MCCM
RESILIENCE
OUR MEDIA
Key systemic risks in Albania’s regulation of digital platforms and media in the digital environment are: non-transparent decision-making processes, high media concentration, and problematic policy approaches to addressing information integrity issues.
A government-centralised digital policymaking and institutional ecosystem has long been a closed system in Albania, facing criticism from civic actors for its lack of multistakeholder inclusion in policy design and the resulting lack of accountability.
Limitations in addressing critical digital issues – such as harmful content on video-sharing platforms, electoral campaigning, AI responsibility, and online privacy violations – reveal significant governance gaps. These challenges are compounded by political interference in the work of independent regulatory bodies, lack of effective democratic checks and balances, jurisdictional limitations, the context of a small digital ‘market’, and insufficient institutional capacity.
Other risks related to conflicting priorities, like child protection (e.g., the TikTok ban) and carte blanche use of national security exemption, are increasingly pursued at the expense of other fundamental rights, including freedom of expression and political participation. Sudden policy shifts raise concerns over principles underpinning the rule of law such as legal certainty and foreseeability.
The Risk Assessment is based on an analysis of legislative and policy monitoring processes conducted from December 2024 to May 2025.
During the monitoring, risks related to personal data misuse—such as surveillance, profiling, and potential law enforcement abuses—were identified as a serious concern, despite the existence of personal data protection legislation. In the meantime, the new Personal Data Protection Law entered into force in early 2025, leaving its consistent, rights-compliant implementation as the primary remaining challenge.
In this context, robust rights and rule-of-law safeguards, and multistakeholder governance, accountability, and enforcement are essential to ensure that regulatory and policy instruments in this domain bolster freedom of expression and access to information in the digital ecosystem.
Identified legislative risks reveal tensions between regulatory reality (most notably, the intransparent process of decision making) and the regulatory “rush” to ensure alignment with the EU acquis in this area. The Risk Assessment points out that the speed of legislative reform sometimes comes at the expense of human rights and the rule of law, exposing persistent challenges in aligning with EU standards.
These are key messages of the publication Albania: Regulating Digital Platforms and Media in the Digital Environment – Risk Assessment [in Albanian] by SEENPM, produced within a UNESCO project “Building Trust in Media in South East Europe: Support to Journalism as a Public Good”, financed by the EU.
The publication outlines key priorities where immediate action by stakeholders is required in Albania’s digital platform regulation and media landscape. Detailed recommendations are provided later in the text.
- Strengthen institutional capacity across the system – Invest in institutional capacities by ensuring adequate resources and targeted training in digital platform regulation, digital media governance, AI regulation, privacy protection, and the integrity of electoral processes, as an immediate priority for government institutions, independent regulators, law enforcement, and the judiciary.
- Enable meaningful civic participation in policy development and governance – Ensure the full participation of various stakeholders in the policy processes. In parallel, equip civil society organisations, media outlets, and fact-checking actors with the resources and capacities needed to effectively engage in, monitor, and contribute to digital and platform governance processes and structures.
- Ensure transparency to anchor trust-based engagement – As an immediate step, require the government to disclose impact assessments, underlying data, and the rationale for regulatory decisions, enabling open and informed consultations, trust-driven multistakeholder participation, and evidence-based policymaking.
The publication is part of a broader series of studies covering Albania, Bosnia and Herzegovina, Montenegro, North Macedonia, Serbia, and Türkiye.
The integral – regional collection publication [in English]: Regulating Digital Platforms and Media in the Digital Environment: Risk Assessments
Fragile Systems, High Stakes: Risks in Albania’s Digital Platform Regulation
A key insight emerging from the assessment is that context matters decisively. In settings affected by institutional fragility and distorted media landscapes – ranging from high levels of media concentration, related media pluralism issues, to outright platform restrictions – rushed and misguided regulation can further erode the integrity of the digital information space.
Albania faces the dual challenge of aligning with EU digital and media regulations while contending with serious internal governance weaknesses. First, noted risks are particularly acute in the design and implementation of digital platform regulation, focusing on content control rather than governance processes. Second, centralised power, weak institutional independence, limited capacity, and political interference threaten both effective enforcement and the credibility of the EU accession process.
The government’s strong focus on AI and platform regulation – more pronounced than in other regional target countries – appears to divert attention from pressing issues such as media ownership concentration, clampdowns, electoral integrity, and broader political dynamics. Without careful assessment of systemic risks, platform and media regulation could be misapplied or politically misused, as previous practices already suggest.
Success hinges on Albania’s willingness and ability to open digital policymaking to diverse stakeholders, integrate human rights safeguards into technological policies, reconcile rights protection with enforcement, and balance societal and technological risks.
Governing the Digital Space: Rights, Oversight, and Civic Resilience
To tackle these interconnected risks and strengthen media freedom, digital rights, and democratic governance, the following key recommendations are proposed:
▪ EU alignment imperative – Gradually harmonise the EU digital acquis (DSA, DMA, EMFA, AI Act) and comply with international standards, including UNESCO governance guidelines, UN AI principles, and ratified conventions (ECHR, ICCPR), backed by effective transposition and enforcement.
▪ Rights-respecting security – In particular ensure that adequate legislative and institutional human rights safeguards secure legal clarity, proportionality, and avoidance of vague or overly broad provisions.
▪ Independent oversight is essential – Strengthen or create politically and commercially independent bodies overseeing AI, platforms, privacy, disinformation, digital elections, competition, and media, cooperating with civil society for accountability and redress.
▪ Multistakeholder digital governance – Formalise forums including civil society, academia, experts, journalists, and watchdogs to guide regulatory design and implementation, e.g., trusted flaggers, certified researchers, and dispute mechanisms under the DSA.
▪ Media freedom and pluralism – Guarantee regulator and public broadcaster independence, transparent state funding, anti-monopoly enforcement, and public disclosure of media ownership.
▪ Protect civic space online – Legally safeguard against misuse of digital surveillance and censorship, defend freedoms of expression, privacy, assembly, and association, and support civic initiatives advancing digital rights, online safety and information integrity.
▪ Cross-border enforcement – Enhance cooperation with EU regulators and platforms to address challenges posed by foreign-based platforms affecting local users in the pre-accession period.
▪ Media and Information Literacy for resilience – Develop a national MIL strategy, per UNESCO guidelines, enabling all citizens—especially vulnerable groups, women, and girls—to critically engage with content, technologies, and resist manipulation and disinformation.
Mapping Risk in Digital Governance: A Tailored Methodology
The assessment is based on a bespoke, replicable risk matrix, structured around three risk groups:
- Misalignment with international standards of human rights protection and rule of law;
- External and internal risks: external risks stem from the broader context (e.g. political climate or potential misuse), while internal risks arise from the regulation itself, including legal gaps, weak or missing redress mechanisms, and loopholes;
- Legislative process factors refer to risks related to how a law or policy is developed, including transparency, stakeholder and expert involvement, and potential political influence during drafting and adoption.
Albania: Regulating Digital Platforms and Media in the Digital Environment – Risk Assessment [in Albanian]
The integral – regional collection publication [in English]: Regulating Digital Platforms and Media in the Digital Environment: Risk Assessments
This article was produced within the UNESCO project “Building Trust in Media in South East Europe: Support to Journalism as a Public Good”, financed by the EU.
The designations employed and the presentation of material throughout this article do not imply the expression of any opinion whatsoever on the part of UNESCO or the European Union concerning the legal status of any country, territory, city or area or its authorities, or concerning the delimitation of its frontiers or boundaries.
The authors are responsible for the choice and presentation of the facts contained in this article and for the opinions expressed therein, which are not necessarily those of UNESCO or the European Union and do not commit the Organization.
