3️⃣ Whole of system approach
Take a whole of system perspective on supporting the media and information environment to make support more relevant, effective and sustainable.
In brief — Principle 3: Take a Whole-of-System Approach
Think ecosystem, not projects. Media support must connect laws, markets, technology, and governance so that funding, regulation, and policy reinforce one another rather than act in silos.
Coordinate across institutions. Align EU and Member State action — from the European Media Freedom Act to digital and competition policy — to ensure consistent, long-term impact.
Empower interdependence. Recognise that media are independent businesses accountable to audiences and staff, but also interlinked with Europe’s democratic, digital, and economic infrastructure.
Why it matters
Independent journalism does not exist in isolation. It depends on a wider system of laws, markets, technologies, and social norms that either enable or constrain it. A whole-of-system perspective means recognising that policy, funding, and regulation must reinforce one another across the information ecosystem — from competition law and digital governance to education, trade, and security. When these strands work in concert, the EU can leverage its full institutional capacity to create resilient, pluralistic, and economically viable media environments at home and abroad.
🏛️ Political level: aligning policy and purpose
At the political level, the European Parliament and Council have a unique opportunity to align Europe’s legislative and budget frameworks with this systemic view. Coherence between the European Media Freedom Act, competition and platform regulation, digital-transformation strategies, and external democracy support would allow the EU to treat media not as a niche sector but as part of Europe’s democratic and economic infrastructure. The challenge lies in bridging policy tracks and ensuring that budget negotiations, industrial policy, and rule-of-law agendas do not evolve in silos.
🇪🇺 European Commission: bridging mandates
Within the European Commission, DG CONNECT, DG JUST, DG INTPA, and the Secretariat-General each bring valuable expertise — from digital markets to legal protections and development cooperation. Yet these parallel mandates can fragment approaches, creating duplication and leaving gaps between content production, market regulation, and safety mechanisms. Building shared analytical frameworks and harmonised monitoring tools would allow services to design interventions that reinforce one another rather than compete for visibility or ownership.
EU Delegations: connecting global policy to local reality
For EU Delegations, the system challenge is equally practical. They must navigate complex local environments where market conditions, legal restrictions, and audience needs intersect. Delegations often have the clearest view of how these dynamics converge on the ground but face limits in mandate, staffing, and coordination. Their experience shows that effective media support cannot be separated from broader governance, digital, and economic reforms. Regular consultation and coordination with local actors and other donors remain critical to avoid overlap and ensure that interventions strengthen the entire ecosystem.
🌐 Member states: acting as one European system
Member State embassies and cultural institutes bring important assets — trusted local networks, linguistic reach, and small-grant flexibility. Yet without coordination, bilateral initiatives risk duplicating EU instruments or competing for partners.
Structured information-sharing, joint programming, and pooled mechanisms would allow Member States to operate as integral parts of a single European ecosystem, not as parallel donors.
📰 Media organisations: independent but interdependent
It is essential to remember that media organisations are businesses and employers with obligations to their audiences, staff, and partners, as well as to donors. Policies and funding instruments that ignore market logic, audience behaviour, or operational sustainability risk undermining the very independence they aim to protect. A systemic approach therefore views journalism as both a democratic safeguard and an economic actor — one that requires coherent regulation, predictable financing, and a level digital playing field to fulfil its public mission.
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