Diversity needs structure, not just regulation: the AVMSD review should think the media transition structurally

The European Commission is evaluating the Audiovisual Media Services Directive (AVMSD) and preparing its review, due by 19 December 2026 under Article 33 of the Directive. The consultation process – a call for evidence (November/December 2025) and a public consultation (February to May 2026) – is complete; the evaluation report and, where appropriate, legislative proposals are now being drawn up. The review is part of the Commission’s commitments under the European Democracy Shield.

GISAD – Global Institute for Structure relevance, Anonymity and Decentralisation, the standards institute of the Trusted WEB 4.0 concept – welcomes the evaluation and its declared objectives: simplification of the rules, a level playing field between traditional and digital players, better protection of young viewers, and the strengthening of media pluralism. These objectives are right. But the debate largely treats the symptoms of the platform logic instead of questioning its cause.

1. Recommender algorithms are the cause, not the frame, of the problem

Systems optimised for watch time and personalisation inevitably produce sensory overload, bias and an attention economy. Advertising as the dominant financing model reinforces this mechanism, because every profile has a market value – including the profile of a child. The European Digital System (EU-D-S) demonstrates the alternative: use by categories instead of personality profiles. The Finder-Suche with around 1,000 categories – derived from the category system of a video rental library, not from an advertising network – preserves diversity because users follow categories, not data streams. Those who want diversity must structure diversity: 40 disciplines, each with its own trustee, are a more lasting economic and cultural guarantee than any quota.

2. Protecting minors without profiling

The protection of young viewers is currently being discussed inside a system that seeks to measure them. WAN anonymity reverses this logic: a system that profiles nobody – including children – and governs assignment exclusively via the trust station needs no filter architecture built on profiles, because there are no profiles. Structural personality protection is more effective than any downstream filter.

3. Disputes belong before trust stations, not before platform courts

Article 18 of the European Media Freedom Act shows the dilemma: media content is removed or downgraded by platforms, and media providers fight against arbitrariness. In the EU-D-S, trust stations are the points of contact in disputes – a conciliation structure with a defined procedure instead of autonomous gatekeeper decisions. This is media pluralism as a procedural guarantee, not as an algorithm parameter.

The European Democracy Shield wants resilient democracies. Democratic resilience does not arise from regulated platforms, but from structurally diverse media – and the structure for this is ready.