largely on non-political topics, had all of their content pre-approved by the Censorship Board, and operated under constant threat of losing their obligatory publishing license or being arrested. The third type was “exile” media outlets that operated abroad, beyond the reach of Myanmar’s regulatory framework, and spent much of their time trying to get information in and out of the country, while the military searched for their journalists and sources.73 REGULATORY TRANSITION A new military-backed quasi-civilian USDP administration began implementing political, economic, legal, and administrative reforms from 2011 to 2015 in what was announced as a transition to democracy under the military-drafted Constitution (2008). The reforms established some basic protections for the rights to freedom of expression and association and led to a general reduction in human rights violations.74 Several exile media outlets were unblocked online in 2011, and a year later the Censorship Board was shut down. Three laws were adopted bringing the regulatory framework governing the media closer to international standards, but never quite free. The News Media Law (2014) granted some limited media rights but did not repeal, expressly override, or require compatibility from other laws that still unduly restricted media freedom.75 The Printing and Publishing Law (2014) retained compulsory licensing for print media – incompatible with international human rights standards – and only removed some of the obstacles that were previously used to block dissenting publications from registering.76 The Broadcasting Law (2015) would have allowed for independent television and radio channels but was not implemented. REGULATORY TRANSITION HALTED Although the media regulatory framework was still restrictive at the time of Myanmar’s first free and fair elections in 2015, new media outlets were launching, exile media outlets and their journalists had returned, and a diverse media sector was beginning to emerge. Aung San Suu Kyi’s NLD administration, which won a landslide electoral victory and took up power from 2016 to 2021, decided after gaining power not to continue the regulatory reforms or better protect the rights to freedom of expression and association, reneging on decades of prior commitments. In particular, the NLD 73 The outlets that based their operations outside of Myanmar were commonly labeled as “exile” media. Most did not originally operate inside Myanmar but rather were set up abroad by “exiled” individuals who had escaped persecution in Myanmar. After the 2021 coup many outlets operating inside Myanmar moved into exile abroad. 74 For more information regarding the general reduction in human rights violations, compare Universal Periodic Review reports 2011, 2015, and 2021: https://www.ohchr.org/en/hr-bodies/upr/mm-index. However, gross and systematic human rights violations continued against many ethnic minority groups. Violations against the Rohingya in particular later increased, leading to atrocity crimes that were being investigated by multiple international mechanisms, including the International Criminal Court and International Court of Justice. For more information, see the UN’s Independent Investigative Mechanism for Myanmar: https:// iimm.un.org. 75 Lawmakers often claimed or implied that the lex specialis doctrine, according to which special laws override general laws, applied to media law, but this was not demonstrated in Myanmar in practice. 76 FEM (2017), “News Media Law”; FEM (2017), “Printing and Publishing Law”; FEM (2017), “Broadcasting Law”. 27