Refusal can come at two separate stages of the process, and the consequences differ. The Press Card Regulation deals with them separately in Articles 29 and 35.
Two Stages
| Stage | Who refuses | Ground | Article |
|---|---|---|---|
| Initial review | The Directorate | Not meeting the conditions in Art. 8 or 9 | Art. 29/2 |
| Commission assessment | The Press Card Commission | Qualifications, professional work, the qualities of the organisation | Arts. 33(a), 35 |
1. Refusal at the Directorate Stage
Article 29/2 is explicit: applications by those whom the Directorate determines, from the information and documents gathered, do not meet the conditions in Articles 8 or 9 are refused. The applicant is notified using the contact details given in the declaration.
A refusal at this stage means the file never reached the Commission.
Reapplication Is Possible
The same paragraph states the remedy: where the deficiencies are completed and the required condition is met, a fresh press card application may be made.
2. Refusal at the Commission Stage
Once the file reaches the Commission, the assessment criteria widen. Under Article 35/2 the Commission decides by assessing the applicant's:
- Qualifications
- Professional work
- Published works
- Awards
- and the qualities of the media organisation they belong to
The Commission stage is therefore not merely a check of conditions but a qualitative assessment.
Reasons Are Recorded in the Minutes
Article 35/5 lays down an important procedural rule: the Commission's decisions are recorded in minutes, and the reasons for decisions refusing applications are annexed to the minutes.
A Criterion Specific to Internet News Site Staff
Article 35/3 adds a further criterion: where the applicant is a member of staff at an internet news site, the site's unique visitor count and page view count are also taken into account.
A Criterion Specific to Information Officers
Under Article 35/4, where the application is made under the title of information officer, the applicant's title and whether the duty actually performed is media-related are taken into account.
Block Voting
Sub-paragraph (ç) of Article 33 gives the Commission power to decide that some applications be voted on as a block. Not every file has to be voted on individually.
Bottom Line
Applications found not to meet the conditions are refused by the Directorate and the applicant is notified; a fresh application may be made once the deficiency is remedied. Where the file reaches the Commission, the assessment covers qualifications, professional work, published works, awards and the qualities of the organisation, and the reasons for a refusal are annexed to the minutes.