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Regulation of Freedom of Information in the European Union

December 2025

   Regulation of Freedom of Information in the European Union

EU Media Freedom Regulation (EMFA) & Getty Images v. Stability AI
1. EU Media Freedom Regulation – Regulation (EU) 2024/1083
The European Union has adopted a comprehensive regulation designed to ensure media
freedom, editorial independence, ownership transparency, and pluralism across all Member
States. The regulation addresses vulnerabilities that have emerged in the digital era and
requires:
Key Provisions:
● Full transparency regarding ownership structure, ultimate beneficiaries, and
state-sponsored advertising data.
● Strengthening editorial independence through internal mechanisms, codes of
ethics, and conflict-of-interest prevention procedures.
● Special rights for media service providers on large platforms, including a right to
receive prior justification before journalistic content is removed or its visibility
restricted.
● A requirement for human oversight of AI-generated journalistic content.
● Establishment of the European Board for Media Services, a new regulatory body
intended to reinforce cooperation and enforcement.

Implementation in Greece:
On 25 November 2025, a comprehensive implementing law was enacted:
● Definition of enforcement authorities (ESR, the Secretariat for Communication, and
others).

● Obligation for media organisations to publish transparent information on their
websites.
● Obligation for public bodies to publish government advertising expenditures.
● Enforcement powers including warnings and fines (€500–€10,000).

Overall Significance:
The regulation marks a major milestone in Europe:
● Mandating a new standard of media transparency.
● Creating meaningful protections against political interference and arbitrary
restrictions of journalistic content by digital platforms.
● Refining the relationship between media organisations and tech platforms in the
digital and AI era.

2. Getty Images v. Stability AI – Landmark Decision in the UK (4
November 2025)
The ruling establishes an initial legal framework for addressing the use of copyrighted works
in AI model training.
Getty’s Claims:
● Unauthorized use of copyrighted images in training Stable Diffusion.
● Generation of images containing watermarks resembling its trademarks.

Court’s Decision:
● No infringement was proven, as the model learns statistical patterns and does not
store or reproduce protected images.
● Trademark infringement was recognized partially and to a limited extent, without
evidence of consumer harm.
● The similar watermarks resulted from model artefacts — not intentional misuse.

Importance of the Ruling:
● Establishes initial legal boundaries regarding liability in AI training.
● Differentiates between “pattern learning” and “copying a work.”
● Reinforces the need for mechanisms to protect creators in the digital space.

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