EIN Freedom of Expression Closing Conference — European Implementation Network

Introduction

On 25–26 June 2025, the European Implementation Network (EIN) held the closing conference of its two-year project Protecting Freedom of Expression by Supporting ECtHR Implementation at the Konstantinidis Mansion, home of the Association of Journalists of Macedonia and Thrace in Thessaloniki, Greece. This landmark event brought together around 40 civil society human rights defenders, lawyers, journalists, academics and officials from across Europe to celebrate collective achievements, confront persisting obstacles and chart a path forward for the protection of freedom of expression.

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By late 2022, more than 105 leading ECtHR judgments on free speech remained unimplemented across at least 20 Council of Europe States, underlining the urgency of the task. Set against a sobering backdrop of democratic backsliding, restrictive defamation laws, state-controlled media and violence against journalists, and after two years of consistent work on generating engagement with free-speech judgments pending implementation, the conference addressed a pressing challenge: How to ensure that the European Court of Human Rights’ judgments on free expression translate from victories on paper into real change on the ground.

Over two days of discussions, participants reflected on the impact of the project’s multifaceted activities, shared best practices and lessons learned, and explored how similar progress could be replicated in other jurisdictions. Civil society members involved in the project compared experiences with peers from different European States, while representatives from the Council of Europe, national human rights structures, the media and other stakeholders identified ways to strengthen synergies, ensure sustainability and enhance the long-term role of civil society in the implementation process.

Keynote Speech – Illiberalism and Growing Threats to Freedom of Expression: Why ECtHR Implementation Matters?

The conference opened with a keynote by Dunja Mijatović, former Council of Europe Commissioner for Human Rights and former OSCE Representative on Freedom of the Media, whose intervention framed the discussions for the two days. Mijatović situated threats to freedom of expression within the wider context of democratic backsliding across Europe. She stressed that this right is foundational: it enables accountability, exposes wrongdoing, and sustains democratic imagination. She warned that across Europe and beyond, this right is eroding — sometimes slowly, others abruptly — undermining democratic institutions.

A major thread in Mijatović’s address was the fundamental importance of implementation of ECtHR judgments. Strasbourg judgments, she argued, are more than legal texts: they are instruments of democratic renewal that only gain meaning when enforced nationally. Drawing from her experience in Bosnia and Herzegovina, the Western Balkans, the OSCE and the Council of Europe regions, Mijatović illustrated how institutional weaknesses, restrictive laws, and political resistance obstruct reforms needed for effective implementation, while at the same time showing that civil society engagement can push for positive change. She highlighted the need for synergies between international institutions and national actors, urging NGOs to seek open channels of communication with regional bodies and to cooperate strategically rather than in parallel with them.

The subsequent Q&A session allowed participants to explore how these synergies can be strengthened. Mijatović emphasised the complementarity of mandates across institutions such as the UN, OSCE, and the Council of Europe, but also their limitations, and the need for more coordinated approaches. She called on civil society to use these mechanisms assertively while insisting on accountability for states. This keynote thus set the tone for the entire conference: implementation of ECtHR free expression judgments as a core democratic battleground and a collective responsibility requiring cooperation across sectors.

Dunja Mijatović’s keynote offered a panoramic overview of the state of freedom of expression in Europe. Drawing on her tenure as Council of Europe Commissioner for Human Rights and OSCE Representative on Freedom of the Media, she conveyed the image of a continent where free speech, once assumed to be secure, is now facing multifaceted pressures. She began by noting that the right to free expression is the linchpin for all other rights — it underpins democratic participation, accountability and pluralism. When curtailed, every other right becomes harder to exercise.
She pointed at three converging threats: (1) the systematic use of defamation laws and Strategic Lawsuits Against Puplic Participation (SLAPPs) to silence journalists and NGOs; (2) the consolidation of media ownership by state-linked actors undermining pluralism; and (3) the widespread harassment and violence against reporters and human rights defenders. These practices, she argued, erode the public sphere and weaken democratic oversight. In her words, Europe is witnessing both slow-burning and abrupt reversals, with restrictive legislation justified in the name of national security or public order.
A central argument of Mijatović’s keynote was that ECtHR judgments are only as powerful as their implementation. She underscored that Strasbourg decisions are not mere technical findings; they are instruments for democratic renewal, clarifying obligations, naming injustices, and mapping pathways for reform. Yet, their authority depends on being enforced nationally. She described how, during her time at the OSCE and the Council of Europe, she saw repeated instances where states accepted judgments on paper but delayed or watered down their execution. This “implementation gap” represents not merely administrative inertia but, often, an intentional political strategy to neutralise human rights oversight.
Mijatović drew on her experience in the Western Balkans, particularly in post-war Bosnia and Herzegovina, to illustrate how fragile democracies wrestle with upholding free expression. She explained that, in fragile democracies, court victories and international monitoring can create moments of progress — new legislation, oversight bodies, or recognition of rights. But, without sustained political will and civic pressure, such gains are easily reversed. She insisted that implementation processes themselves must be understood as arenas of advocacy, not just a legal end-point.
Much of the keynote and subsequent Q&A focused on synergies between institutions. Mijatović mapped the relevant ecosystem, including UN special procedures, Council of Europe mechanisms (including the Commissioner’s Office, the Execution Department and the Platform for the Safety of Journalists), and the OSCE’s three human dimension institutions. She stressed that, while overlaps can lead to duplication, coordinated action can create real impact, as in joint statements or country visits undertaken with fellow mandate holders. Coordination between them, however, is still underdeveloped. NGOs, she urged, should view these bodies as complementary channels rather than discrete silos.
As part of the Q&A session, participants asked how NGOs can effectively use these mechanisms given the shrinking civic space. Mijatović noted that Rule 9 submissions to the Committee of Ministers, public briefings, and joint advocacy across borders are practical ways to exert pressure. She cautioned, however, that mandates differ in how outspoken their holders can be, which sometimes results in uneven engagement or even silence from certain bodies. This is not necessarily bad faith but reflects institutional constraints. Civil society can offset this by feeding credible information to all relevant mechanisms simultaneously.
Mijatović also reflected on her own choice to use plain, direct language during her mandates — sometimes breaking diplomatic convention — to amplify urgent concerns. This, she suggested, is sometimes necessary to shift narratives, but it requires NGOs to be prepared with solid evidence and coherent messaging to back such statements.
Looking ahead, Mijatović urged participants to recoceptualise implementation as the decisive stage where rights either remain rhetorical or become a reality. This means anticipating obstacles, framing communication around human impact, and building coalitions with media, parliamentarians, and independent state bodies. It also means making better use of the synergies between international institutions so that no judgment falls into a vacuum. The right to free expression, she concluded, does not enforce itself; its preservation requires political courage and collective action.
By the end of the keynote session, it had become evident that the conference would not merely celebrate achievements but would also delve into the structural weaknesses obstructing ECtHR judgments’ implementation. Mijatović’s insistence on collective responsibility — where NGOs, governments, and international bodies must align efforts — became a recurrent reference point throughout the discussions in subsequent panels.
Thus, the keynote and its Q&A established a conceptual frame linking freedom of expression, democratic resilience, and the implementation of ECtHR judgments. It highlighted that while Europe faces rising illiberalism and shrinking civic space, it also has a strong but underused network of institutions and civil society actors capable of resisting this trend — provided they coordinate effectively. This dual message of urgency and possibility was designed to energise participants and to set the substantive and strategic tone for the panels that followed.

Panel 1 – Advocating Change: Impact and Lessons from Effective ECtHR Implementation

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The first panel highlighted how civil society can drive tangible change through the implementation of ECtHR judgments on freedom of expression. The discussion brought together project beneficiaries and partners from Lithuania, Romania, and Moldova, each presenting national experiences under the Freedom of Expression project. Across the three case studies, panelists illustrated how systematic engagement with the Committee of Ministers, combined with rigorous national-level advocacy, has resulted — in cases where political resistence to effective implementation is not deeply entrenched and a strategic choice of the jurisdiction concerned — in legal reforms, improved institutional responses and stronger public debate around freedom of expression.

Speakers reported that, in Lithuania, civil society used the Macatė v. Lithuania case to secure structural changes in defamation standards and bolster journalist protections, achieving a Constitutional Court ruling declaring impugned provisions unconstitutional. In Romania Rule 9 submissions, public hearings and strategic alliances helped exercise pressure on the authorities to continue addressing freedom of expression deficiencies through angles that were prematurely considered as resolved. Finally, speakers underscored that in Moldova independent journalists worked with NGOs to leverage ECtHR findings and create momentum for legislative change despite persistent political volatility, which became possible through achieving to alter the implementation trajectory of the ECtHR judgment at issue and preventing its premature closure.

All speakers of the panel placed emphasis on the relevance of collaboration — not only between NGOs but also with international bodies such as the Council of Europe. Panelists underscored the importance of evidence-based advocacy, media outreach and persistence in the face of political resistance. The session finally distilled lessons for replication: clear messaging around human impact, proactive engagement with authorities, and coalition-building across borders. Together, these interventions framed implementation not as a technocratic process but as a strategic avenue for democratic renewal, which can achieve substantial reforms if the political will to go down the path of effectively upholding Convention standards is not entirely absent.

This opening panel moved from Dunja Mijatović’s international-level framing to concrete examples of how civil society transforms ECtHR judgments into domestic reforms. Moderated by Maciej Nowicki, EIN’s Chair, it brought together three practitioners representing Romania, Lithuania and Moldova.
Panel 1’s deep dive into effective implementation campaigns began with Ramute Remezaite, EIN’s Vice-Chair, Lithuanian Lawyer & Senior Legal Consultant and Implementation Lead at the European Human Rights Advocacy Centre (EHRAC) providing an analysis of Lithuania’s Macatė case, which concerned restrictions imposed on a children’s book depicting same-sex families. The book was suspended from distribution in 2014 and later released anew with a warning label under the Minors Protection Act. In 2023, the ECtHR Grand Chamber found that these restrictions violated Article 10. Turning to implementation, Ramute explained that the Ministry of Justice initially proposed removing the provision through legislation, but parliament rejected the draft. Nonetheless, because repealing the provision did not require enacting a new law, the government had another avenue, that of constitutional review of the impugned legislation. As such, the Ministry petitioned the Constitutional Court, which in late 2023 declared the provision unconstitutional. Ramute detailed how civil society played a decisive role in this development, with Lithuanian NGOs engaging actively with the Committee of Ministers through Rule 9 submissions, monitoring domestic processes, and maintaining dialogue with the authorities. Finally, she underlined that experience from this judgement demonstrated that even in relatively favorable environments, reforms need civil society’s monitoring to be upheld with a view to avoiding backsliding.
Georgiana Gheorghe, Executive Director of the Asociația pentru Apārarea Drepturilor Omului în România, Comitetul Helsinki (APADOR-DH, which currently holds the position of Secretary on EIN’s Board) then traced Romania’s unresolved struggle with defamation law, focusing on the Ghiulfer Predescu v. Romania judgment. Although Romania decriminalised defamation in 2006, Georgiana stressed, the problem merely migrated into civil proceedings. Predescu’s own case illustrated the dynamic: in 2007 she was ordered to pay heavy damages for criticising a mayor, a sanction the ECtHR condemned in 2017 for failing to distinguish between value judgments and factual statements and for imposing a chilling burden on journalism. Georgiana underlined that despite government claims of progress, reality on the ground tells another story. Nine further judgments have confirmed similar violations, while Romania has witnessed an explosion of SLAPPs targeting not only journalists but also environmental activists and other citizens. In response, civil society has gradually consolidated its efforts: documenting abusive cases, submitting Rule 9 communications to the Committee of Ministers, and using Strasbourg’s supervision to reopen domestic debates on the legislative reforms required to effectively resolve the underlying sources of violation. They also seized the legislative moment created by the Directive (EU) 2024/1069 of the European Parliament and of the Council of 11 April 2024 on protecting persons who engage in public participation from manifestly unfounded claims or abusive court proceedings (herein after, the ‘EU Anti-SLAPP Directive’), pressing the Ministry of Justice to make the most of the ECtHR judgment by going beyond a minimal approach, which would consider the upholding of minimum standards satisfactory. In her conclusion she noted that progress is often slow and incremental, but keeping the issue visible ensures that momentum and opprotunities for effective implementation of an EctHR judgmens are not lost.
Cristina Durnea, Lawyer and Program Manager at the Independent Journalism Center (IJC), presented the Manole and Others v. the Republic of Moldova case, which originated from a state-owned broadcaster having been brought under strict political control following the 2001 elections. In 2009, the ECtHR found a violation of Article 10, ruling that Moldova had failed to secure genuine independence for its public broadcaster. Cristina underlined that implementation lagged for years and, in 2021, a new parliamentary majority even reintroduced political control, effectively replicating the violation identified by the ECtHR. At this stage, she explained, civil society intervened decisively, by publishing legal critical assessments, organising press conferences, and using its place in a parliamentary working group to object to the amendments. Crucially, with EIN’s support, IJC submitted its very first Rule 9 communication to the Committee of Ministers, leading to the placement of the Manole case under enhanced supervision. Civil society’s consistent pressure led to their involvement in the development of a new package of amendments aimed at restoring safeguards for independence. Cristina concluded by stressing that without civil society vigilance, the judgment might have been prematurely closed despite backsliding. Instead, sustained advocacy, international visibility, and reliance on Strasbourg mechanisms created space to correct the course.
Panelists converged on several lessons from their national experiences. Evidence-based advocacy strengthens credibility before the Committee of Ministers, while timing is critical: submissions and public actions should coincide with legislative or political oportunities for intervention. Coalition-building enhances resilience and visibility, preventing authorities from isolating individual NGOs. Equally important is communication-framing technical implementation issues as human-impact stories to mobilise wider public support.
The role of the Council of Europe and EIN was highlighted as central. As per the speakers, the EIN Secretariat has facilitated cross-border exchanges, provided templates and advice for Rule 9 submissions, and enabled civil society to meet with national delegations before the CM. Council of Europe officials are increasingly receptive to detailed, solution-oriented NGO evidence, creating a feedback loop in which credible data prompts sharper questioning of governments and greater pressure for compliance.
Looking ahead, panelists pointed to the EU’s Anti-SLAPP Directive, the need for national action plans to ensure sustained follow-up on ECtHR judgments, and the potential of an alert system to track pending cases and new threats. They stressed that maintaining visibility after initial reforms is essential, since gains can quietly unravel without ongoing monitoring.
The overarching narrative reframed implementation not as a bureaucratic chore but as a political opportunity: a chance to re-anchor freedom of expression as a cornerstone of democratic governance. By linking Strasbourg judgments to everyday concerns — press freedom, civic participation, anti-corruption — civil society can broaden alliances, attract public support, and build momentum for deeper democratic renewal.
This first panel provided a template for the conference: moving from diagnosis to applied strategies. It showed that even amid political headwinds, civil society can leverage ECtHR judgments to reshape national laws and practices, provided advocacy is persistent, evidence-based and cooperative. The interventions of Ramute, Georgiana and Cristina illustrated how actors in three different jurisdictions at varying stages of democratic development can nonetheless apply similar methods to defend free expression and push governments toward compliance with Strasbourg’s standards.

Panel 2 – Halfway There? Navigating Fragmented Impact in SLAPPs-Plagued Jurisdictions

This panel took the audience from examples of success stories to more persistent challenges, best exemplified through a more complex picture, present in jurisdictions where SLAPPs still distort public debate and impede ECtHR judgment implementation. The panelists described how defamation suits, political pressure and weak institutional safeguards in Croatia, Greece, Poland, Italy and Slovakia have limited reforms despite Strasbourg judgments and an active civil society engagement.

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Speakers began by detailing Croatia’s entrenched SLAPP culture — aspects of which were examined in the context of the Stojanović v. Croatia group of cases — and the chilling effect of excessive damages, a problem which the — now closed — implementation process failed to tackle effectively, in the civil society’s view. Subsequently, Greece’s struggles to address long standing problems of outdated defamation laws and new forms of political intimidation, as well as the linkages between Poland’s legislative stagnation and broader rule-of-law concerns were examined. Finally, the jurisdictions of Italy and Slovakia were examined in the light of the SLAPPs’ perspective, with the interventions highlighting instances of complete stagnation in addressing criminal defamation-related concerns, and examples of how populist actors instrumentalise litigation and regulatory capture to restrict dissent while claiming compliance with human rights norms.

Across these contexts, panelists stressed the difficulty of pushing reforms without clear ECtHR case-law on SLAPPs and underscored the importance of combining further strategic litigation, Rule 9 submissions, evidence gathering, and cross-border NGO coalitions to maintain pressure. They also called for better training of judges at first instance courts, more consistent use of Strasbourg jurisprudence domestically, and stronger media alliances to expose SLAPP practices. Ultimately, this session framed SLAPPs as a structural barrier to free expression, requiring both legal reform and sustained civil society engagement.

Ivan Novosel, Director of Programs at the Human Rights House Zagreb (HRHZ) kickstarted the discussions of Panel 2 by situating Croatia as a revealing test case for how entrenched SLAPPs practices can blunt the ECtHR’s impact. He focused on the Stojanović group of judgments, where the ECtHR had found persistent failures by Croatian courts to distinguish value judgments from statements of fact, a cornerstone of Article 10 case-law. Despite these rulings, domestic courts continue to impose disproportionate sanctions, and journalists remain vulnerable to decade-long defamation proceedings that create a strong chilling effect. Ivan explained that Human Rights House Zagreb, working with the Croatian Journalists’ Association and with the support of the EIN, had filed four detailed Rule 9 communications before the Committee of Ministers. These submissions documented that scattered Supreme Court or Constitutional Court interventions attempting to uphold Convention standards on Art. 10 matters were still not filtering down to everyday judicial practice. To substantiate their claims, NGOs used freedom-of-information requests to extract data on judicial training and case outcomes. These records showed both both the scale of the persisting problem as demonstrated by the number of new incoming SLAPP lawsuits, and the inadequacy of training for lower-level judges. Despite this evidence, the Committee of Ministers chose to close supervision, a decision Ivan described as sending the wrong political signal and leaving Croatian journalists exposed to systemic intimidation through civil litigation.
Aspasia Theochari, Lawyer and Vice-President of the Hellenic League for Human Rights (HLHR), then examined the Greek context, highlighting how outdated defamation provisions and an increasingly hostile political climate combine to entrench SLAPP-like practices. She recalled that although “simple defamation” was recently decriminalised in Greece, civil courts continue to award excessive damages while “slanderous defamation” remains criminal. She drew attention to the Vasilakis v. Greece judgment, already pending for close to 18 years, noting that the Court had effectively articulated SLAPPs criteria long before using the term explicitly. Aspasia emphasised that Greece still lacks a coherent action plan for implementing ECtHR free expression judgments. This legal uncertainty has been exploited in politically sensitive areas, where powerful actors use defamation claims to stifle scrutiny. While the EU Anti-SLAPP Directive offers new tools, she warned that its delayed entry into force and the government’s reluctance to extend protections beyond cross-border cases mean that journalists remain exposed. For Aspasia, the priorities are clear: targeted training for judges, systematic monitoring of defamation judgments, and building public awareness that abusive litigation undermines democratic oversight.
Zuzanna Nowicka, lawyer for the Freedom of Speech Programme at Helsinki Foundation for Human Rights (HFHR), then placed Poland’s fragmented experience with implementation of free-speech judgments in the sui generis context of rule-of-law deterioration the jurisdiction has been grappling with in the last decade. She explained that the capture of the judiciary and the erosion of institutional independence directly weaken the implementation of ECtHR judgements. She notably highlighted the surge of SLAPPs filed by politicians and state-owned enterprises, often using public funds, through which journalists and NGOs are pulled into costly, protracted litigation, even when cases are ultimately dismissed. Although Poland has filed action plans with references to reforms, in practice there has been no real shift. Civil society organisations have therefore been compelled to rely on international mechanisms, particularly Rule 9 submissions to the Committee of Ministers, to maintain pressure and even obtain information that were requested at national level without success. Zuzanna argued that without restoring institutional independence, domestic compliance will remain superficial, but sustained international scrutiny is essential to prevent complete backsliding.
Maksym Popovych, Senior Legal Officer for Europe and Central Asia at Article 19 broadened the discussion by addressing Italy. Concerning Italy, he pointed to the Belpietro judgment, where the ECtHR ruled that even suspended prison sentences for journalists breach Article 10 of the Convention. Despite this finding, criminal defamation remains enacted in legislation, and parliament has repeatedly failed to pass reforms. Civil defamation claims also continue, with disproportionate awards. Maksym described this as “implementation fatigue”: Strasbourg judgments are formally acknowledged but not absorbed into domestic law or practice, leaving risks for journalists unaddressed. He then expanded the perspective to Europe and beyond, stressing that while the European Court has strengthened scrutiny of defamation cases, it has not categorically condemned criminal defamation. Other international bodies, such as the UN Human Rights Committee and the African Court, have explicitly called for decriminalisation. Maksym pointed to countries in Latin America, Africa, and Asia where criminal defamation has been abolished without harming public debate, offering examples that can inform advocacy efforts in Europe. Finally, he emphasised the current momentum created by the EU Anti-SLAPP Directive, urging coordinated action to pursue comprehensive defamation reform. This includes addressing criminalisation, excessive sanctions, overlapping civil and criminal cases, and promoting effective non-pecuniary remedies that protect both freedom of expression and reputation.
Panelists identified common obstacles across Croatia, Greece, Poland, Italy, and Slovakia. A major difficulty is the absence of ECtHR case-law explicitly addressing SLAPPs, which forces NGOs to rely on defamation precedents and to stretch existing jurisprudence to confront new forms of litigation abuse. Even where constitutional or supreme courts have seemingly aligned with Strasbourg standards, lower courts often fail to follow, leaving everyday practice unchanged. At the local level, “serial slappers” use repeated defamation suits to create a sheriff-like culture. For journalists, the chilling effect is compounded by the heavy financial and psychological toll of protracted litigation.
Despite these challenges, panelists highlighted strategies that have proven effective in practice. Freedom of information-driven evidence-gathering has been crucial for exposing gaps left by government reporting and for providing independent data to Strasbourg bodies. Joint submissions by multiple NGOs enhance both legitimacy and visibility before the Committee of Ministers. Training programs for first-instance judges are essential to ensure Strasbourg principles are applied where they matter the most. Coalitions among media actors, meanwhile, help publicise SLAPP patterns and mobilise public opinion, ensuring that abusive litigation is framed as a threat to democratic accountability rather than as isolated disputes.
Looking forward, speakers emphasised the role of European-level frameworks — such as the EU Anti-SLAPP Directive and Council of Europe recommendations, in particular the Recommendation CM/Rec(2024)2 on countering the use of SLAPPs — but warned that without meaningful domestic implementation these instruments risk remaining symbolic. To strengthen monitoring, they called on EIN and its partners to establish an alert system to track pending cases and identify new threats early on.
By showcasing the “middle-ground” jurisdictions of Croatia, Greece, Poland, Italy, and Slovakia, where reforms have been stalling or have only partially taken hold, the panel underscored that Strasbourg judgments alone cannot drive reform. Implementation remains fragile unless reinforced by persistent advocacy, cross-border solidarity, and strategic communication. This framing echoed the keynote’s central message: progress depends not only on legal victories but also on sustained mobilisation to translate those victories into democratic renewal.
This session reframed SLAPPs as not merely an individual legal tactic but a structural impediment to democratic oversight and Strasbourg compliance. The interventions by Ivan, Aspasia, Zuzanna and Maksym offered a granular look at how NGOs can still push forward: data collection, joint submissions, training of judges and building public awareness to reduce the chilling effect and strengthen the rule of law.

Panel 3 – Persistent Stumbling Blocks: Overcoming Legal and Political Resistance to ECtHR Implementation

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This panel shifted the focus to jurisdictions where legal and political resistance to ECtHR free expression judgments remains entrenched, constituting one aspect only of these jurisdictions’ strategic backtrack on international democratic and human rights standards. Moderated by the EIN director, the discussion featured an analysis of national contexts in Türkiye, Azerbaijan, Hungary, and Georgia. Speakers described how restrictive laws, weak institutions, reprisals against rights defenders and ever-changing legislative agendas weave together repression of free speech with other illiberal policies, thus impeding effective implementation of free-speech judgments even when formal reforms exist.

Opening with a focus on Türkiye’s oscillation between engagement and defiance, panelists underscored that broad terrorism definitions and revived dormant laws target journalists, lawyers and activists, weaponising repression of free speech to silence critical opinions. At the same time, nominal reforms on free-speech matters — while landmark relevant judgments remain flagrantly disregarded — seek to manipulate and undermine the implementation mechanism. Spotlighting Azerbaijan, the member State currently presenting the gravest non-implementation resistance and overall defiance of CoE standards, another panelist stressed the consequences of structural repression (resulting in an extremely effective crackdown on civil society), and the importance of persistent Rule 9 submissions to maintain international attention on the plight of journalists and human rights defenders. Furthermore, a reflection on Hungary’s entrenched political control over media and the judiciary showcased how deliberate illiberal governance goes hand in hand with grave resistance to the ECtHR authority, including on free-speech matters, thus undermining Strasbourg standards. Finally, addressing Georgia’s mixed record, speakers noted that a country’s previous track record of incremental reforms cannot guarantee adherence to the jurisdiction’s democratic path, highlighting the rapidly emerging grave risks for ordinary citizens and human rights defenders alike, especially around public protests and judicial independence.

Across all four examples, panelists converged on three main barriers to free expression, among other indications of a country’s democratic standing: vague or regressive laws, lack of independent judiciaries, and political hostility towards oversight. They underscored the need for multi-level advocacy, combining international mechanisms, cross-border partnerships, and grassroots support to protect defenders and journalists. The session concluded that implementation in these contexts cannot be a purely legal process, but must be a sustained political struggle requiring long-term solidarity.

Unlike the earlier panels, which had highlighted elements of success and stalled reforms in specific policy areas relating to free speech, Panel 3’s discussion focused on the jurisdictions presenting the greatest challenges to the Convention system. There, freedom of expression violations are not an isolated instance of non-Convention-compliant legislation or practice and go beyond a SLAPPs culture; they are rather one of the symptoms of overall ailing democracies and of rule of law that has been compromised, but also a weapon in the hands of illiberal jurisdictions in the effort to further erode these fundamental values. The cases concerning the jurisdictions under review — Türkiye, Azerbaijan, Georgia, and Hungary — demonstrated how systemic authoritarian practices not only persistently block ECtHR implementation of free-speech judgments, too, but also weaponise legal and political tools against free speech to entrench repression.
İdil Özcan, Lawyer & Project Officer at the Truth Justice Memory Center (Hafiza Merkezi) opened Panel 3 by describing Türkiye as a country oscillating between implementation fatigue and legislative regression. She recalled that, in the early 2000s, under EU accession-related pressure, legislation was amended to align with Strasbourg jurisprudence. Yet, these reforms proved superficial or counter-productive in the long run: Vague and overly broad provisions were retained and are now used extensively to criminalise dissent. Terrorism-related offences dominate, with nearly a quarter of expression cases based on charges of “propaganda for a terrorist organisation” or “membership.” İdil noted that laws once dormant in the 1990s have been revived to target journalists and lawyers, while new risks are emerging, including a draft “agents of influence” law and anti-LGBTI legislation intended to criminalise gender identity expression. İdil argued that Türkiye treats compliance transactionally, weighing costs and benefits: She emphasised, in particular, that the state maintains close procedural engagement with the Council of Europe — submitting action plans, responding to Rule 9 submissions, and attending meetings — yet offers misleading information and enacts superficial reforms. The Kavala and Demirtaş cases best illustrate this pattern: Despite repeated violation findings and infringement proceedings in the context of an already extremely escalated implementation process, both applicants remain imprisoned, in flagrant violation of Türkiye’s Art. 46 obligations. For her, raising the stakes for non-compliance is essential. Civil society’s role lies in making the best use possible of the limited international space that exists — through Rule 9 submissions, briefings, and coalition-building — to keep violations and such manipulative tactics visible and to gain some protective leverage.
Ramute Remezaite took the floor once more, to discuss another jurisdiction this time. She described Azerbaijan as the Council of Europe’s most resistant member currently, where non-compliance and repression are systemic and deliberate. She recalled that nearly all judgments pending implementation involve some kind of suppression of free speech, and that civil society is the only actor pressing for implementation of the judgments concerned. Yet, restrictive association laws, arbitrary prosecutions and asset freezes persist, undermining NGOs’ capacity to operate. She noted that Rule 9 submissions remain the sole avenue for engagement, as no domestic dialogue with the authorities exists. But even these interactions are increasingly perfunctory, with government reports providing procedural updates rather than substantive reforms. Ramute drew attention to the 2014 crackdown on civil society and journalists, which generated important Strasbourg rulings in the Mammadli group of cases. Persistent failures to enforce these judgments directly enabled the renewed repression of 2023, when journalists and defenders received heavy prison sentences. She stressed that the absence of consequences for this defiance allows the authorities to continue on the patth of repression, and called for clear and consistent pressure from all Council of Europe bodies. Supporting the few remaining domestic human rights defenders is urgent, both for their survival and for the CoE’s own credibility. Without decisive action, Azerbaijan risks following on the steps repeating the trajectory of Russia, where delayed responses resulted in total disengagement.
Anna Gelencsér, Legal Officer at the Hungarian Helsinki Committee, and Léna Perczel, Legal Officer for the Political Freedoms Program at Hungarian Civil Liberties Union (HCLU) described Hungary’s deliberate erosion of democratic checks under Fidesz’s two-thirds majority. Hungary has the EU’s highest rate of non-compliance with ECtHR judgments (76%). This is not due to capacity constraints but to lack of political will, with the government even budgeting to pay EU fines rather than complying with rulings. They highlighted four emblematic cases: Kenedi v. Hungary (2009), concerning access to secret service archives, remains unimplemented more than a decade later. Magyar Helsinki Bizottsag v. Hungary (2016) established at the Grand Chamber level that freedom of information falls within Article 10, yet loopholes continue to allow police to deny data requests. Szurovecz v. Hungary (2020), on journalists’ access to refugee camps, has not been implemented despite the authorities’ argument to the opposite eff ect, and reporters are still barred from press events or eviction sites. ATV ZRT v. Hungary (2020) found a violation where a broadcaster was sanctioned for calling Jobbik “far-right,” yet the Media Act enabling censorship remains unchanged. Although Rule 9 submissions have prevented premature closure in several of these cases, systemic reforms are blocked. Media capture, surveillance of journalists, and vilification of NGOs as “foreign agents” further weaken resistance. Anna and Léna stressed that advocacy must remain internationally visible to shield domestic actors and ensure that Strasbourg standards remain on the agenda, even if compliance at national level is absent.
Tamazi Kirtava, Project Coordinator at the Georgian Young Lawyers Association (GYLA) traced Georgia’s abrupt and sharp democratic backsliding. While earlier judgments had prompted incremental reforms, the government has, since 2023, passed legislation modelled on Russia’s “foreign agents” law. Despite mass protests that initially forced withdrawal, the bill was reintroduced and passed, accompanied by violent dispersals of protesters. The crackdown escalated in November 2023, when the Prime Minister announced the suspension of EU negotiations. New legislative measures sharply curtail freedoms, while media is targeted through restrictions on foreign funding, vague “fairness” rules on content, and a proposed defamation law facilitating SLAPPs. Access to court proceedings is also being curtailed, with proposals to shift decisions on closure to the politicised High Council of Justice. Civil society organisations face invasive reporting requirements, including disclosure of sensitive beneficiary data, under threat of imprisonment for non-compliance. Tamazi painted an utterly grim and concerning picture, warning that Georgia is already experiencing realities similar to those once described in Ecodefence and Others v. Russia. Civil society’s ability to litigate or monitor implementation is rapidly eroding. While space for mobilisation still exists, authoritarian consolidation is advancing fast, and international actors must respond decisively to avoid losing Georgia as they lost Russia.
Speakers identified a set of recurring obstacles across the most resistant jurisdictions. Governments exploit vague, regressive, or even revived laws to sidestep Strasbourg standards, while weak or politicised judiciaries — including higher courts setting problematic precedents — prevent consistent application of these standards. Human rights defenders face systematic reprisals — from smear campaigns to financial restrictions and arrests — that erode their capacity to advocate effectively. Constantly shifting legislative agendas further complicate monitoring, creating moving targets that make it difficult to measure compliance.
Despite these challenges, panelists pointed to strategies that sustain pressure. Meticulous documentation of violations can support Rule 9 submissions and international reporting, while cross-border coalitions amplify visibility and allow learning from advocacy strategies that have worked in other jurisdictions. Simultaneous engagement with the Council of Europe, UN, and EU increases leverage and reduces dependence on any single mechanism. Crucially, framing freedom of expression within a wider democratic agenda — linking it to judicial independence, minority rights, or anti-corruption — helps broaden support bases.
The panel concluded that, in such repressive environments, resistance to implementation must be understood as a deliberate choice and a conscious and calculated political strategy, not failings in a technical exercise. It requires long-term engagement and solidarity: financial support for NGOs, legal defence for journalists, and proactive media outreach to counter official narratives. Only by embedding freedom of expression within a wider struggle for democratic renewal can Strasbourg judgments be meaningfully defended.
By weaving together the current state of play in Türkiye, Azerbaijan, Hungary and Georgia, this panel illustrated how entrenched resistance transforms ECtHR judgments from instruments of reform to contested political terrain. Yet, as the speakers demonstrated, civil society actors are not powerless: persistent, coordinated and evidence-based advocacy can still delay regressions, secure incremental gains and help uphold the prevalence of freedom of expression as a European norm.

Panel 4 – Beyond Slander: Competing or Intersecting Challenges

Panel 4 shifted focus from entrenched SLAPP practices to emerging and intersecting challenges at the boundaries of freedom of expression. The session focused on relevant experiences from Italy, France, Slovakia, Bulgaria, and Hungary. Drawing on the context of various national cases, panelists addressed how ECtHR case-law balances freedom of expression against other fundamental rights and values — such as judicial independence, media pluralism, national security and public order — and how these balances influence domestic implementation.

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Italy’s lack of institutional engagement despite two strategic Rule 9 communications was discussed at the opening of the panel, pointing to the country’s deeper reluctance to accept Strasbourg jurisprudence. Subsequent panelists reflected on how the ECtHR navigates its obligations to uphold freedom of speech amid important considerations concerning national security in France. Furthermore, Slovakia’s paradox of a strong legal framework coexisting with the political instrumentalisation of human rights language by far-right actors was examined alongside Bulgaria’s case-law on the intersection between judicial independence and freedom of expression. The last panelist further expanded on Hungary’s Baka case, illustrating how political backlash can neutralise ECtHR judgments seeking to protect judges’ free speech.

Together, the panelists painted a picture of multiple but converging challenges: when freedom of expression overlaps with other rights or values, implementation becomes more politically charged and less predictable. They called for a nuanced, cross-country approach, sustained monitoring and broader coalitions to defend journalists, judges and activists caught in these intersections.

Camilla Prunas-Tola & Federico Camurati, lawyers representing StraLi for Strategic Litigation, described challenges present in the Italian contecxt: lack of progress, the Italian colleagues argued, is less about direct repression and more about institutional inertia. Together with CILD, StraLi prepared two Rule 9 communications, which eventually received no meaningful response from national authorities. The speakers therefore concluded that isolated NGO interventions are insufficient: Rule 9 submissions should be coordinated and ideally submitted collectively by multiple organisations to give them more political weight. Building on this point, Federico expanded on the Associazione Politica Nazionale Marco Pannella v. Italy case, which concerned the exclusion of the political association from the public broadcaster’s coverage. Domestic courts eventually acknowledged the violation but provided partial remedies, and the ECtHR confirmed that Article 10 had been breached. Yet, this has still not resulted in any reforms. StraLi’s Rule 9 submission urged the Committee of Ministers to press Italy for an action plan, noting that broadcaster governance remains closely tied to parliamentary majorities. The panelists argued that broader reforms — such as a registry of SLAPPs, early dismissal mechanisms, cost-shifting sanctions, and legal aid for defendants — remain unaddressed, demonstrating how even detailed submissions and national advocacy cannot overcome entrenched passivity without sustained, collective pressure.
Radoslav Stoyanov, Co-Chair of the Bulgarian Helsinki Committee (BHC) presented Bulgaria’s Miroslava Todorova v. Bulgaria case as emblematic in the intersection between judicial independence and freedom of expression. Todorova, a prominent criminal judge and president of the Bulgarian Judges Union, was sanctioned and demoted after criticising the Minister of Interior. The ECtHR ruled in 2021 that her punishment violated Article 10, stressing that judges who speak up on matters of public interest deserve heightened protection. Implementation, however, has been faced with resistance. The government initially sought closure of the supervision, claiming that compensation was sufficient and the violation isolated. Civil society intervened with successive Rule 9 submissions, tying Todorova’s case to broader issues of judicial capture, including the powers of the Chief Prosecutor and the composition of the Supreme Judicial Council. These submissions pointed to additional disciplinary abuses and stalled reforms. In June 2025, the Committee of Ministers accepted this framing, refused closure, and placed the case under enhanced supervision, urging Bulgaria to adopt structural guarantees such as increasing the proportion of judges elected by their peers in the Council. For Radoslav, the case demonstrates both the vulnerability of judges who speak up and the potential of sustained advocacy to reframe individual violations as systemic.
Anna Gelencsér, Legal Officer at the Hungarian Helsinki Committee then turned to Hungary, where the Baka v. Hungary judgment remains one of the longest-standing examples of non-implementation. Former Supreme Court President András Baka was dismissed after criticising judicial reforms, and in 2016 the ECtHR found violations of Articles 6 and 10. Yet, nine years later, there are still no legal protections for judges against political dismissal, and Anna stressed that reprisals have continued. Recent judicial protests against new structural reforms — where salary increases were tied to measures undermining independence — show signs of resistance, but the chilling effect endures. For Anna, the Hungarian case demonstrates how political backlash and legislative manoeuvres can neutralise even clear Strasbourg rulings, making international solidarity and vigilant monitoring indispensable.
Following up, Maroš Matiaško, lawyer & Senior Human Rights Consultant at the Forum for Human Rights, turned to the paradox of Slovakia’s legal framework. On paper, there is a robust framework against hate speech and defamation, but in practice, hate speech is weaponised even by the highest instances of political authority to stifle investigative journalism and fuel smear campaigns against journalists and judges. High-profile political figures — notably from the far-right — cast themselves as free speech martyrs, invoking Article 10 to shield hate speech or harassment. This instrumentalisation of rights complicates advocacy, as the very language of Strasbourg jurisprudence is turned against defenders and contributes to shrinking the civic space. Maroš also highlighted that egislative initiatives to restructure the media board — shifting from collective to individual control — and to create special courts enhancing the legal avenues for politicians to harass voices of dissent are presented as efforts at compliance with European norms while in reality consolidating intrusive executive power. In fact, such reforms would place more power in the hands of political majorities. These developments, he warned, illustrate how governments can reshape institutional frameworks under the guise of protecting expression, while in fact consolidating control and undermining pluralism. He concluded that Slovakia stands at a crossroads. Although no Strasbourg judgment yet addresses these practices, domestic litigation is ongoing. Civil society therefore needs stronger transnational platforms to share Rule 9 submissions, coordinate strategies, and prevent authoritarian governments from learning abusive tactics from one another.
Finally, Vincent Lefebvre, Co-Chair and Legal Compliance Director at Generation for Rights Over the World (GROW), illustrated examples of difficult balancing exercises when the protection of freedom of expression intersects with national security and public order concerns. Drawing on ECtHR jurisprudence in France, he examined the Rouillan v. France case – which concerns the disproportionate sentence imposed on the applicant in 2017 following his praise of the perpetrators of the terrorist attacks committed in November 2015, broadcasted on the radio and then on the internet in 2016 — situating the stalled implementation of the case in France’s securitarian trajectory and shrinking civic space. Underscoring that a 2014 amendment moved apology of terrorism offences from press law into the Penal Code, Vincent conveyed information about a drastic increase in the number of relevant convictions: only 14 between 1994–2014, against 332 in 2015 and 495 in 2016. Furthermore, he noted that the trend intensified after October 2023, when the then Minister of Justice instructed prosecutors to clamp down on any speech deemed to legitimise terrorism. Since then, bans on pro-Palestinian demonstrations and prosecutions of political figures, union leaders, academics, and activists have proliferated. In conclusion, he stressed that framing is crucial: if such cases are reduced to technical compliance, states can evade reforms under the guise of security imperatives. Instead, civil society must present them as core democratic questions, ensuring that Strasbourg’s balancing exercises are not distorted domestically to legitimise unlawful restrictions, beyond what is strictly necessary to appease and address security concerns.
The panel highlighted several recurring challenges. Freedom of expression under Article 10 frequently intersects with other democratic values, requiring delicate ECtHR balancing exercises that domestic authorities often exploit to delay or dilute implementation. In some jurisdictions, political actors instrumentalise human rights rhetoric — invoking “free speech” to defend hate speech or discredit journalists — thereby complicating advocacy. Deficits in media pluralism further exacerbate the problem: without diverse and independent outlets, public understanding of these complex legal issues remains limited, making it harder to mobilise support for reform.
In response, the panelists outlined strategies to reinforce implementation. They stressed that one-off communications are insufficient: regular Rule 9 submissions, ideally presented by larger NGO coalitions, are necessary to sustain pressure. Strategic framing is equally important, linking freedom of expression with judicial independence, media pluralism, and anti-corruption efforts to broaden alliances and make the stakes more visible. International monitoring mechanisms — both Council of Europe and EU-based — must be leveraged to keep cases and relevant policy areas high up on the agenda. Finally, capacity-building for judges, journalists, and NGOs is vital to ensure Strasbourg standards are understood and applied in cases where rights intersect.
By examining Italy, France, Slovakia, Bulgaria and Hungary through this lens, the panel revealed how intersecting challenges amplify political resistance and complicate the implementation of ECtHR judgments. Beyond this, the speakers also demonstrated that targeted strategies — from persistent submissions to broader coalitions — can counter this resistance. The session thus extended the conference’s central theme: implementation is not only about technical compliance but about sustaining democratic principles in the face of increasingly complex challenges and intersecting global values.

Dialogue on the Implementation of Free-Speech-Related Judgments in Russia and How to Move Forward

Media freedom and free expression in Russia have suffered a severe decline over the past decade, a reality that predated Russia’s 2022 expulsion from the Council of Europe and has only worsened since. Successive waves of repressive laws, from “foreign agent” regulations to extrajudicial internet censorship, have steadily and efficiently choked independent media and dissent. Even before Russia’s expulsion, the Committee of Ministers of the Council of Europe struggled to enforce compliance, as Russian authorities showed defiance towards implementation of ECtHR judgments.

This dialogue, featuring Council of Europe and civil ociety stakeholders, provided a candid and sobering discussion of the consequences of Russia’s expulsion from the Council of Europe for the implementation of ECtHR judgments, notably on freedom of expression. Speakers reflected on the legacy of Strasbourg jurisprudence in Russia, the ongoing risks faced by journalists and civil society, and possible avenues for maintaining international engagement. Discussing the status of free-speech-related judgments against Russia still pending before the Committee of Ministers, speakers noted that while the Russian authorities have ceased engaging with the implementation mechanism and formal execution procedures have ground to a halt, the judgments retain their binding character, remain part of international law and can still be invoked by domestic actors and in third states. In this context, speakers recalled the day-to-day reality for Russian media lawyers and journalists — including criminalisation of dissent, “foreign agent” labelling and the near-total closure of independent outlets — and highlighted how the ECtHR’s case-law remains a crucial reference point for exiled or underground practitioners.

A key takeaway from the dialogue was the emphasis on the continuation of international solidarity and documentation, even in the current hopefully temporary absence of an effective implementation mechanism when it comes to Russia. Speakers called for coordinated efforts by European civil society and institutions to keep Russian cases visible, support exiled media, and maintain the legal memory of Strasbourg standards.

Implementing ECtHR rulings on free speech was an uphill battle even when Russia was still part of the Convention system. The authorities often paid just satisfaction to victims but refused deeper reforms, avoiding changes to laws or practices highlighted by the Court. By 2010, a growing backlog of unimplemented cases had emerged, including judgments on politically sensitive issues like media censorship and the “foreign agents” crackdown. Many of these systemic problems remained unresolved when Russia was expelled in 2022.
Speakers began by outlining the status of ECtHR judgments against Russia following its expulsion from the Council of Europe. Post-expulsion, compliance with the Court’s judgments deteriorated further. Moscow ceased cooperating with the Committee of Ministers and even passed a law refusing to execute any judgments issued after March 2022 and criminalising any cooperation with international mechanisms Russia is not a member of. While in theory Russian law still acknowledges pre-2022 judgments, there is no political will to drive their implementation forward. Domestic courts offer no redress either, given the lack of judicial independence under current conditions. This leaves victims of rights’ violations with no hope for justice unless there is a major political change.
Despite these bleak circumstances, Russian human rights defenders and lawyers, many now exiled, underground or defunded, continue to document abuses and to seek accountability. In the two years since Russia’s expulsion, they have filed 48 Rule 9 submissions to the Council of Europe’s Committee of Ministers, reporting on Russia’s non-compliance with human rights judgments. While the execution procedure under the Committee of Ministers is formally stalled in the absence of any meaningful engagement from the Russian authorities, hundreds of free-speech-related judgments remain outstanding. These judgments retain their legal value:
- Their binding character under Article 46 of the Convention remains unaffected for violations that occurred before Russia’s expulsion.
- They can be invoked by Russian lawyers before the domestic courts to argue for Convention-compatible interpretations.
- They serve as authoritative guidance for third countries and international bodies documenting abuses.
- They remain relevant for the Council of Europe to monitor developments and maintain a record for future accountability mechanisms.
The discussion then offerred a first-hand account of the risks faced by journalists and lawyers in Russia. Speakers described how “foreign agent” laws, “undesirable organisations” lists and new wartime censorship provisions have virtually eliminated independent media inside Russia. Many journalists are now in exile; those who remain risk criminal prosecution for basic reporting. Even in exile, Russian journalists rely on ECtHR case-law as a normative benchmark and as part of their legal strategy when publishing in or about Russia.
Speakers converged on several challenges:
- Loss of formal enforcement mechanisms: Without the Committee of Ministers’ supervision, judgments risk being forgotten. Against this backdrop, the role played by civil society in documenting the continuation of human rights violations identified by a EctHR judgment is crucial.
- Shrinking civic space: Lawyers and NGOs inside Russia face criminalisation and surveillance, making documentation dangerous.
- Exile and fragmentation: The Russian independent media and civil society actors are now dispersed across multiple countries, which complicates coordination.
- Narrative control: State propaganda frames ECtHR judgments as politically motivated, contributing to further eroding the domestic legitimacy of the Convention.
Despite the sobering account, the discussion evidenced practical steps to be taken to overcome these challenges. Russia’s expulsion underscores the need for resilient mechanisms to continue to uphold judgments even in the extreme scenation of expulsion or withdrawal from the Convention. Maintaining the legal memory of Strasbourg standards can serve as a bridge for future democratic transition. Speakers agreed that silence or disengagement would effectively validate repression; instead, persistent visibility can protect individuals and keep options open for the future, despite the danger that this entails.
Looking forward, the discussion highlighted the importance of maintaining engagement through a holistic approach that integrates several strategies, including:
- Archiving and documentation: Ensuring all pending cases and judgments are preserved for future accountability.
- Supporting exiled media and NGOs: Providing legal, financial and technical assistance for exiled Russian civil society to continue monitoring and reporting and keeping their voices included in global discussions.
- International advocacy: Continued advocacy, through submissions to international monitoring bodies, engagement with UN special procedures, and public campaigns, is vital to maintain pressure on Russian authorities.
- Knowledge transfer: Training new cohorts of Russian lawyers and journalists in exile on Strasbourg standards.
The dialogue ended by framing the current moment as not the end but a transition. While the classic implementation process before the Committee of Ministers has been neutralised as a result of Russia’s negation of its international obligations, tools remain accessible to civil society and institutional stakeholders to retain the value of Strasbourg standards as a legal compass and advocacy tool. The dialogue thus echoed the conference’s overall message: implementation is ultimately about sustaining norms and solidarity, even in the most adverse circumstances.

Panel 5 – Communicating for Public Mobilisation: The Role of the Media in Supporting ECtHR Implementation

Panel 5 tackled a paradox at the heart of the conference: although ECtHR free-expression judgments directly affect the press and public debate, their implementation rarely becomes a news story. The discussion zeroed in on how media and communication strategies can transform legal findings into catalysts for public pressure, political accountability and long-term reform. Drawing on the perspectives of journalists, expert communicators and civil society experts, the panel examined why implementation receives little journalistic attention, how under-resourced media sectors across Europe struggle to follow complex legal developments, and what can be done to translate Strasbourg judgments into compelling stories for the public.

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Speakers discussed structural obstacles such as a lack of legal training among journalists, scarce resources, and rapidly shifting news cycles, which make implementation appear less appealing to editors. They also highlighted examples of how investigative reporting, when paired with strategic advocacy, can influence policy reforms, and underscored the importance of legal clarity, institutional transparency, and strategic framing to enable stronger media engagement.

Across the discussion, there was a consensus that media coverage can put pressure on governments to act on judgments, protect NGOs and journalists from retaliation, and build public support for pushing for the adoption of reforms. Participants called for closer cooperation between civil society and the media — including training for journalists on ECtHR case-law, joint communication campaigns, and framing stories around human impact rather than technical details — positioning communication as a central pillar of effective implementation.

Opening the panel, Neus Vidal Marti, Executive Director of the Seek Initiative, offered a candid assessment of why implementation is not appealing to journalists. Implementation processes lack the appeal and immediacy of initial court rulings; they unfold slowly, rarely provide a neat resolution, and are buried in legal detail. Neus highlighted that across Europe, underfunded and understaffed newsrooms, especially in Eastern and Southern Europe, often cannot dedicate time or personnel to follow-up reporting. She also stressed that many reporters lack formal legal training, making ECtHR jurisprudence difficult to interpret or translate for a general audience. As a result, most outlets cover a case at the moment of judgment and then stop focusing on it, leaving implementation to proceed in obscurity. Neus also pointed to other factors for lack of implementation visibility, such as poor communication from authorities, absence of press-friendly summaries, and in some countries, political or legal risks to journalists who dig into sensitive reforms.
The panel agreed with Neus’s warning that this invisibility undermines accountability. Without public scrutiny, governments do not feel compelled to comply with Strasbourg rulings, and NGOs or journalists who push for reform receive less protection. Panelists therefore framed better communication not as an “optional extra” but as a central pillar of effective implementation.
Delving into his experience as a journalist in Romania, and a beneficiary of EIN’s freedom of expression project, Marian Chiriac illustrated how sustained media coverage can become a catalyst for change. By consistently tracking freedom-of-expression judgments and their aftermath, investigative reporters created a feedback loop: public exposure pressured politicians, while public interest shielded journalists and NGOs from retaliation. Marian showed that presenting clear metrics gave editors a hook; pairing statistics with human stories generated empathy and engagement. He found that adding an investigative twist — probing why implementation was delayed and who benefited — transformed a dry compliance update into an accountability narrative.
Adding an institutional perspective, Michael O’Neill, Head of Legal at the Irish Human Rights and Equality Commission (IHREC), underscored that governments and national human rights bodies can themselves make coverage easier. When authorities publish clear action plans, timelines and accessible press materials, journalists are far more likely to report meaningfully and hold them to account. He noted that national human rights institutions can act as translators between Strasbourg and the public, issuing plain-language summaries, briefs, and ready-to-use quotes that journalists can plug into stories. Building on IHREC’s successful media outreach strategy in the context of advocating for the implementation of the O’Keeffe v. Ireland case, he encouraged NGOs and public bodies alike to invest in such media-friendly outputs and to tie them to news cycles, for example linking an ECtHR judgment to a domestic controversy or a global awareness day.
Beyond clarity, Philip Doyle, Co-Founder of One Step Beyond, stressed the importance of framing. Technical legal victories rarely inspire public mobilisation, but presenting them as part of a larger struggle for justice and democratic renewal can. Philip encouraged NGOs to collaborate with creative professionals to highlight how ECtHR judgments improve people’s daily lives — safer conditions for journalists, more transparent institutions, less censorship. This “hope-based” approach, he argued, emphasises achievable benefits rather than only failures, countering audience fatigue and cynicism. Framing implementation as an opportunity makes compliance aspirational and relatable.
Philip also highlighted the need to diversify communication channels. Traditional media remains crucial for influencing policymakers, but younger audiences and niche communities can be reached through podcasts, influencers, legal bloggers or YouTubers who translate complex issues into accessible formats. Marian reinforced this point, describing how he used Facebook groups and short videos to extend reach beyond his newspaper’s readership. The future of implementation advocacy, they concluded, depends on using both established and emerging platforms to keep stories alive.
Throughout the discussion, several practical lessons emerged:
- Humanise the story: frame implementation not as bureaucratic compliance but as tangible changes affecting communities and individuals.
- Provide context and clarity: offer journalists plain-language explanations, visuals and relatable examples to lower the barrier to entry.
- Build relationships: engage editors and reporters early, not only when a judgment is handed down; treat journalists as partners rather than last-minute recipients of press releases.
- Joint training: bring journalists, lawyers and NGOs together for co-learning sessions on Strasbourg standards, making everyone more confident in handling legal content.
- Use multimedia: infographics, podcasts, videos and social media snippets can make complex legal issues accessible and shareable.
Panelists also suggested creating public databases or dashboards showing each country’s implementation record on free-expression judgments, providing a transparent scoreboard that journalists, activists and citizens can consult at a glance. Such tools could inject steady public pressure, making it harder for governments to avoid their obligations.
The discussion repeatedly returned to the stakes: media coverage can put pressure on governments to comply, protect NGOs and journalists from retaliation, and mobilise public support for reforms. Without public awareness, ECtHR judgments risk being treated as obscure technicalities. A well-informed media ecosystem can complete the “virtuous cycle” — amplifying a judgment, sparking public interest, prompting political action, and then reporting on successful implementation.
Panel 5 thus reframed communication as an essential component of democratic accountability. Rather than relying on sporadic press releases, civil society and media should build ongoing partnerships around monitoring and storytelling. This includes NGOs thinking like journalists — crafting accountability angles, identifying newsworthy data points, and offering human stories — and journalists viewing NGOs and NHRIs as reliable sources and collaborators.
By blending practitioners’ experience, institutional perspective and strategic communication insight, the panel produced a blueprint for energising public engagement with ECtHR implementation: simplify without oversimplifying, leverage data and rankings, maintain a hopeful tone, diversify communication channels, and invest in relationships. The panel also demonstrated how these efforts dovetail with the themes of the closing session on maintaining long-term momentum: strong communication strategies are integral to sustaining advocacy over time.

Panel 6 – Maintaining Momentum: Future Strategies for Long-term Impact and Synergies

The final panel drew the conference’s threads together, focusing on how to sustain and scale up, through effective synergies, the progress achieved throughout the duration of the project. The discussion featured representatives from the Council of Europe Division for Cooperation on Freedom of Expression, the Greek National Commission for Human Rights and the European Network of National Human Rights Institutions (ENNHRI), who underscored that lasting impact requires synergies between national, regional and international actors, secure funding for civil society, and the institutionalisation of good practices.

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The discussion highlighted the Council of Europe’s standard-setting and cooperation work — including initiatives on disinformation, SLAPPs, and journalists’ safety — illustrating how these instruments can anchor important reforms in national jurisdictions. It also underscored the importance of strong national human rights institutions (NHRIs) in translating international standards into domestic policies, while stressing the value of cross-border NHRI cooperation to reinforce implementation where national institutions are weak and their independence is under political pressure.

Further discussions focused on capacity building, knowledge sharing and multi-stakeholder approaches, with an emphasis placed on linking ECtHR implementation to broader democratic and rule-of-law frameworks. Participants noted that momentum depends on embedding implementation mechanisms into institutional practice, engaging new stakeholders, and maintaining pressure through international visibility. The session concluded on a forward-looking note, calling for a “pulling effect”, in the words of EIN Director, Ioulietta Bisiouli, of collaborating actors and the combined use of a wealth of resources, to effectively protect free expression amid rising illiberalism.

Evangelia Vasalou, Project Officer at the Division for Co-operation on Freedom of Expression of the Council of Europe set the stage by underlining the organisation’s central role in standard-setting and cooperation on freedom of expression. She recalled the 2023 Reykjavík Declaration reaffirming democratic resilience, and described how her division helps member States align laws and practices with CoE standards, including supporting the implementation of EctHR judgments. She then presented several key instruments – including the Guidance Note on Countering Online Disinformation, the Recommendation of the Committee of Ministers on countering the use of SLAPPs, and forthcoming texts on AI and freedom of expression as well as on the safety of online content creators and users. Alongside these, initiatives such as the Journalists Matter campaign and the Council of Europe Platform for the Safety of Journalists provide monitoring and pressure mechanisms that can support reforms. Crucially, Evangelia stressed that these tools only achieve impact when civil society and national institutions actively engage with them, moving beyond project work to sustained institutional practice.
Building on the project’s legacy, she announced that the Council of Europe intends to weave these lessons into its future programming. For instance, under its new action plan on media freedom, the Council of Europe plans to keep convening multi-stakeholder meetings and explore creating a freedom-of-expression implementation hub to track progress across countries. Evangelia also referred to the idea of a standing forum or panel to review implementation annually, offering a permanent platform for exchange and accountability.
Christos Tsevas, Human Rights Officer at the National Commission for Human Rights of the Hellenic Republic, stressed the pivotal role of NHRIs in translating international standards into domestic reforms. As intermediaries between the ECtHR and national administrations, NHRIs can provide legal expertise, monitor compliance, and act as trusted interlocutors for NGOs, journalists and policymakers alike. Drawing on the Greek experience, he described plans to establish a Freedom of Expression Observatory – a mechanism to systematically follow up on ECtHR and national judgments, maintain public scrutiny and involve Parliament in pushing for implementation. He suggested that similar observatories or “implementation task forces” could be replicated across member States to sustain momentum beyond project cycles, and encouraged formal partnerships between NHRIs, NGOs and international bodies to secure continuity and shared ownership.
Paula Nowek, Human Rights Officer at the European Network of National Human Rights Institutions (ENNHRI), extended the discussion to the regional level, emphasising that cross-border cooperation becomes indispensable where national institutions are weak or subject to political pressure. To maximise the impact of efforts to safeguard freedom of expression, she stressed that collaboration must operate on multiple levels: among NHRIs themselves, between NHRIs and civil society actors, and – crucially – between NHRIs and ENNHRI. In this regard, ENNHRI’s role is to institutionalise exchanges among national institutions, develop thematic working groups, and connect NHRIs with NGOs, human rights defenders, and international mechanisms, on the basis of a shared commitment to defending human rights and fundamental freedoms. Such cooperation allows actors to draw on lessons learned across jurisdictions, adapt strategies to national contexts, and strengthen their credibility before international bodies. Paula also underscored the importance of channelling ECtHR implementation data into parallel processes, such as the EU’s rule-of-law monitoring, so that multiple institutions can concurrently exert pressure on states from different angles.
Across the interventions, a unifying theme emerged: the need to move from ad hoc initiatives to permanent structures. The project’s training on drafting Rule 9 submissions, building media partnerships, and involving NHRIs has created a community of practice. The next step is to institutionalise these practices so that monitoring, reporting and advocacy become routine rather than project-based. This involves bringing in new actors – parliamentarians, media regulators, academics, and tech experts – to broaden the coalition and create a shared knowledge base. Participants also pitched the idea of a central public database or scoreboard on freedom-of-expression judgment implementation to allow journalists, activists and citizens to track progress and sustain pressure.
Funding emerged as a major recurring concern for panelists. Implementation advocacy is vital but often less visible to donors than litigation or emergency aid. The panel called on foundations, EU bodies, and voluntary contributions to view implementation as its own strategic stage of human rights protection. Even small, targeted grants – for example, enabling an NGO coalition to meet quarterly with officials or to run a communications campaign around a judgment’s anniversary – can keep momentum alive. Evangelia noted that while the Council of Europe cannot usually fund NGOs directly, it can amplify their work, include civil society components in its projects, and provide a platform for visibility. Christos and Paula added that networks can foster soft accountability by regularly asking members to report on their actions, creating gentle pressure to not drop the ball.
Panel 6 also underscored the importance of staying ahead of new threats to freedom of expression, particularly digital disinformation and AI-driven manipulation. Building on warnings from the keynote address, speakers urged that ECtHR principles such as transparency and proportionality be applied to future regulations and content moderation practices. Academic partners and technology experts can play a crucial role here by providing evidence and innovative proposals. In this way, “synergy” extends beyond traditional human rights actors to include those on the cutting edge of digital policy.
During the Q&A, participants explored how to keep stakeholders engaged after the project ends. Suggestions included using positive recognition and media coverage to acknowledge officials who are instrumental in the effort to effectively implement judgments, planning news hooks around key dates to keep stories in circulation, and making implementation narratives more human-centred. These tactics can maintain visibility, encourage peer recognition, and create incentives for ongoing engagement.
The closing reflections captured both optimism and realism. Panelists described the project as having run a strong “first lap” of a relay race, with the baton now passed on to a broader network of actors who will continue pushing implementation forward. The idea that there is a need for implementation efforts to be combined to generate pulling effect – in other words, acknowledging that no single actor can claims implementation victories but synergeticd efforts are capable of generating real impact – resonated throughout. In the words of one participant, the project’s most important legacy is a mindset shift: ECtHR judgments are no longer seen as an endpoint but as a call to action.
Panel 6 thus provided a roadmap for the future: embed the practices and networks built over the past two years into permanent structures, strengthen national and cross-border alliances, secure long-term funding, anticipate emerging challenges, and engage the public through strategic communication. Protecting free expression in an increasingly restrictive environment is a long-term endeavour, but the conference demonstrated that tangible progress is achievable when stakeholders unite and persist. The knowledge, partnerships and strategies forged here have equipped the community to carry on the fight stronger than before.

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EIN Freedom of Expression Closing Conference - Implementing ECtHR Free Speech Judgments: Civil Society Impact, Lessons Learned and Future Strategies

Introduction

Keynote Speech – Illiberalism and Growing Threats to Freedom of Expression: Why ECtHR Implementation Matters?

Panel 1 – Advocating Change: Impact and Lessons from Effective ECtHR Implementation

Panel 2 – Halfway There? Navigating Fragmented Impact in SLAPPs-Plagued Jurisdictions

Panel 3 – Persistent Stumbling Blocks: Overcoming Legal and Political Resistance to ECtHR Implementation

Panel 4 – Beyond Slander: Competing or Intersecting Challenges

Dialogue on the Implementation of Free-Speech-Related Judgments in Russia and How to Move Forward

Panel 5 – Communicating for Public Mobilisation: The Role of the Media in Supporting ECtHR Implementation

Panel 6 – Maintaining Momentum: Future Strategies for Long-term Impact and Synergies

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News

Introduction

Keynote Speech – Illiberalism and Growing Threats to Freedom of Expression: Why ECtHR Implementation Matters?

Threats and erosion

Why implementation matters?

Experience from the Balkans and beyond

The role of synergies

Civil society’s leverage

Breaking the diplomatic mould

Strategic outlook

Setting the tone for the conference

Panel 1 – Advocating Change: Impact and Lessons from Effective ECtHR Implementation

Ramute Remezaite on Lithuania

Georgiana Gheorghe on Romania

Cristina Durnea on Moldova

Cross-cutting lessons and strategic outlook

Panel 2 – Halfway There? Navigating Fragmented Impact in SLAPPs-Plagued Jurisdictions

Ivan Novosel on Croatia

Aspasia Theochari on Greece

Zuzanna Nowicka on Poland

Maksym Popovych on Italy and international perspectives

Cross-cutting lessons and strategic outlook

Panel 3 – Persistent Stumbling Blocks: Overcoming Legal and Political Resistance to ECtHR Implementation

İdil Özcan on Türkiye

Ramute Remezaite on Azerbaijan

Anna Gelencsér and Léna Perczel on Hungary

Tamazi Kirtava on Georgia

Cross-cutting lessons and strategic outlook

Panel 4 – Beyond Slander: Competing or Intersecting Challenges

Camilla Prunas-Tola and Federico Camurati on Italy

Radoslav Stoyanov on Bulgaria

Anna Gelencsér on Hungary

Maroš Matiaško on Slovakia

Vincent Lefebvre on France

Cross-cutting lessons and strategic outlook

Dialogue on the Implementation of Free-Speech-Related Judgments in Russia and How to Move Forward

The legal landscape post-expulsion

Reality on the ground

Key challenges identified

Strategies for maintaining engagement

Panel 5 – Communicating for Public Mobilisation: The Role of the Media in Supporting ECtHR Implementation

Why Implementation stays in the shadows?

Lessons from investigative reporting and advocacy

The role of legal clarity and institutional transparency

Crafting hope-based narratives

Cross-cutting recommendations

Why it matters?

Panel 6 – Maintaining Momentum: Future Strategies for Long-term Impact and Synergies

From standards to practice: the Council of Europe’s role

National-level institutional support: the role of NHRIs

Cross-border networks and peer support

Institutionalising practices and expanding coalitions

Resources, visibility and mutual accountability

Adapting to emerging challenges

Maintaining momentum through strategic communication

A relay race, not a finish line

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