The honest answer: the Press Card Regulation lays down no appeal or litigation route. There is no article headed "appeal", "action" or "judicial remedy".
What the Regulation Does Offer: Reapplying
Art. 29/2 spells out the route for a refusal at the Directorate stage: requests from those found, on the information and documents gathered, not to meet the conditions in Art. 8 or Art. 9 are refused; the applicant is notified using the contact details given in the declaration. Once the deficiencies are made good and the required condition is met, a fresh press card application may be made.
Two Kinds of Refusal, Two Different Bodies
| Type of refusal | Who decides | On what basis | Article |
|---|---|---|---|
| Condition check | The Directorate | Failure to meet the conditions in Art. 8 or Art. 9 - objective | Art. 29/2 |
| Refusal on the merits | The Commission | Qualifications, professional work, published output, awards and the qualities of the outlet - discretionary | Arts. 33/1-a, 35/2 |
Reasons Are Annexed to the Minutes
Art. 35/5 contains an important safeguard: the Commission's decisions are recorded in minutes, and the reasons for decisions refusing applications are annexed to the minutes. A refusal is therefore a reasoned act, not a bare outcome.
Cancellation Follows the Same Pattern
The Regulation treats cancellation the same way: it provides no appeal stage, only the conditions for coming back.
- Art. 38/1 - Where a card is cancelled, a fresh application is required once the grounds of cancellation have disappeared.
- Art. 38/4 - Where the cancellation was for breach of the press ethics principles, no new card is issued until one year has passed from the date the card was returned.
Summary
- The Press Card Regulation contains no appeal body, appeal period or reconsideration procedure.
- What it offers is a fresh application once the deficiency is cured (Art. 29/2).
- Refusal decisions of the Commission are reasoned and the reasons are annexed to the minutes (Art. 35/5).
- A refusal is an administrative act; general administrative procedure legislation, which lies outside this article's source set, governs judicial remedies.