Report of the parliamentary committee of enquiry into the psychological effects of TikTok
A report on the psychological effects of TikTok on minors, written by the National Assembly’s committee of enquiry, has been published. In its report, the committee, chaired by Arthur Delaporte with Laure Miller as rapporteur, expresses concern about the harmful effects of the Chinese social network on the mental health of minors, noting that content moderation does not meet the requirements of the DSA. In the light of these findings, the rapporteurs put forward 43 proposals, including banning under-15s from social networks (excluding messaging services), introducing a digital curfew from...
Georgia
[GE] National regulator issues warning to broadcasters
On 9 October 2025, the Communications Commission (ComCom), the national media regulator of Georgia, reported that it had issued a written warning to the television broadcasters Formula and Formula Multimedia for violating the Law on Broadcasting and ordered them to cease receiving funding from a foreign legal entity. ComCom found that, in the second quarter of 2025, Formula Multimedia LLC had received 1 336 675 Georgian lari (GEL), or about €425 000, from a legal entity registered in Cyprus, Infinity CV Group CY Ltd. In turn, Formula Multimedia had paid GEL 463 000 (€147 000)...
Italy
[IT] The Italian Data Protection Authority blocks ClothOff
On 1 October 2025, the Italian Garante per la Protezione dei Dati Personali (Data Protection Authority - the Authority) adopted an urgent order against the company AI/Robotics Venture Strategy 3 Ltd., based in the British Virgin Islands, declaring unlawful the processing of personal data that the company carried out through its website ClothOff and immediately limiting the processing of personal data for Italian users. ClothOff offers a generative AI service that allows users to digitally remove clothing from photos depicting people: users upload images of people and receive their fake nude...
Luxembourg
[LU] LiveJasmin service providers fined €20,000
The decision issued on 7 August 2025 by the Luxembourg Independent Audiovisual Authority (ALIA) follows a self-referral concerning the LiveJasmin video-sharing platform. In the course of its investigation, the ALIA assessed the compliance of the age-verification measures implemented by the providers JWS Americas S.à r.l. and JWS International S.à r.l. with Article 28 septies of the amended Law of 27 July 1991 on Electronic Media, transposing article 28 ter of the Directive on audiovisual media services. LiveJasmin offers its users access to sexually explicit content reserved for...
Moldova
[MD] Sweeping changes in the Audiovisual Code
A 46-page-long set of sweeping amendments to the Audiovisual Media Services Code (AVMSC) of the Republic of Moldova, previously adopted by the national parliament, was officially published and came into force (with some exceptions) on 21 August 2025. Among the definitions that were amended, is, once again (see IRIS 2023-9:1/14) the definition of disinformation. It now closely follows the definition provided by the 2018 EU Action Plan against Disinformation. A new definition – “hate speech” – now follows and expands the wording of the Recommendation of the Committee of...
Netherlands
[NL] Dutch court orders Meta to ensure Dutch users’ right to set a chronological feed as their default
On 2 October 2025, the District Court of Amsterdam issued a ruling in the summary proceedings (kort geding) brought against Meta by digital rights organisation Bits of Freedom. The court found that Meta had violated the Digital Services Act (DSA) by failing to preserve the user’s choice of a chronological feed and ordered it to ensure that Dutch users could retain a non-algorithmic recommender system when reopening the app or website or navigating to other sections thereof. Under the DSA, all providers of online platforms must ensure the transparency of their recommender systems...
Slovenia
[SI] New Law on Media adopted by Parliament
On 2 September 2025, the Slovenian Assembly adopted the long-awaited Law on Media. A draft media law was published for consultation on 12 December 2023 (see IRIS 2024-2:1/9). Following this, the hearing of the draft in the National Assembly was planned to take place in September or October 2024 (according to the European Commission's 2024 Rule of Law Report on Slovenia). The government approved the new Law on Media on 31 December 2024 and submitted it to the National Assembly for consideration. The proposal was removed from its final reading in Parliament in May 2025 while the legislative...
Ukraine
[UA] Decision of the media regulator about hate speech against LGBTIQ+
The Law of Ukraine “On the Media” contains a list of content restrictions in the media. These include the prohibition of disseminating statements that incite hatred, hostility, discrimination, and oppression of individuals or groups “based on ethnic or social origin, citizenship, nationality, race, religion and beliefs, age, gender, sexual orientation, gender identity, disability, or other characteristics.” The dissemination of such statements is considered a significant and serious violation that requires a response from the National Council of Ukraine on Television and...
