Crime and corruption reporting network – LUPA, after ten years of successful work in the civil sector in the field of investigative journalism, has completely unjustifiably found itself targeted by the Agency for Audiovisual Media Services (AMU).
On February 24, 2026, an email was sent to NGO LUPA containing a request from AMU for our organization to submit an application “for the provision of on-demand audiovisual media services.”
03-041-26-161-2 Invitation to align operations with the Law on AVM – Internet publication LUPA
In its response to AMU, LUPA stated, among other things, that the organization does not engage in advertising, marketing, or the production of on-demand audiovisual content, which is clearly indicated in its imprint.
NGO LUPA is not registered in the Central Register of Business Entities (CRPS), but in the NGO registry as a non-profit organization, making it clear that it cannot be a provider of on-demand AVM services.
On April 10, 2026, AMU sent another response insisting once again that LUPA submit an application “for the provision of on-demand audiovisual media services.”
03-041-26-161-4 AMU Response – alignment with the Law on AVM – Internet publication LUPA
On April 24, 2026, LUPA sent a new response to AMU, stating, among other things, that its primary purpose is not the provision of on-demand AVM services, but the promotion of investigative journalism and the publication of investigative projects. The video content referenced by the Agency serves only as a supporting tool to LUPA’s primary mission.
“If LUPA were to register as a provider of on-demand AVM services, it would be required to fulfill numerous additional obligations prescribed by the Law on AVM Services, specifically in Articles 58–61. These obligations include: separate accounting (which in itself implies a ‘profit-oriented’ nature of AVM service providers, whereas LUPA has no commercial use of the video content in question), the creation of a complete program framework and its categorization, as well as ensuring a share of European audiovisual works. Fulfilling these obligations would fundamentally transform the nature and purpose of LUPA, effectively preventing it from achieving its statutory goals,” the response states, adding that all relevant legal measures will be taken to protect LUPA’s right to continue operating in the civil sector and in the public interest through investigative journalism.
LUPA, which is a member of the Global Investigative Journalism Network (GIJN), particularly highlights the fact that this “action by AMU” was initiated after the appointment of Dragoljub Duško Vuković, President of the Assembly of the NGO “Media Center,” to the AMU Council.
This NGO has on several occasions filed complaints alleging conflicts of interest and legal violations against the founder of LUPA and Director of Radio Television Podgorica, Vladimir Otašević (all complaints were dismissed by competent state authorities as unfounded).
For this reason, there is suspicion that the aforementioned “action by AMU” ultimately aims to initiate another attack against LUPA’s founder. If LUPA were to register as a provider of on-demand AVM services, it could potentially result in the initiation of a new procedure against Otašević (as founder of LUPA and current Director of RTV Podgorica) to determine a conflict of interest.
Editorial Office of NGO LUPA