{"id":40292,"date":"2026-03-15T12:03:01","date_gmt":"2026-03-15T10:03:01","guid":{"rendered":"https:\/\/afteegypt.org\/?p=40292"},"modified":"2026-03-15T12:03:01","modified_gmt":"2026-03-15T10:03:01","slug":"the-complaints-committee-of-the-supreme-council-for-media-regulation-and-its-restrictive-interventions-on-media-and-digital-expression","status":"publish","type":"post","link":"https:\/\/afteegypt.org\/en\/research-en\/2026\/03\/15\/40292-afteegypt.html","title":{"rendered":"The Complaints Committee of the Supreme Council for Media Regulation and Its Restrictive Interventions on Media and Digital Expression"},"content":{"rendered":"

A research paper by: Rahma Samy<\/strong><\/span><\/p>\n

Content<\/strong><\/p>\n

Methodology
\n<\/strong><\/p>\n

Introduction
\n<\/strong><\/p>\n

First: The legal and institutional framework of the complaints committee <\/strong><\/p>\n

Second: <\/strong>Accusations and violation patterns addressed by the complaints committee<\/strong><\/p>\n

Third: The impact of the complaints committee\u2019s interventions on media freedom and digital expression
\n<\/strong><\/p>\n

Conclusion and recommendations<\/strong><\/p>\n

Methodology<\/strong><\/span><\/p>\n

This paper relied on descriptive analysis of the publicly announced decisions and recommendations of the Complaints Committee of the Supreme Council for Media Regulations from 2021 to 2025 as well on a database that compiles the cases referenced in those decisions, classifying them according to different variations such as the nature of the complaint, the complainant, the type of targeted outlet or platform, the nature of the accusation or offence, the intervention type used, and the outcome of the complaint, which enables the comparison of the different intervention paths. The analysis is based on a sample of 35 publicly documented interventions included in that database.<\/p>\n

The paper also employs legal analysis, grounded in the Media Regulation Law, its executive regulations, and the disciplinary regulation, along with the professional codes and standards issued by the Media Council, which serve as references for defining violations, In addition, the analysis incorporated a comparative assessment against relevant international obligations, most notably Article 19 of the International Covenant on Civil and Political Rights, General Comment No. 34 of the UN Human Rights Committee,\u00a0 and reports by Special Rapporteurs on freedom of opinion and expression concerning the principles of legality, necessity, and proportionality in regulating media and digital content.<\/p>\n

Additionally, the paper employed publicly available statements and press coverage that documented the Media Council\u2019s decisions, the Committee\u2019s recommendations, or incidents of intervention associated with them. The scope of the paper is limited to published data and accessible information. and does not extend to other incidents that have not been publicly published.<\/p>\n

Introduction<\/strong><\/span><\/p>\n

This paper discusses how the Complaints Committee of the Supreme Council for Media Regulation (hereinafter referred to as the Supreme Council) operates as one of the regulatory systems through which the Council exercises its mandate governing the media and digital spheres in Egypt. This is undertaken through an analysis of the Committee\u2019s decisions and publicly announced recommendations during the period from 2021 to 2025. The Committee operates within the organizational structure of the Supreme Council as one of the specialized committees established by the Council through internal regulatory decisions, pursuant to the powers vested in it under the Press and Media Regulation Law and the Supreme Council for Media Regulation Law No. 180 of 2018 (hereinafter referred to as the Media Regulation Law), particularly the authority related to receiving and examining complaints submitted by concerned parties regarding content published or broadcast through media outlets.<\/p>\n

The Complaints Committee is presented in this context as the entity responsible for receiving and examining complaints from concerned parties regarding content published in newspapers or broadcast in media outlets that may harm individuals\u2019 reputations, infringe on their privacy, or involve other violations. Its stated aim is to ensure compliance with professional standards and codes issued by the Supreme Council, thereby seeking to strike a balance between freedom of expression and regulatory requirements.<\/p>\n

However, the Committee\u2019s practical operation, as reflected in its published decisions, indicates a broader scope of intervention. Its role has not remained limited to addressing specific professional complaints; in several cases, it has extended to affecting the availability and circulation of content, the continuity of broadcasting, and the boundaries of media and digital practice. In this context, the paper focuses on three central questions: Which actors are most capable of activating the complaints process and transforming it into a regulatory intervention? What types of content are most frequently subject to the Committee\u2019s interventions? And what disciplinary measures are most commonly applied, such as summonses, content blocking, program suspension, or preventing media appearances?<\/p>\n

By tracing recurring patterns of intervention, the paper seeks to analyze the limits of professional regulation when it evolves into administrative measures that impact media freedom, and the challenges this raises in relation to restrictions on freedom of expression and the right to access information.<\/p>\n

 <\/p>\n

First: The Legal and Institutional Framework of the Complaints Committee<\/strong><\/span><\/p>\n

Analyzing the work of the Complaints Committee of the Supreme Council for Media Regulation requires situating its role within the broader legal framework governing freedom of thought and expression and the regulation of media activity. This framework encompasses international obligations for the protection of freedom of expression, constitutional guarantees, national legislation regulating the media and its executive regulations, as well as professional codes and standards. Together, these elements allow for an assessment of the legitimacy of the Committee\u2019s interventions in regulating media and digital content.<\/p>\n

At the international level, Article 19 of the Universal Declaration of Human Rights affirms the right of every person to freedom of opinion and expression, including the freedom to seek, receive, and impart information and ideas through any media without restriction. Similarly, the International Covenant on Civil and Political Rights stipulates that any restriction on freedom of expression must be based on clear legal provisions, necessary to achieve a legitimate aim, and proportionate to that aim[1]<\/sup><\/a>.<\/p>\n

At the constitutional level, the Egyptian Constitution guarantees freedom of thought, opinion, and expression under Article 65. Article 70 affirms the freedom to issue newspapers and media outlets by mere notification, while Article 71 prohibits censorship, confiscation, suspension, or closure of newspapers. Article 77 further guarantees the independence of professional syndicates and their authority to hold members accountable, thereby establishing a constitutional framework governing any regulatory intervention in media content or accountability of media professionals[2]<\/sup><\/a>.<\/p>\n

At the national legislative level, the Media Regulation Law sets the rules for regulating the media sector.[3]<\/sup><\/a> Its Executive Regulations, issued by Prime Ministerial Decree No. 418 of 2020, establish a set of administrative measures and procedures that may affect the continuity and legal status of media outlets. These measures include suspension of publication, cancellation or suspension of licenses, or the loss of the legal impact of notification in certain cases, as well as the invalidity of legal acts related to ownership or management if undertaken without the prior written approval of the Supreme Council[4]<\/sup><\/a>.<\/p>\n

The law also grants the Council broad discretion in defining professional violations, mandating it to issue \u201ccodes\u201d or \u201cwritten norms\u201d that set professional principles, monitor journalistic and media performance, and assess compliance with these codes, standards, and professional charters issued by relevant syndicates[5]<\/sup><\/a>. The Supreme Council has indeed issued such codes in the form of the Regulations on Professional Standards and Criteria, aimed at ensuring that press and media institutions adhere to professional ethics, respect intellectual property rights related to their content, and comply with the professional rules and standards governing journalistic, media, and advertising performance, as well as established written norms[6]<\/sup><\/a>. The Council has subsequently issued additional amendments and supplements categorized according to the type of content[7]<\/sup><\/a>.<\/p>\n

Notably, the Media Regulation Law does not explicitly establish the Complaints Committee or define its mandate and procedures in detail. Instead, it grants the Supreme Council broad authority to form permanent or temporary committees from among its members or others, without specifying their nature or scope[8]<\/sup><\/a>. In practice, the Complaints Committee functions as one of the mechanisms through which the Council exercises its regulatory role over content. The Council\u2019s official website provides an electronic form for submitting complaints, as a publicly announced procedural channel for communication and reporting[9]<\/sup><\/a>.<\/p>\n

On December 26, 2024, the Supreme Council (chaired by Engineer Khaled Abdel Aziz) issued a decision to reconstitute the Complaints Committee under the chairmanship of Essam El Amir (Deputy Chairman of the Council), with members including: Counselor Abdel Salam El Naggar (Vice President of the State Council), broadcaster Mohamed Nawar, media professional Naela Farouk, Counselor Yasser El Maabdi (Secretary General of the Council), and Counselor Walid Mahmoud. This publicly available information illustrates that the Committee\u2019s formation is determined by internal decisions, reinforcing its character as a body restructured periodically according to the Council\u2019s work cycle[10]<\/sup><\/a>. However, publicly available information about the Committee\u2019s detailed mandate and procedures, such as membership terms, renewal frequency, referral criteria, guarantees of hearing and response, and reasoning of recommendations, remains limited and fragmented. As a result, assessing its human rights impact depends not only on legal texts but also on the degree of procedural transparency provided by the Council from the moment a complaint is submitted until a decision is issued.<\/p>\n

Despite the Supreme Council\u2019s reliance on multiple codes and professional standards, a number of them lack precise procedural definitions or measurable indicators. thereby expanding the scope of discretionary authority when characterizing violations and linking them to such standards, particularly where published decisions do not clearly specify the conduct constituting the violation or the rationale for selecting a particular intervention and assessing its proportionality. This observation is supported by the analysis of a sample of decisions contained in the database prepared for this paper, which included 35 publicly announced instances of intervention.<\/p>\n

The data revealed that a significant portion of these cases were based on general standards or lacked sufficient detail in the published decision to clarify what constituted the violation. Specifically, seven cases described the violation as \u201cunclear,\u201d seven others invoked vague standards, and eight lacked adequate description to understand the grounds for intervention. By contrast, cases that relied on more specific standards provided clearer descriptions of the violation, which directly affects the ability of media and digital actors to anticipate the boundaries of regulatory intervention.<\/p>\n

The Complaints Committee\u2019s scope of work is not limited to complaints submitted by individuals.\u00a0 Multiple pathways trigger its intervention mechanism: the Committee receives complaints from the public and from media professionals, as well as complaints submitted through the Unified Government Complaints System. In addition to internal monitoring through its General Department for Monitoring, it constitutes a significant channel for initiating the Committee\u2019s actions.<\/p>\n

This raises several questions regarding the boundaries between successive stages of the process, beginning with receiving a complaint, its referral, examination, and investigation, and the transparency guarantees surrounding these procedures, through to the final decision taken. It also raises questions as to whether complaints resulting from internal monitoring are subject to the same safeguards applicable to complaints submitted by external parties.<\/p>\n

Concerning appeals against decisions issued on the basis of the Complaints Committee\u2019s recommendations, the Media Regulation Law and the sanctions regulations of the Supreme Council guarantee concerned parties the right to challenge the Council\u2019s decisions and sanctions through two successive pathways: internal grievance, followed by judicial appeal. Article 94 of the Law stipulates in its final paragraph: \u201c<\/em>Concerned parties shall have the right to challenge these sanctions or measures before the Administrative Court. Such a challenge shall not be admissible unless a grievance has first been submitted to the Supreme Council[11]<\/strong><\/sup><\/em><\/a>.\u201d
\n<\/em>
\nIn this context, Article (28) of the Sanctions Regulations governs the right to submit an internal grievance, stating: \u201cConcerned parties may submit a grievance to the Supreme Council for Media Regulation against the sanctions or measures it issues within fifteen days from the date on which they become aware of their issuance. Grievances submitted after this period shall be deemed inadmissible[12]<\/sup><\/a>.\u201d<\/p>\n

Article (29) of the regulation further governs the Grievances Committee, providing that: \u201cA decision shall be issued by the Chairman of the Supreme Council for Media Regulation to form a committee that is responsible for studying the grievances referred to in the previous article, and the committee shall submit a report on the results of this study and the recommendations it concludes with to the Supreme Council for Media Regulation. This committee will be composed of individuals with journalistic, media, and legal expertise, and its members must not be members of the council. And it will have an odd number of members, and its meetings shall be valid with the attendance of a majority of members. Decisions and recommendations shall be adopted by an absolute majority of those present. The committee shall have a technical secretariat, whose formation and operation shall be determined by a decision of the Council\u2019s President. The committee may also consult experts or specialists, who have no voting rights, and may summon the complainant, their legal representative, or anyone connected to the subject of the grievance to provide clarifications, without hearing new facts.\u201d<\/p>\n

While this procedural variation formally satisfies the requirements of administrative regulation, it raises a human-rights concern regarding the independence and effectiveness of the grievance committee’s work. The committee remains an internal and an inseparate entity of the council that imposed the sanction, and its decisions lack sufficient transparency regarding the publication, reasoning, or regular disclosure of the outcomes of submitted grievances. Published judicial records reveal that individuals have submitted appeals, including appeals submitted to the State Council against several Supreme Council decisions related to regulating media content, the most recent of which was a lawsuit challenging the Council\u2019s decision to abolish the segment analysing referee performance in football matches[13]<\/sup><\/a>.<\/p>\n

This issue became more significant with the escalating severity of interventions prescribed by the Law and sanctions regulations in cases of non\u2011compliance or repeated offences. Article 101 of the Media Regulation Law stipulates: \u201cAny editor\u2011in\u2011chief or responsible manager of a newspaper, media outlet, or website who violates Articles 11 or 22 of this Law shall be fined not less than fifty thousand Egyptian pounds and not more than one hundred thousand Egyptian pounds.[14]<\/strong><\/sup><\/a>\u201d<\/em><\/p>\n

Additionally, Articles (5) and (6) of the Sanctions Regulations grant the Council the authority to impose severe penalties. Article (5) stipulates: \u201cThe Supreme Council for Media Regulation may impose the sanction of banning the publication or broadcast of journalistic, media, or advertising material that violates the provisions of the Law or regulations issued pursuant thereto, or decisions issued by the Council, or the professional code of ethics or standards. The ban may be temporary or permanent.\u201d<\/p>\n

Article (6) adds: \u201cIn cases of fraud or deception by a media institution, outlet, or website in rebroadcasting the same offending material that was previously banned under a different title, or attempting to circumvent Council decisions, the media outlet or website deemed to have lost a licensing condition and violated a fundamental provision of its license, This authorizes the Council to suspend or revoke the license, after notifying the violating party of the nature of the violation and granting an appropriate period, not less than one week and not exceeding one month, to correct it. In cases of serious violations or harm to national security, as determined by the Council, it may adopt necessary measures, including blocking the website\u00a0 or temporary suspension of satellite broadcasting licenses, without prejudice to the continuation of other activities such as production, recording, filming, and contractual operations according to the Council\u2019s rules, until satellite broadcasting is resumed.\u201d<\/p>\n

Article (10) of the Sanctions Regulations also stipulates that: \u201cThe Supreme Council for Media Regulation may double the penalty if the same offence is repeated. Decisions issued to impose the penalty shall be taken into consideration when considering the renewal of the license.\u201d<\/p>\n

This regulatory framework places the affected party on a procedural path starting with an enforceable administrative decision, followed by internal grievance procedures, and only then judicial appeal. This process often involves lengthy periods that may not correspond to the immediate impact of sanctions, particularly in cases involving suspension of broadcasting or blocking of content. Furthermore, the continued enforcement of the penalty while a grievance or judicial appeal is pending may practically limit the effectiveness of the appeal, especially when the harm caused by the decision is immediate or difficult to reverse. International standards emphasize that appeals against decisions restricting freedom of expression should not be merely formal; they must be effective, independent, and capable of reviewing the contested decision, or suspending its effects when they conflict with guarantees of media freedom and freedom of expression[15]<\/sup><\/a>.<\/p>\n

\u00a0<\/strong><\/p>\n

\u00a0<\/strong><\/p>\n

Second: Accusations and violation patterns addressed by the complaints committee<\/span><\/p>\n

<\/strong>Monitoring complaints and decisions issued by the Supreme Council’s Complaints Committee during this period reveals a recurring pattern regarding the type of entities capable of effectively transforming submitted complaints into concrete regulatory interventions. According to officially published data, state institutions and bodies with institutional influence, such as ministries and government agencies, as well as non\u2011governmental actors like private companies and streaming platforms, dominate the list of complainants whose submissions have, in a notable number of cases, resulted in clear executive actions. For example, a complaint filed by the Ministry of Finance against several content creators led to a hearing session, while complaints filed by streaming platforms and production companies resulted in recommendations to block websites or content for allegedly violating exclusive broadcasting rights[16]<\/sup><\/a>.\u00a0 By contrast, the same data shows that a number of complaints submitted by individuals or followers across various channels were either dismissed, deemed outside the scope of the committee, or resolved through less restrictive measures, such as requiring the media outlet to publish a reply or clarification. This disparity becomes evident when comparing the complaint process and its outcome, not in terms of the number of complaints filed, but rather in terms of the resulting action.<\/p>\n

Parallel to \u201ccomplainants actors\u2019\u201d inequity, the Committee\u2019s annual statistics reveal disparities in the \u201ctargeted media outlets.\u201d Satellite channels, websites, and digital platforms account for the majority of decisions compared to print newspapers or radio stations, reflecting a focus on television and digital domains given their widespread reach and influence in shaping public opinion. Moving from “who has the authority to initiate intervention” to \u201cwhich is the most targeted media outlet?\u201d, the following section highlights the types of media and content most frequently targeted by the Council based on the Committee\u2019s recommendations.<\/p>\n

Analysis of the Committee\u2019s decisions and recommendations during the period under review shows that its interventions are primarily linked to the nature of the alleged offence attributed to media or digital content. The analyzed cases demonstrate that the committee’s intervention focuses on specific categories of offences, including infringement of intellectual property rights, promotion of activities or products without legal licenses, defamation, incitement and fostering intolerance, and breaches of professional codes and standards governing media work.<\/p>\n

Within the scope of \u200b\u200bintellectual property rights violations, the committee decided, on December 1, 2025, to block several links found to be broadcasting content belonging to the \u201cYango Play\u201d platform without obtaining broadcasting rights[17]<\/sup><\/a>. The analysis also reveals that the committee intervened in cases related to regulating digital advertising and medical content. On May 4, 2025, the committee decided to block several social media pages for promoting medical products and devices without official licenses.<\/p>\n

In another pattern of interventions in the area of sports and digital content, on December 9, 2025, the committee summoned the owner of the Facebook account \u201cKhaled Talaat\u201d to hear his statements regarding a complaint filed by Zamalek Sporting Club against him. Conversely, some cases show that the committee dismisses complaints due to the absence of proven offences. For example, on July 28, 2025, the Committee decided to dismiss a complaint filed by the Musicians Syndicate against a program aired on Al\u2011Nahar channel.<\/p>\n

Taken together, these cases indicate that the type of offence is the key point upon which the committee bases its procedures and determines the appropriate intervention. The data also reveal variations in the clarity of the standards used to define offences, while some decisions rely on specific legal infractions, others are based on broader concepts such as professional standards or societal considerations. Some patterns of intervention can be detailed as follows:<\/p>\n

First Pattern: Blocking and Prohibition of Publication or Broadcasting<\/strong><\/span><\/p>\n

Blocking as an intervention used by the committee cannot be analyzed in isolation from the legal frameworks governing it within the Egyptian legislative system, as it is subject to several legal pathways that differ in nature, objectives, and scope of application. In the context of uncommon crimes such as those related to terrorism, the Anti-Terrorism Law No. 94 of 2015 provides the possibility of blocking websites that spread terrorist activities. Article 49, paragraph two, stipulates: \u201cThe Public Prosecution or the competent investigative authority may suspend or block the websites referred to in paragraph one of Article 29 of this Law, or block any form of use mentioned in this article, and seize the devices and equipment used in the crime.\u201d<\/em> Article 29 of the Anti\u2011Terrorism Law addresses the use or creation of websites for the purpose of promoting terrorism[18]<\/sup><\/a>.<\/p>\n

 <\/p>\n

By contrast, the Anti\u2011Cybercrime Law No. 175 of 2018 regulates procedures for blocking websites in the context of crimes committed through the use of information networks. Article (7) of the law stipulates that \u201cIf there is evidence that a website\u2014whether operating within or outside the country\u2014is publishing content including phrases, numbers, images, films, promotional materials, or the like that constitute an offense under this Law and pose a threat to national security or endanger the country’s safety or national economy, the competent investigating authority may issue an order to block the site or broadcasting sites, where technically feasible. The investigating authority shall submit the blocking order to the competent court sitting in chambers within 24 hours, accompanied by a memorandum stating its opinion. The court must issue a reasoned decision accepting or rejecting the order within 72 hours of its submission. In urgent cases involving imminent danger or harm, the competent investigative and enforcement agencies may notify the Authority, which shall then instruct the service provider to immediately implement a temporary block of the website, content, or links mentioned in the first paragraph of this Article, in accordance with its provisions. The service provider must comply immediately upon receiving the notice. The enforcement or investigative authority that issued the notification must prepare a report of the procedures taken under the above paragraph and submit it to the investigative authority within 48 hours. This report shall follow the same procedures described in the second paragraph of this Article. The court shall then issue a decision either upholding or canceling the blocking. Failure to submit the report within the specified time shall render the blocking null and void. The trial court, while hearing the case, or upon request by the investigative authority, the Authority, or an interested party, may order the termination or amendment of the blocking order. In all cases, a blocking order shall be rendered void upon issuance of a decision to dismiss the criminal case or a final judgment of acquittal.\u201d<\/p>\n

 <\/p>\n

Meanwhile, the Media Regulation Law grants the Supreme Council for Media Regulation powers to oversee the performance of media outlets and websites. Article (19) of the law stipulates that websites and media outlets must adhere to several regulations, including refraining from publishing or broadcasting content that incites violations of the law, violence, hatred, discrimination, invasion of privacy, or dissemination of false news. It also authorizes the Council to block websites that violate this provision. This multiplicity of legislative frameworks reveals that blocking is used within three principal legal contexts: terrorism, cybercrime, and media regulation. Distinguishing between these contexts is essential when analyzing the Committee\u2019s decisions, to avoid conflating blocking measures linked to anti\u2011terrorism or cybercrime with those used as regulatory sanctions in the media sector.<\/p>\n

Article 94 of the Media Regulation Law also empowers the Council to impose administrative sanctions on media outlets, including permanent or temporary bans on publishing or broadcasting content.\u00a0 This provision is likewise applied in cases involving suspension of television programs. Monitoring data show that the Council issued decisions to suspend programs based on violations deemed contrary to its professional codes and standards. For instance, during the period under review, the Council suspended the program \u201cTafaseel[19]<\/strong><\/sup><\/a>\u201d<\/em> on Sada El\u2011Balad channel for three months and imposed a financial penalty on the channel. It also suspended the program \u201cSabaya[20]<\/strong><\/sup><\/a>\u201d<\/em> on Heya<\/em> channel for two months, fined the channel, and issued a warning against repeating content considered to violate individuals\u2019 privacy or offend societal values. In some cases, sanctions extended to the media outlet itself. For example, the Council decided to close the “Seha w Gamaal<\/em>” channel for practicing media activity without a license, thus making the violation in this case for practicing media activity without legal authorization, rather than to the content itself.<\/p>\n

 <\/p>\n

Within the framework of the Complaints Committee\u2019s work, monitoring data indicate that blocking is one of the most common forms of intervention used by the committee as an administrative penalty that restricts or prevents the circulation of content. There were many cases subjected to blocking, such as blocking links proven to be used to broadcast content from digital platforms without obtaining the legal rights to display it, blocking social media pages for promoting unlicensed medical products or devices, and blocking websites engaged in media activity without authorization from the competent authorities.<\/p>\n

These cases reveal that blocking is used against offences that differ in their legal nature, which raises several questions about the proportionality of blocking to the nature of the offence, especially in cases where the published decisions do not provide a clear explanation for choosing blocking over less restrictive penalties. Some decisions where blocking was the final decision also raise procedural concerns, as they lack clear statements regarding the duration of blocking, ways to appeal it, or criteria used to assess the offence. This raises questions about the consistency of these measures with the standards of legality, necessity, and proportionality stipulated in international standards governing freedom of expression.<\/p>\n

In this regard, a 2011 Joint Declaration by the UN Special Rapporteur on Freedom of Opinion and Expression and his regional counterparts emphasized that blocking broadcasting channels or banning newspapers constitutes a severe restriction on freedom of expression, which can only be justified in exceptional circumstances based on necessity and proportionality to a legitimate aim. This benchmark provides a useful reference for evaluating the consistency of such sanctions and their associated safeguards with media freedom guarantees[21]<\/sup><\/a>.<\/p>\n

Second Pattern: Preventing Media Appearance<\/span><\/p>\n

<\/strong>The sanctions regulations grant the Supreme Council authority to issue bans on media appearances as a preventive measure, subject to its discretion, and applicable when a journalist or media professional is referred to disciplinary accountability before their syndicate. Article 8 of the sanctions regulations stipulates: \u201cThe Council may, at its discretion, adopt a preventive measure prohibiting the appearance of the violator in newspapers, media outlets, or websites until the completion of disciplinary proceedings before the competent syndicate.\u201d For example, the Supreme Council decided to ban Captain Mostafa Younes from media appearances for three months and required him to delete content from his\u00a0 YouTube channel, citing violations of the Council\u2019s codes and standards due to offensive remarks against the president and members of Al\u2011Ahly Club\u2019s board[22]<\/sup><\/a>.<\/p>\n

Despite the severity of the sanction and its direct impact on media practice, the decision merely referred to a general violation of codes and standards, without specifying the professional clause violated or explaining why a ban was chosen over less restrictive measures. Similarly, the Complaints Committee approved TEN channel’s decision to temporarily suspend Captain Reda Abdel Aal for one week from participating in the “El Primo” program[23]<\/sup><\/a>, as a result of what the committee called a self-assessment to address code and standards violations, without clarifying the specific professional rule violated or the conduct that warranted the sanction.<\/p>\n

 <\/p>\n

A review of several Council decisions imposing penalties for preventing media appearances shows that they were often based on alleged breaches of professional codes and standards issued by the Supreme Council itself. These codes and standards serve as regulatory tools for media performance, such as respecting privacy, avoiding offensive or inciting content, and upholding societal values. Yet, analysis reveals that some decisions lacked detailed reasoning to explain the relationship between the nature of the violation and the severity of the sanction, or the basis for determining the duration of the ban. This raises concerns about the consistency of these sanctions with the legal principles governing administrative authority, particularly the principle of proportionality and the requirement of graduated sanctions.<\/p>\n

Third pattern: Summoning and Hearing Clarifications<\/span><\/p>\n

<\/strong>Monitoring data also reveal a pattern in the committee\u2019s interventions that involves the use of summoning and hearing clarifications as a regulatory measure that precedes imposing a penalty in some cases. This pattern differs from direct punitive interventions, such as blocking or suspending programs, as it aims to enable the committee to examine the complaint and to hear those in charge of the media outlet or the defendant content creators before issuing a final decision. This procedure has been applied in several cases involving allegations of defamation, incitement, or breaches of professional standards. For example, the Complaints Committee decided to summon the owner of the Facebook account \u201cKhaled Talaat\u201d to hear his statements in response to a complaint submitted by Zamalek Sports Club, against charges of defamation and inciting fanaticism among sports fans.<\/p>\n

 <\/p>\n

This pattern indicates that the Committee\u2019s interventions are not limited to imposing sanctions, but it extends to preliminary investigative procedures designed to verify whether an offence has occurred before reaching a final decision.\u00a0 It reflects the Committee\u2019s use of procedural oversight tools that may ultimately result in either imposing a penalty or dismissing the complaint if no violation is proven.<\/p>\n

 <\/p>\n

However, analysis of published decisions shows that summoning procedures do not always include clear statements of the procedural framework governing them, such as determining the type of the investigation, the guarantees of the right to defense, or the criteria for transitioning from summons to imposing a penalty. This raises questions about the clarity of the regulatory procedures that govern the committee\u2019s work.<\/p>\n

 <\/p>\n

\u00a0Third: The impact of the complaints committee\u2019s interventions on media freedom and digital expression<\/span><\/p>\n

<\/strong><\/p>\n

The patterns of intervention by the Supreme Council, as reflected in decisions issued based on the Complaints Committee\u2019s recommendations during the period under review, reveal that these interventions draw on two main sources: the professional codes and standards issued by the Council itself, and the broad regulatory powers granted by the executive regulations of the Media and Press Regulation Law. In many cases, however, there is no clear correlation between the nature of the violation and the disciplinary tool chosen to address it[24]<\/sup><\/a>.<\/p>\n

The Council presents its media codes and standards as regulatory rules intended to ensure professional performance in the implementation of the Constitution and the governing law. In some instances, the Council has issued these codes as a form of published regulatory decisions, such as the code of conduct and ethics for reporting crimes[25]<\/sup><\/a>. Yet, the actual impact of these codes depends on how they are applied in practice and the clarity of the relationship between the violated professional standard and the penalty imposed.<\/p>\n

The relationship is more obvious in limited cases. For example, in complaints concerning violations of exclusive broadcasting rights, particularly those filed by media production companies or sports broadcasting platforms, the Council\u2019s interventions resulted in requiring media outlets to delete infringing content or block specific links, in relative compliance with intellectual property and broadcasting rights protection laws, Similarly, in cases of promoting medical or therapeutic products without a license, the council restricted content availability, citing violations of advertising regulations and the need to protect the public from misleading information. These cases demonstrate a more explicit relationship between the violation in question and the sanction imposed.<\/p>\n

However, the prevailing trend reflected in these patterns has been broad and general descriptions of violations, such as breaching societal values, violating media standards and regulations, or harming the image of society, without referring to a specific article in the media codes or clarifying the professional law that was violated. This was evident when the council issued decisions that resulted in restrictive measures on content availability or in direct disciplinary sanctions, such as preventing media appearances, suspending participation in programs, or blocking, as discussed earlier.<\/p>\n

These practices suggest that the Supreme Council for Media Regulation\u2019s interventions oscillate between a limited number of cases where the basis of its intervention can be traced, and a majority of decisions that rely on vague descriptions of violations, allowing the use of highly impactful tools such as blocking or preventing media appearances, without a systematic explanation of the relationship between the nature of the violation and the severity of the penalty.<\/p>\n

The human rights impact of disciplinary sanctions resulting from the Complaints Committee\u2019s decisions cannot be assessed in isolation from the international framework governing freedom of expression and media. which requires examining the legality of restrictions and their practical application. Article 19 of the International Covenant on Civil and Political Rights stipulates that any restriction on freedom of expression must be provided for in a clear law, have a legitimate and specific aim, and be necessary and proportionate to achieve that aim.[26]<\/sup><\/a>\u00a0 The UN Human Rights Committee, in its General Interpretation No. 34[27]<\/sup><\/a>, affirmed that vague or undefined wording of restrictions opens the door to their arbitrary or excessive application, thereby undermining the essence of the right to freedom of expression.<\/p>\n

In this light, the Complaints Committee, in several of its interventions, relied on general standards contained in the professional codes and regulations issued by the Supreme Council for Media Regulation[28]<\/sup><\/a>, such as protecting societal values, maintaining public order, or not harming national security, without sufficient clarification of the nature of the violation or its severity. A review of published decisions reveals inconsistencies in the reasoning of interventions: some decisions were based on general descriptions, such as infringement of exclusive broadcasting rights or promotion of medical products without a license. This reflects the absence of a consistent intervention approach despite differences in the clarity and severity of violations.<\/p>\n

The human rights assessment expands when compared with international standards, The European Court of Human Rights, in its application of Article 10[29]<\/sup><\/a> of the European Convention on Human Rights, has affirmed that interventions which disrupt the continuity of media work, such as suspending programs or preventing media appearances are considered among the most severe restrictions on press freedom, and can only be justified in exceptional circumstances that meet the strict criteria of necessity and proportionality in a democratic society. The Court also stressed that the use of general concepts such as national security or the protection of values is not, in itself, sufficient to justify such restrictions unless the state demonstrates the existence of real and direct harm. These issues may be summarized as follows:<\/p>\n