✅ Whole of System Checklist

Purpose

To ensure that EU-funded media and information-integrity programmes strengthen the entire information ecosystem—linking regulation, markets, safety, technology, and governance—so that interventions are coherent, sustainable, and mutually reinforcing. Apply this checklist during programme design, inter-service coordination, and evaluation.

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🧭 1. Strategic Coherence

Area	Key Questions	Action Points
Legislative alignment	Are media freedom, competition, and digital-market agendas reinforcing each other?	Map overlaps between EMFA, DSA, DMA, anti-SLAPP, and rule-of-law measures; coordinate briefings across committees.
Cross-DG coherence	Are DG CONNECT, DG JUST, DG INTPA, and EEAS funding or regulating in silos?	Establish inter-service taskforces and shared MEL frameworks to align calls and reduce duplication.
External-internal linkages	Are EU internal and external actions consistent (e.g., Creative Europe vs Global Europe)?	Create joint briefings between DG INTPA and DG CONNECT; share evaluation data on ecosystem impact.
Political framing	Is media treated as democratic and economic infrastructure, not just as a cultural add-on?	Integrate “information ecosystem” into MFF, Global Gateway, and Democracy Shield programming.

💡 Tip: Frame journalism as public infrastructure for democratic resilience and market transparency.

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🔄 2. Programme Integration

Dimension	Minimum Standard	Enhanced Practice
Design	Include context-specific media-ecosystem analysis in every ToR or CfP.	Use joint studies with local universities or observatories; build programmes on shared diagnostics.
Funding logic	Avoid isolated “training-only” projects.	Combine safety, legal resilience, distribution, and revenue diversification in one portfolio.
Inter-sector links	Acknowledge media’s role across governance, security, and digitalisation.	Embed watchdog journalism into Global Gateway and infrastructure oversight mechanisms.
Platform dependency	Do not entrench reliance on dominant tech platforms.	Support open, interoperable, and European-standard infrastructure (secure cloud, analytics, archives).

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🧩 3. Coordination & Evidence

Area	Good Practice	Enhanced Practice
Knowledge sharing	Maintain a central repository of assessments and evaluations.	Align DGs and Delegations on shared “evidence grids” and update annually.
Donor collaboration	Participate in local or regional donor huddles.	Formalise coordination compacts among EU Delegations and Member States to prevent overlap.
Learning loop	Capture lessons beyond outputs.	Use ecosystem indicators – pluralism, safety, diversity, audience trust – in all MEL frameworks.

💡 Tip: Coordination is not an add-on—it is a systemic safeguard against fragmentation and duplication.

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🌱 4. Inclusion & Diversity

Focus	Baseline Requirement	Improved Practice
Representation	Ensure participation of women, youth, and regional or minority-language media.	Introduce diversity benchmarks in tenders; reward projects with inclusive consortium structures.
Local ecosystems	Engage beyond capital-based outlets.	Map and support community media, rural broadcasters, and cross-border regional networks.

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⚙️ 5. Market & Infrastructure Resilience

Domain	Good Practice	Enhanced Practice
Financial viability	Encourage plural revenue models.	Support blended-finance pilots under InvestEU / EIB / EIF with independence clauses.
Digital transition	Integrate cybersecurity and data-governance standards.	Fund shared cloud and AI tools governed by public-interest standards (e.g., Journalism Cloud Alliance).
Accountability	Tie infrastructure spending to transparency obligations.	Link Global Gateway projects with investigative oversight and civic-tech participation.

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💬 Field Voices

“The whole-system approach means engaging governments, agencies, civil society, and media together. Without that dialogue, we just fund isolated projects.” — Development Agency representative

“Even small funding lines can have big ripple effects if they are linked across governance, digital, and infrastructure portfolios.” — EU Delegation official, Asia

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💡 Reminder

“Whole-of-system” means every intervention—legislative, financial, or diplomatic—affects the same information ecosystem. Think horizontally: coordination, inclusion, and infrastructure reform are security investments, not administrative luxuries.