North Macedonia

[MK] Recent Legal Developments in Influencer Registration in North Macedonia

IRIS 2026-2:1/12

Vladimir Gjorgjieski

Agency for Audio and Audiovisual Media Services (AVMU)

Following the alignment of the national audiovisual media regulatory framework with European Union law, in particular the Audiovisual Media Services Directive (AVMSD)(EU) 2018/1808, North Macedonia introduced further legislative and regulatory measures aimed at adapting audiovisual media regulation to the digital environment and to new forms of audiovisual content creation and distribution carried out via online platforms.

This alignment was implemented within the framework of the Law amending the Law on Audio and Audiovisual Media Services (Official Gazette of the Republic of North Macedonia No. 154/23) which provides the legal basis for extending audiovisual media rules to natural persons providing audiovisual media services on demand.

Building on this legislative framework, a dedicated by-law regulating the registration of influencers came into force in July 2025, establishing 31 December 2025 as the deadline for compliance and registration. Compliance with the registration obligation and the applicable rules is monitored and enforced in accordance with the Law on Audio and Audiovisual Media Services.

The preparation of the by-law was preceded by a consultative process involving a broader group of influencers, alongside other relevant stakeholders operating in the audiovisual and digital content ecosystem. This process was intended to ensure that the regulatory text reflected the practical realities of content creation and dissemination on social media platforms.

The draft by-law was published for public consultation, during which all interested parties were allowed to submit comments, observations and proposals. Contributions received during the consultation period were reviewed as part of the regulatory process. They informed the finalisation of the by-law, in accordance with applicable procedural requirements governing secondary legislation.

Under the new regulatory framework, influencers may be legally qualified as natural persons providing on-demand audiovisual media services, where predefined conditions are cumulatively fulfilled. This qualification reflects the extension of existing audiovisual media concepts to the online environment and applies to individuals whose activities go beyond purely private or incidental content sharing.

The framework applies to influencers who disseminate audiovisual content via online platforms and who engage in economic activity related to such content. The regulatory approach is platform-neutral and applies irrespective of the specific social media or video-sharing platform used for content distribution.

The by-law establishes six cumulative criteria for determining whether an influencer falls within its scope.

First, the audiovisual content must be provided through electronic communications networks, including platforms for sharing audiovisual content.

Second, the activity must constitute an economic service, meaning that it represents an economic activity carried out in the market.

Third, the principal purpose of the service, or a distinct part thereof, must be the provision of audiovisual programmes intended to inform, entertain or educate, with the influencer exercising editorial responsibility over the selection and organisation of the content.

Fourth, the influencer must have published at least 24 audiovisual content items within the previous 12-month period, demonstrating regular activity over time.

Fifth, the service must be intended for the general public, which, for the by-law, is presumed where the influencer’s profile reaches at least 10 000 followers or subscribers.

Sixth, the service must enable access to audiovisual content on an on-demand basis, typically through an organised catalogue of content.

Only influencers who cumulatively meet all six criteria are subject to the registration obligation.

Registered influencers are entered into a public register maintained by the regulatory authority. Registration is carried out per individual influencer, irrespective of the number of platforms on which audiovisual content is distributed, with all relevant platforms declared at the time of registration.

The register serves as a transparency and oversight mechanism, enabling the regulatory authority to monitor compliance with applicable audiovisual media rules and to identify providers falling within the regulatory scope.

Registered influencers are subject to obligations deriving from the Law on Audio and Audiovisual Media Services and the corresponding secondary legislation.

These obligations are not limited to transparency in audiovisual commercial communications. Influencers must clearly identify advertising, sponsorship and product placement, regardless of the form of remuneration or economic benefit involved.

In addition, the framework applies rules concerning the protection of minors, including safeguards against content that may impair their physical, mental or moral development. Registered influencers are also subject to professional standards applicable to audiovisual media services, consumer protection principles and other administrative duties prescribed by law.

Non-commercial audiovisual content disseminated by influencers remains outside the scope of the regulatory framework.

The adoption of the by-law on influencer registration represents a further step in the national implementation of the AVMSD. By defining clear eligibility criteria, introducing a registration mechanism and applying existing audiovisual media obligations to influencers engaged in economic activity, the framework provides legal clarity regarding the regulatory treatment of influencers operating in the digital audiovisual environment.