Armenia

[AM] Media coverage involving minors – regulatory assessment and ethical self-regulation

IRIS 2026-1:1/8

Anna Hovhanisyan

Commission on TV and Radio of Armenia

On 4 December 2025, the Commission on Television and Radio of the Republic of Armenia (CTR) adopted a decision to discontinue an administrative proceeding against Shark LLC, the broadcaster of the television programme 5th Channel, in connection with the coverage of a tragic event involving children. The issue at stake was whether the manner in which minors were shown in the coverage of a child’s death complied with the legal safeguards for the protection of children in audiovisual media.

The case followed an exercise involving the monitoring of a programme broadcast on 5 November 2025, which reported on a tragic incident involving a family with several children, including the death of one of them. During the report, the faces of the children were visible, and a general verbal reference was made to the children having "apparent health problems".

The CTR identified potential indications of a breach of Article 9(3) of the Law of the Republic of Armenia on Audiovisual Media (Audiovisual Media Law), which restricts the broadcasting of content that may harm the health, mental or physical development, and upbringing of minors. Reference was also made to CTR Decision No. 73-N of 28 June 2024, which establishes criteria for determining audiovisual programmes potentially harmful to minors. An administrative procedure was initiated, and the broadcaster was invited to submit explanations.

The broadcaster submitted that the report had been produced exclusively in the public interest, aimed at drawing attention to the severe social conditions in which the children were living, including circumstances suggesting that the tragic death of one child may have occurred in the presence of another minor. It emphasised that filming had taken place in the presence of the children’s parent, who had given verbal consent for the interviews and recording.

According to the broadcaster, no identifying personal data were disclosed, and additional measures were taken to minimise the risk of identification. It further argued that the presenter’s statement regarding the children’s health was general and descriptive in nature, did not contain sensitive medical data, and was based on the journalist’s direct observations of the living conditions at the scene. The broadcaster also referred to its compliance with the internal code of ethics.

In its assessment, the CTR reaffirmed the importance of editorial independence and freedom of expression in a democratic society, while stressing that the protection of minors and their best interests constitutes a key element of the public interest pursued by audiovisual regulation.

Although the CTR noted that the minors’ faces were visible during the broadcast, it accepted that the verbal consent provided by the parent could be regarded as a lawful basis for filming and interviewing the children in the specific circumstances of the case.

The CTR further concluded that the report's content did not include elements such as violence or horror, nor did it involve the disclosure of special categories of personal data, including detailed health information. As such, the programme did not fall within the category of content subject to time-of-day restrictions under Article 9(3) of the Audiovisual Media Law.

However, a decisive factor in the CTR’s reasoning was that the issues raised primarily concerned professional ethics rather than regulatory compliance. The broadcaster’s internal ethics committee reviewed the matter and adopted internal guidance aimed at reinforcing sensitivity when reporting on minors. In addition, reflecting on the case, the Armenian Media Ethics Observatory issued a public statement reminding media outlets of the need for particular care when reporting on children and other vulnerable groups, and encouraging compliance with national ethical codes and international standards, including UNICEF guidelines on reporting about children.

The CTR welcomed the broadcaster’s initiative to seek further guidance from the Human Rights Defender, viewing this step as consistent with international best practices on media self-regulation.

Taking into account the public-interest nature of the reporting, the absence of evidence of harm to the minors, and the role played by ethical self-regulatory mechanisms, the CTR concluded that there was no administrative offence under the Audiovisual Media Law. In particular, the broadcaster’s internal ethics committee reviewed the report. It acknowledged that, while certain elements could be considered sensitive from an ethical perspective, the coverage had been prepared without intent to breach regulatory requirements and in pursuit of accurate and socially relevant reporting. As a result of this review, internal guidance was issued to reinforce greater sensitivity in future reporting involving minors, technical measures were applied to the problematic footage, and the audio segments featuring the children were edited. Accordingly, the administrative proceeding was discontinued.

The decision illustrates the CTR’s approach of clearly distinguishing between regulatory enforcement and issues better addressed through ethical self-regulation while reaffirming that the best interests of the child must remain a primary consideration in media coverage.