在歐美各國不同的新聞自律作法中，納入新聞工作者與公眾團體力量的自律機制，較具成效；而市場力量獨大、由業者所主導的自律機制，則往往因為缺乏強制力，功效備受質疑。在台灣，威權時代官督民辦的新聞自律機制，隨著解嚴而崩解，新聞工作者自主成立的新聞自律機制一度出現，但卻受限於社會條件，未能形成風潮。近期媒體小報化的趨勢中，逐漸出現業者所主導的「淨化自律」趨勢，但仍流於道德訴求而未能落實，也並未納入新聞工作者的真正自律。本文最後援引目前歐盟「共同管制」的觀點，建議改變過去以業者主導的作法，改以納入新聞工作者、閱聽人、與政府力量的「民主參與式」的「共管」自律機制。

Among various models of media self-regulation in the U.S. and European countries, those that allow journalists and citizens to participate are more effective than those that include only media owners. In Taiwan since the 1990s, there have been two tendencies about self-regulation, while the traditional self-regulated organizations, which were practically controlled by the government, have declined along with the democratization process. On the one hand, the development of an alternative mechanism of self-regulation created by journalists in the mid 1990s has been largely constrained in the for-profit media market. On the other hand, the function of conservative, self-regulated bodies that focus on obscene and violent content has been widely questioned. In order to improve media accountability, this paper suggests a model of “participatory and regulated self-regulation” which includes citizens, journalists, the government, and media owners.