LLMs as media technology: implications under article 10 ECHR

This article suggests viewing LLMs as ‘media technology’. This is both a factual and a normative argument. It is factual given the increasing proliferation of LLMs in news content production and distribution routines—even within legacy newsrooms. It is normative because framing LLMs as media technology brings to the fore crucial questions about press freedom in Europe in the age of automated content generation. Taking the demands of media freedom and pluralism as a starting point, the article unpacks the implications of this conceptual shift under art 10 of the European Conventions on Human Rights. The analysis that follows is primarily supported by the case law of the European Court of Human Rights, based on which it will be critically reflected on the EU’s regulatory choices in the Artificial Intelligence Act.