The current Bill makes two major omissions, the first on the relationship between the ZMC and any other self-regulatory mechanisms. The second omission is on the Zimbabwe Media Commissions responsibilities to promote access to information as set out in Sections 18 and 35 of the current Freedom of Information Bill. The first omission relates to the possibility of a hybrid regulation of the media landscape as clearly set out in Section 249 (3) of the Constitution. The promulgation of a new media law in the form of a Zimbabwe Media Commission Act provides Zimbabwe with an opportunity to migrate from the current State Regulation/ Dual Regulation model to a co-regulatory regime whereby the internationally respected self-regulatory mechanism would be enhanced with the co-operation of the State. Sections 18 and 35 of the Freedom of Information Bill currently identify the Zimbabwe Media Commission as the Commission responsible for the monitoring and exercise of the right to access information in Zimbabwe. The current version of the Zimbabwe Media Commission Bill is silent on how the Zimbabwe Media Commission will handle these additional functions assigned to it by the Freedom of Information Bill. In addition to the above, MISA Zimbabwe makes the following further observations in the spirit of ensuring that the Bill is more closely aligned to the letter and spirit of Section 61, 248, and 249 of the Constitution. a. Sections of the Draft Bill that bestow wide discretionary powers on the Minister over the Commission should not be allowed to stand in the final Bill or Act. This setup significantly compromises or depletes the independence of the Commission (as such independence is envisaged in the Constitution).1 b. The Bill states that the Commission can initiate investigations on its own. This arguably, is open to abuse and theoretically promotes persecutory type investigations. It is more desirable that the primary basis for investigations to be the filing of a complaint by a specific identifiable complainant. 1 For example: 7 Section of the Bill gives the Minister extensive powers in the appointment of Commission staff Section 21 of the Bill which gives the Minister extensive powers in the drafting and approval of Regulations 7