Filling the minimum roster by numbers is not enough: everyone you show on it must hold a particular qualification and must not hold particular ties. The Regulation on Official Announcements and Advertisements deals with this in two separate articles — Article 19 lists who may be on the roster, Article 20 who may not.

Those who may be on the roster (Art. 19)

Article 19 requires editorial staff to hold at least one of the following. There are seven separate routes and one is enough:

RouteCondition
Education (communication)A degree from a communication faculty or a communication-related undergraduate programme of another faculty, or a master’s or doctoral programme in communication; or an equivalent diploma recognised by the Higher Education Council
Press cardHolding a press card in the capacity of editorial staff
Vocational school + 6 monthsGraduating from a communication-related programme of a vocational school and having worked, uninterrupted, at least 6 months as editorial staff in press organs, with documentation
Vocational high school + 12 monthsGraduating from a communication-related programme of a vocational school recognised by the Ministry of National Education and having worked 12 months in total under Law No. 5953, at least 6 of them continuous, with documentation
Experience 15 monthsHaving worked 15 months in total as editorial staff under Law No. 5953, at least 6 of them continuous, with documentation
Public broadcaster 15 monthsHaving worked 15 months in total in the news services of public broadcasters under public-law status, at least 6 of them continuous, with documentation
Other degree + 9 monthsGraduating from a non-communication undergraduate programme and having worked, uninterrupted, at least 9 months as editorial staff in press organs, with documentation

The last route opens a door for people without a communication education who have worked in the field. The point to watch is the word uninterrupted: the nine months must be continuous.

The second paragraph grants two exemptions: those employed as columnists, and — limited to one member of editorial staff — persons treated as disabled under Law No. 4857 who document this with a proper medical board report.

Those who may not be on the roster (Art. 20)

Ownership and management ties

The concession holder or the representative of the legal person determined under Law No. 5187; partners in general partnerships; active partners in ordinary and share-capital limited partnerships; shareholders in shipping partnerships; partners representing the company and company managers in limited companies; partners authorised to represent the company and members of the board of directors and audit board in joint-stock companies; in cooperatives the manager, members of the management and audit boards and persons authorised to represent — none of them may appear in the editorial rosters of publications belonging to themselves or to others.

Kinship ties

The mother, father, spouse, natural and step children, adopted child and spouse’s parents of a natural person owning a publication concerned with official announcements, or of members of the management or audit organs of a legal person owner, may not appear on that publication’s roster.

Other bars

Students in daytime education and second-shift students in another province (open and distance education excepted), persons called up for military service and persons on unpaid leave may not appear in editorial rosters.

Qualification is not enough: the work itself is inspected

Article 18 requires, together, that the contracts of those on the roster are made in writing and full-time in conformity with Law No. 5953, that their wages are paid in advance over a full day and a full month, that they actually perform the work corresponding to their contractual duties, that social security notifications and tax accruals are made within the statutory period, and that they engage in no commercial business benefiting themselves.

Those five conditions target the “roster on paper” practice directly. On inspection the contract, the payroll, and the social security and tax records are cross-checked.

Conclusion

To be on the roster a person must satisfy at least one of the seven routes; education and a press card are the most direct. Conversely the concession holder, company representatives and members of management and audit organs, together with the owner’s close relatives, cannot be shown — the exception being relatives with a communication degree or a press card.

The numbers required per category are in the newspaper guide and the online news site guide.