Regulatory Convergence of Ukrainian Media Legislation with EU Acts: DSA and EMFA

The article examines the regulatory convergence of Ukrainian media legislation with the European Union framework comprising the Audiovisual Media Services Directive, the Digital Services Act and the European Media Freedom Act. It argues that traditional media regulation, focused mainly on broadcasting and the status of media entities, does not adequately address digital platforms, algorithmic content moderation, systemic information risks, advertising technologies and media pluralism. The article aims to identify directions for modernising Ukrainian media legislation, considering Ukraine’s European integration commitments, martial law and the resource vulnerability of the media sector. The study applies formal legal, comparative legal, systemic and structural, functional and institutional methods, as well as legal modelling. It finds that the Law of Ukraine “On Media” substantially approximates European audiovisual standards but does not establish a comprehensive regime for digital intermediary services or incorporate safeguards for editorial independence, transparency of state advertising, media market concentration assessment, predictable funding of public service media and the protection of media service providers on very large online platforms. The scientific novelty lies in an integrated three-level model combining media, platform and security regulation. The article proposes completing legislative adaptation, adopting a separate law on digital intermediary services, modernising the Register of Media Entities, developing co-regulation, ensuring transparent state advertising and establishing safeguards for temporary and proportionate security restrictions. The findings may support legislative amendments and a roadmap for further approximation to European Union law. Further research should focus on the institutional model for regulating digital intermediary services in Ukraine.