✅ Consolidated Checklist

EIB, EIF, InvestEU

Purpose

To integrate information integrity, transparency, and media viability into EU-backed investment and development finance operations. This checklist helps financial institutions align with the OECD Principles, reduce governance risk, and support the watchdog function of journalism as part of sustainable development.


🧭 1. Strategic Alignment

Area
Key Questions
Action Points

Policy Coherence

Do investment and advisory operations reference the OECD Principles or the EU Media Freedom framework?

Integrate references to information integrity and media viability within EIB/EIF sustainability and governance policies.

Democracy and Risk Management

Are governance and corruption-risk indicators linked to access to information and media oversight?

Include “public transparency and watchdog coverage” as part of environmental, social, and governance (ESG) due-diligence checklists.

Cross-sector collaboration

Are partnerships established with civil-society and media networks to strengthen accountability in high-risk sectors?

Convene a Media Financing Task Force with EU institutions, philanthropies, and watchdogs to share risk data and lessons learned.


💰 2. Media as SMEs

Area
Key Questions
Action Points

Eligibility

Are independent media explicitly recognised as SMEs eligible for EIB/EIF or InvestEU support?

Amend SME eligibility criteria to include independent, public-interest, and community media organisations.

Access to Finance

Do credit or equity lines reach small media outlets and start-ups?

Provide dedicated windows for media enterprises under entrepreneurship and innovation programmes.

Capacity Support

Do financial intermediaries understand the media business model?

Pair financial products with technical assistance and mentoring on governance, digital resilience, and compliance.


🧩 3. Blended Finance & Investment Instruments

Area
Key Questions
Action Points

Instrument Design

Are blended-finance products available for high-impact, low-return sectors like public-interest media?

Combine grants, concessional loans, and guarantees under an EU Media Viability Facility implemented via EIF.

Safeguards

Are editorial-independence and human-rights clauses embedded in finance contracts?

Add side-letters prohibiting donor or investor interference in content, staffing, or governance.

Impact Metrics

Are success indicators limited to financial returns?

Include governance, transparency, and pluralism metrics in investment impact reporting.


🌐 4. Digital Infrastructure with Safeguards

Area
Key Questions
Action Points

Due Diligence

Do digital-infrastructure loans or guarantees include information-integrity assessments?

Require human-rights impact and transparency reviews before approval.

Public Value

Do digital projects strengthen openness and interoperability?

Prioritise open-source and public-interest technologies that enable media access and citizen oversight.

Cybersecurity

Are small media outlets supported in secure digital transformation?

Fund shared cloud, encryption, and cybersecurity infrastructure under digital-investment pillars.


🔍 5. Anti-Corruption & Illicit Financial Flows (IFFs)

Area
Key Questions
Action Points

Transparency

Are anti-IFF safeguards linked to the role of independent oversight?

Recognise journalism and civic data platforms as part of EU anti-corruption architecture.

Evidence & Learning

Is the contribution of investigative reporting to asset recovery tracked?

Commission studies quantifying journalism’s role in tax recovery, procurement transparency, and governance reforms.

Collaboration

Are partnerships established with watchdog networks?

Support cross-border investigative collaborations through technical assistance or guarantees.


🧮 6. Monitoring, Evaluation & Reporting

Area
Key Questions
Action Points

Impact Reporting

Do investment reports capture non-financial outcomes?

Add information-integrity indicators (e.g., improved transparency, public-interest coverage) to EIB/EIF annual reports.

Transparency

Can civil society access anonymised data on funded media projects?

Publish aggregated and anonymised portfolio data to demonstrate governance impact.

Learning Loops

Are lessons shared across EU instruments?

Establish an internal knowledge hub on media and governance finance within the EIB/EIF.


🛡️ 7. Safeguards & Risk Management

Area
Key Questions
Action Points

Editorial Firewalls

How is independence protected contractually?

Require explicit no-interference clauses and grievance procedures.

Political Sensitivity

Could association with EU finance endanger partners?

Allow for anonymised reporting and visibility waivers.

Proportionality

Are compliance requirements scaled to partner size and capacity?

Apply proportional due-diligence thresholds and flexible repayment terms for small outlets.


📈 8. Coordination & Partnerships

Area
Key Questions
Action Points

Internal Coordination

Are EIB, EIF, and InvestEU teams aligned on governance and democracy safeguards?

Create an inter-service coordination node linking DG INTPA, DG NEAR, and EIB Group policy units.

External Partnerships

Are philanthropic or impact-investor partnerships leveraged?

Mobilise co-investment via GFMD, IFPIM, and other donor platforms.

Whole-of-System Coherence

Does support complement EU Delegation and Member State programmes?

Align financing initiatives with EU Delegations’ governance and anti-corruption portfolios.


⚙️ 9. Key Concepts

  • Information Integrity: Transparency and accountability safeguards embedded in all finance operations.

  • Media Viability Facility: Blended-finance instrument combining grants, loans, and technical assistance.

  • Editorial Independence Clause: Contractual provision ensuring no financial or political interference.

  • Anonymised Impact Data: Aggregated reporting that demonstrates governance value while protecting partners.

  • Public-Interest Tech: Open, secure digital infrastructure accessible to civil society and independent media.


🧾 Summary

✅ Embed information integrity and editorial independence as standard EIB/EIF safeguards. ✅ Treat independent media as SMEs and eligible impact-investment partners. ✅ Use blended-finance tools to de-risk journalism and attract co-funding. ✅ Ensure digital and anti-corruption investments include media oversight components. ✅ Monitor results through governance and transparency indicators, not just ROI.

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