In journalism, self-regulation refers to profession-led accountability through codes of ethics, independent press/media councils, and non-coercive remedies. Its core purpose is to preserve editorial freedom while providing accessible redress for audiences without resorting to state sanctions or courts. Classic guidance from the OSCE underscores that there is no single model; effective systems tend to be voluntary, profession-owned, and centered on transparent procedures and published decisions (OSCE Representative on Freedom of the Media, 2008). In digital contexts, these principles continue to apply: the OSCE’s online guidebook explicitly argues that the same ethical standards and complaint mechanisms should extend across formats, with adaptations for speed and reach (OSCE Representative on Freedom of the Media, 2013). Press-council networks describe this settlement succinctly: freedom with responsibility, operationalized through ethical codes and complaint handling open to the public (MCDA) (European Fedeartion of Journalists, n.d.).

As a baseline, effective self-regulatory arrangements are typically expected to display: (i) independence from government and dominant funders; (ii) transparent, reasoned decisions published in a timely way; (iii) meaningful newsroom participation so that remedies have practical effect; and (iv) accessibility for citizens. These criteria recur across OSCE handbooks and Council of Europe standard-setting on quality journalism and complaint mechanisms (OSCE Representative on Freedom of the Media, 2008; OSCE Representative on Freedom of the Media, 2013; Council of Europe, 2022).

Co-regulation denotes structured, arm’s-length cooperation between statutory regulators and voluntary bodies—typically via codes of conduct, referral protocols, or data-sharing—while keeping editorial decision-making outside direct state control. In EU policy, the revised Audiovisual Media Services Directive (AVMSD) encourages Member States to foster co- and self-regulation through codes of conduct in areas such as the protection of minors and commercial communications, reflecting the view that such arrangements can complement statutory objectives (Directive (EU) 2018/1808, European Union, 2018). Council of Europe instruments likewise recognize co−/self-regulatory tools within a broader freedom-of-expression framework (Committee of Ministers of the Council of Europe, 2011). However, it is important to mention that in this article, AMC/AEM are treated as voluntary self-regulatory arrangements. While Albania exhibits a mixed accountability ecology (voluntary self-regulation alongside statutory enforcement), this should not be conflated with ‘co-regulation’ in the narrower EU/CoE sense that typically entails formalized shared governance or structured joint frameworks between state and non-state actors.

Albania’s Audiovisual Media Authority (AMA) is a statutory regulator with a mandate over linear and non-linear audiovisual services under Law No. 97/2013. Within this remit, AMA issues warnings and financial sanctions and applies a detailed Broadcasting Code (most recently updated by Decision No. 60, 10 July 2023). By design, this pillar relies on administrative enforcement and legally binding remedies rather than the moral persuasion typical of self-regulatory arrangements (Council of Europe, 2020).

By contrast, Albania’s voluntary media accountability architecture – centered on the Albanian Media Council and the Alliance for Ethical Media - operates through voluntary adherence to the Journalists’ Code of Ethics, mediation, and public decisions aimed at correction and ethical accountability rather than punishment. Remedies are non-coercive and reputational in nature and depend on publication practices, newsroom cooperation, and public visibility for their practical effect, reflecting core principles articulated in OSCE guidance and European press-council practice (OSCE Representative on Freedom of the Media, 2008).

In this study, self-regulation (non-coercive, profession-led remedies) and statutory regulation (law-based, coercive enforcement) are treated as distinct but potentially complementary accountability paths, each operating under different legal mandates, incentives, and visibility conditions. The analysis does not assume that one path is normatively superior or empirically dominant. Instead, it examines how each pillar generates observable accountability signals, how those signals differ in form and salience, and how their coexistence shapes complaint-handling practices in a mixed system (Directive (EU) 2018/1808, European Union, 2018).

Scholarship on media self-regulation and accountability has long debated when press and media councils move beyond symbolic or purely moral instruments to become effective sites of redress. Classic work emphasizes that councils, ombudsmen, and ethic bodies rely primarily on soft power—reputation, peer pressure, and transparency—rather than coercion (Bertrand, 2000; McQuail, 2003). Cross-national studies of European accountability bodies identify persistent design tensions: arrangements that are too closely aligned with professional interests’ risk capture and ineffectiveness, whereas those tied to state institutions or dominant market actors risk undermining editorial independence (Eberwein et al., 2011; Fengler et al., 2014). Research on media and regulatory governance further situates self- and statutory regulation within broader hybrid systems, in which authority is distributed across regulators, industry actors, and civil society (Bardoel and d’Haenens, 2004; Puppis, 2010). In post-communist and hybrid regimes, these arrangements operate in politicised environments marked by contested regulator independence, market concentration, and EU conditionality (Dragomir, 2019; Hallin and Mancini, 2004; Jakubowicz, 2007). Albania’s dual-pillar configuration fits this broader European pattern of hybrid accountability, while also reflecting the specific pressures of democratic consolidation and accession-driven reform.

Domestic scholarship has increasingly examined Albania’s media regulation within the context of EU integration. Legal-policy analyses trace how innovative regulatory tools and practices align (or fail to align) with EU standards in the digital age, including proposals around co-regulation and platform oversight (Budini et al., 2025b), while related work on media discourse shows how Albanian newsrooms narrate the path “from isolation to integration” in their coverage of EU accession (Budini et al., 2025a). Earlier scholarship already highlighted self-regulation in the electronic media as a key test of Albania’s readiness to internalize European norms, but mainly at the level of formal frameworks and policy prospects (Budini, 2015). Complementary contributions from journalism and media-law studies focus on how technology-driven data journalism can support transparency and accuracy in line with EU expectations (Ferhataj, 2025), and how media-freedom and source-protection standards derived from international and European law should be embedded in domestic practice (Lamçe and Zhilla, 2025). Building on this body of work, the present article shifts the lens from normative design and discourse to within-case process tracing of complaint handling and policy conflict, asking not only what the Albanian framework aspires to under EU standards, but how accountability mechanisms actually function across voluntary and statutory bodies.

Our theorised mechanism builds on how these literatures understand legitimacy and accountability in non-judicial redress. Political science work stresses that institutions gain acceptance not only from their formal mandates but also from perceptions of fair procedures and effective problem-solving (Scharpf, 1999; Suchman, 1995). Media-specific studies similarly argue that accountability mechanisms are credible when they are procedurally transparent, open to audiences, and capable of generating visible corrective action in newsrooms (Eberwein et al., 2011; McQuail, 2003). At the same time, research on co-regulation and regulatory competition suggests that strong statutory enforcement can “crowd out” voluntary mechanisms when citizens and media actors come to view the state regulator as the only effective route to remedy (Bardoel and d’Haenens, 2004; Puppis, 2010). Our rival “state-centric substitution” and “litigation/SLAPP deterrence” mechanisms speak directly to this concern.

Within this scholarship, the article’s contribution is threefold. Empirically, it reconstructs in detail how complaints travel through Albania’s mixed accountability system—both in the voluntary and statutory pillar—and how the anti-defamation package would have redrawn the boundary between them. Existing comparative work on media accountability in Central and Eastern Europe and the Western Balkans often maps institutions and legal frameworks but rarely follows specific complaint sequences across fora or over time. Conceptually, the article refines the notion of “accountability” in mixed systems by showing how it depends not only on the existence of codes and councils, but also on the visibility of outlet-side compliance and on the relative publicity and coerciveness of statutory sanctions. Methodologically, it demonstrates how theory-testing process tracing can be applied to media regulatory design: by using hoop, smoking-gun, and straw-in-the-wind tests on documentary evidence, we assess not just whether institutions formally exist, but whether the hypothesized mechanism linking design features to accountability visibility and complaint routing is borne out in concrete Albanian cases.

The research question guiding the study is: To what extent does Albania’s self-regulatory system produce credible and visible non-judicial remedies, and how do interactions with statutory oversight help or hinder that process?

The analysis covers 2018–2025, from the revision of the Journalists’ Code of Ethics (Council of Europe, 2018) through the anti-defamation debate and the entry into force of the European Media Freedom Act (with full application from August 2025). The domain is media-ethics accountability in press/online journalism and audiovisual broadcasting, excluding criminal speech and court litigation. Evidence is drawn exclusively from publicly accessible documentary sources: laws and ethical codes, institutional procedures and rulebooks, published decisions, official bulletins and press notes, and assessments by European and international organizations.

Building on the process-tracing canon (Beach and Pedersen, 2019; Bennett and Checkel, 2014; Collier, 2011; George and Bennett, 2005; Mahoney, 2012), we formulate the following mechanistic hypothesis:

We conceptualize this mechanism as shown in Table 1: clear procedural rules + empowered bodies + timely, public, reasoned decisions ⟶ accountability visibility ⟶ legitimacy and uptake of non-judicial redress.

The mechanism is expected to operate under the following scope conditions:

In addition to the main hypothesized mechanism outlined above, the analysis is evaluated against two rival mechanisms that have been identified in the literature on media governance and regulatory interaction.

The first is a state-centric substitution mechanism. This mechanism does not assume displacement as a given, but posits that where statutory enforcement produces more salient, regularly publicized, and coercive outcomes than voluntary remedies, complainants may come to view the statutory regulator as the most effective route to redress within its jurisdiction. Over time, this may condition complaint-routing behavior, particularly in high-visibility media sectors such as broadcast entertainment. Importantly, this mechanism is treated as contingent, not automatic: it is expected only where statutory remedies are both more visible and clearly applicable,

The second is a litigation and legal-risk sensitivity mechanism, often discussed in relation to SLAPPs. This mechanism is treated bidirectionally. Heightened legal risk may reduce outlets’ willingness to publicly acknowledge ethical breaches or engage visibly with voluntary rulings; at the same time, contemporary EU digital regulation (including the Digital Services Act) recognizes participation in self-regulatory or co-regulatory schemes as a form of due diligence and risk mitigation. Legal risk may therefore either discourage or incentivise engagement with voluntary accountability mechanisms, depending on context, sector, and dispute type (Table 2).

In the empirical analysis that follows, the state-centric substitution mechanism is treated as the primary rival and subjected to process-tracing tests alongside the main hypothesis. The litigation/legal-risk sensitivity mechanism is treated as a background conditioning factor, informed by aggregate indicators and external assessments, but not reconstructed as a full within-case causal sequence due to limitations in the available documentary evidence.

The study employs purposeful within-case selection to maximize inferential leverage on the hypothesized mechanism and its rivals, following established guidance in theory-testing process tracing (George and Bennett, 2005; Blatter and Haverland, 2014; Beach and Pedersen, 2019). Rather than seeking representativeness, cases are selected because they illuminate distinct stages of complaint handling, variation in remedy visibility, and different institutional configurations within Albania’s mixed media accountability system.

Three cases are analysed, each serving a specific analytic function.

The empirical corpus is documentary and archival/online, consisting exclusively of publicly accessible sources:

We convert the mechanism’s abstract steps into observable indicators of accountability visibility:

Coding proceeded in two stages: (1) event reconstruction (chronological sequencing of decisions and actions), (2) mechanism coding (presence or absence of indicators at each step). Uncertainty was recorded explicitly particularly where outlet-side responses were not observable in the documentary record.

For Case A’s outlet-side compliance, we used a standardized search strategy to reduce non-observation risk. For each outlet (Panorama Online, Elbasani Plus, Tirana Sot), we started from the URL cited in the AMC decision and checked whether the original item had been removed, amended, or accompanied by a correction, apology, or editorial note. We then used the outlet’s internal search and site-restricted web searches (e.g., “R. T.,” headline keywords, “korrigjim/përgënjeshtrim” + site:domain.tld) and, where available, scanned dedicated clarification/corrections sections and AMC social-media posts or news items announcing decisions. The search window ran from the decision date (24 June 2025) to three months afterwards. For each outlet, we coded compliance as “yes” (visible correction/apology or link-back on the outlet’s site), “no” (explicit non-publication noted by AMC), or “uncertain” (no observable action in the materials consulted). This procedure cannot eliminate all risk of non-observation, but it makes explicit the tools, time frame, and criteria behind the visibility assessment.

Following the process-tracing canon, we deploy diagnostic tests (Beach and Pedersen, 2019; Mahoney, 2012; Collier, 2011):

Among rival explanations, the analysis focuses on state-centric substitution as the primary alternative mechanism and subjects it to the same inferential logic as the main hypothesis, examining relative visibility and salience of statutory versus voluntary accountability signals. Litigation and legal-risk sensitivity is treated as a contextual conditioning mechanism, informed by aggregate indicators and institutional assessments, but not reconstructed as a full within-case causal sequence due to evidentiary limits.

To safeguard internal validity, we base the analysis on dated, primary documents issued by institutions—laws, codes, formal decisions—so that event timing is clear and the risk of recall or reporting bias is minimized. The study’s central analytical focus, “accountability visibility,” is operationalized through observable indicators rather than claims about public perception. For reliability and transparency, we keep an auditable record of all files and event logs, and when webpages are mutable or frequently updated, we rely on official PDFs or archived snapshots to preserve a stable evidentiary record. The approach has limitations. Non-observation does not equal non-compliance: the absence of a visible correction may reflect site design, relocation, or deletion rather than inaction. Some decisions are summarized rather than fully reasoned, which introduces selective-transparency risk. Finally, the study does not directly measure audience perceptions or complaint-routing behavior, and any inferences regarding legitimacy or uptake remain conditional and inferential rather than demonstrative.

This case examines how far Albania’s voluntary self-regulatory track progresses along the hypothesized causal sequence, from formal rules and adjudication to observable accountability outcomes. The complaints were filed by R. T., who argued that several outlets had retained or republished legacy online stories from 2020 concerning a family dispute involving alleged falsification of civil-status records in the context of a housing and property conflict. The complainant had discussed the matter publicly when he was 18 years old. The three Albanian Media Council (AMC) decisions—concerning Panorama Online, Elbasani Plus, and Tirana Sot—identify the specific articles at issue and conclude that the content no longer carried sufficient public-interest value, that the complainant had been young and in a vulnerable position at the time of the interviews, and that the outlet which originally published the story had since removed it. On this basis, the Board recommended that the outlets respect the complainant’s right to be forgotten by withdrawing, correcting, or otherwise remedying the publications. The hypothesized sequence for this case is: published rules and jurisdiction → receipt and screening of complaint → reasoned decision → public availability of the decision and recommended remedy → accountability visibility.

Each link is evaluated using process-tracing diagnostics (hoop tests, straw-in-the-wind indicators, and—where normatively appropriate—potential smoking-gun indicators), triangulating across posted decisions and institutional rules.

Preconditions (rules and jurisdiction): The Alliance for Ethical Media’s internal rules codify jurisdiction, conflict-of-interest declarations, and meeting periodicity, and assign the Albanian Media Council the role of complaints secretariat. They specify operational deadlines: the media outlet must respond within seven working days to the Board’s information request; the Board meets at least monthly; decisions are generally adopted within one month (extendable to three months); and decisions must be communicated to the parties within seven days. Importantly for accountability visibility, Article 13 requires outlets found in breach to publish the Board’s decision in the same space as the contested item. If publication does not occur within seven days, the Board is required to inform Alliance members and periodically inform the public about non-compliant outlets. These provisions satisfy hoop tests for the institutional preconditions of the mechanism and define what publication of a remedy would entail in practice (Alliance for Ethical Media, n.d.).

Case B examines the statutory enforcement pathway through which the Audiovisual Media Authority (AMA) translates legal mandate and oversight capacity into reasoned decisions that culminate in warnings or financial sanctions. The statutory mechanism under observation is: legal mandate → complaint intake and/or monitoring → reasoned decision → public warning or sanction → accountability visibility.

Legal basis and scope. AMA’s jurisdiction is grounded in Law No. 97/2013 on Audiovisual Media (as amended), which covers linear and non-linear audiovisual services and explicitly excludes the written press and most online-only publications. The authority operationalizes this mandate through the Audiovisual Media Broadcasting Code, approved by AMA Decision No. 60 of July 10, 2023. Both the statute and the code delineate standards on the protection of minors, hate speech and discrimination, and advertising practices, among others. The AMA’s own complaints bulletin reiterates that even after the April 2023 amendments, online press remains outside the authority’s remit. These sources satisfy a hoop test for jurisdiction and scope, establishing that AMA has authority over the programs analyzed in this case while delimiting what lies beyond it [Republic of Albania, 2013; Audiovisual Media Authority (AMA), 2023a, b, 2024b].

Case C examines how domestic veto points and international legal scrutiny conditioned the trajectory of proposals to expand statutory media regulation in Albania between 2019 and 2024. Rather than treating the episode as a conflict between statutory regulation and self-regulation as such, the analysis focuses on whether the proposed expansion of the Audiovisual Media Authority’s (AMA) mandate complied with internationally recognized standards of scope, independence, proportionality, and due process. The process-tracing proposition is that parliamentary adoption would activate domestic constitutional checks and external review by European institutions, and that these interventions—if targeting core design defects rather than marginal issues—would significantly reshape the prospects for implementation. The diagnostic expectation is a sequence of necessary hoop events (adoption; activation of a domestic veto), followed by probative evidence that international assessments identified structural legal flaws, and culminating in an outcome signal consistent with sustained constraint (policy stalling or withdrawal).

Revisiting the rival mechanisms in light of the cross-case evidence further clarifies the study’s inferential boundaries. The state-centric substitution mechanism is partially supported at the level of conditions, but not at the level of outcomes. Case B confirms that statutory enforcement produces more salient and coercive remedies within the audiovisual sector. Case A shows that voluntary remedies may be less visibly implemented at the outlet level in certain types of disputes. Together, these findings establish the possibility of substitution under specific conditions—namely where statutory remedies are clearly applicable and more visibly enforced. However, the study does not provide direct evidence that complainants actively redirect disputes away from voluntary bodies toward AMA, nor that voluntary complaint volumes decline as a result. Substitution therefore remains a plausible but unobserved mechanism, consistent with the literature but not demonstrated in the Albanian cases examined.

The litigation and legal-risk sensitivity mechanism, often discussed in relation to SLAPPs, operates in the background rather than as a traceable within-case sequence. Aggregate indicators point to a challenging legal environment for media actors, but the available documentary evidence does not allow reconstruction of specific causal chains linking legal threat to engagement or non-engagement with voluntary accountability bodies. Importantly, contemporary EU regulatory frameworks also recognize that legal risk may incentivise participation in self- or co-regulatory schemes as a form of due diligence. For these reasons, legal-risk sensitivity is best treated as a contextual conditioning factor that may interact with both statutory and voluntary mechanisms in different ways, rather than as a unidirectional deterrent.