WORKING GROUP ON
THE SUSTAINABILITY
OF JOURNALISM
A NEW DEAL FOR JOURNALISM
JUNE 2021

ABOUT THIS REPORTThis report has been produced by the Working Group on the Sustainability of Journalism of the Forum on
Information and Democracy, in response to a worsening international crisis facing the economic viabilityof independent professional journalism everywhere.
The report calls for immediate and sustained action from, and collaboration between, governments
and other influential actors to improve the policy, funding, and enabling environment for independent
professional journalism – a New Deal for Journalism amounting to up to 0.1% of GDP annually in direct
and indirect funding worldwide. The measures we outline in this report are evidence-based and canalready point to broad support in many countries around the world.
The gravity of the crisis facing journalism is severe, but, if policymakers and decision-makers can findthe political will and imagination to take these choices now, and to build on them over the next decade,we believe this has the potential to be an inflection point for the sustainability of journalism, and for thehealth of open societies everywhere.

STEERING COMMITTEE MEMBERS:• Rasmus Nielsen, chair. Director, Reuters Institute for the Study of Journalism, University of Oxford. He

is also Professor of Political Communication at the University of Oxford.
• Julia Cagé, co-director, Laboratory for Interdisciplinary Evaluation of Public Policies. As a professor of
Economics, she published Saving the media: Capitalism, crowdfunding and democracy.
• Prem Chandran, co-founder and CEO, Malaysiakini. He also serves as non-executive director of KiniTV
and FG Media, and he is the Chairperson of Asia Mobiliti.
• Styli Charalambous, publisher and CEO, Daily Maverick. He is a reformed accountant now working inmedia entrepreneurship.
• Naresh Fernandes, editor, Scroll. He is also on the editorial policy board of the World Policy Journal. He
was previously the editor-in-chief of Time Out India and The Wall Street Journal in New York.
• Elizabeth Hansen Shapiro, Senior Research Fellow at the Tow Center for Digital Journalism at Columbia
University.
• Kwame Karikari, professor in journalism and mass communication, School of Communication Studies,
University of Ghana. Previously, he was the Executive Director of the MFWA.
• Arne H. Krumsvik, Rector and Professor of Media and Communication, Kristiania University College.
He is considered to be one of the founders of media innovations studies.
• Nishant Lalwani, Managing Director, Luminate. He also leads the organization’s work in narrativechange across all its impact areas and oversees Luminate’s strategy, and partner support teams.
• Mira Milosevic, executive director, GFMD. She authored the World Press Trends reports, managed
Media Development Programmes at WAN-IFRA, and was the director of Media Center Belgrade.
• Tania Montalvo, Executive editor, Animal Político. She started out as a reporter for Animal Político in2013, with a focus on corruption, organized crime, violence and conflict.
• Henri Pigeat, former president, AFP. He is currently a press editor. Previously, he was the animator of
the Quality of News and Information Task Force of the WAN.
• Sibylle Rizk, public policies director, Kulluna Irada. She is an expert of Lebanese challenges as theformer Editor in Chief of the leading Lebanese monthly Le Commerce du Levant.
• Natalya Sindeyeva, founder and CEO, Dozhd. Dozhd is a Russian independent television channel.
Natalia has twice won the ‘Russia’s media manager’ award for her work on radio and in television.

2• Olaf Steenfadt, head of the “Journalism Trust Initiative” at RSF. Olaf is a member of the “Committee ofExperts on Quality of Journalism in the Digital Age” at the Council of Europe.
• Kirstine Stewart, head of Shaping the Future of Media, Entertainment and Information. Previously,
she was the Vice-President, Media, Twitter after launching the Twitter Canada office.
• Patricia Torres-Burd, Managing Director – Media Services, Media Development Investment Fund.
Previously, she was the vice-president of UBC International.

REPORT TEAM:
Lead Rapporteur: Sameer Padania
Rapporteurs: Emma Goodman, Louise Anglès-d’Auriac
Forum team: Camille Grenier
RSF team: Thibaut Bruttin, Iris de Villars

ACKNOWLEDGEMENTS:
We would like to thank the dozens of experts and organizations across the globe who generously
contributed their time and insights for this report – through interviews, submissions, leads andpublications. We also thank those whose analysis, evidence and research we have cited.

LICENSING INFORMATION:
The Forum grants a Creative Commons license – Attribution-ShareAlike 4.0 International (CC BY-SA 4.0) –to this report. Under the terms of this license, anyone may copy, adapt and widely distribute the material
in any format without charge, provided that they indicate clearly where any changes have been madefrom the original material, that they credit the Forum on Information and Democracy as the creator, andthat they provide a link to the report on the Forum’s website.

TO CITE THIS DOCUMENT, PLEASE USE THE FOLLOWING FORM:
Forum on Information & Democracy. (2021). A New Deal for Journalism.
https://informationdemocracy.org/working-groups/sustainability-of-journalism/3

PREFACE
HISTORIC ACTION
FOR AN HISTORIC TIME
By Christophe Deloire, Chair of the Forum on Information and Democracy
Historic time requires historic action.
The time has come for a New Deal for Journalism, a major commitment on a national and international
scale to foster journalism worthy of the name, public-interest journalism, and journalism of quality: free,independent and reliable.
The International Declaration on Information and Democracy, published in 2018 by the Commission on
Information and Democracy, declared: ‘Journalism’s social function is that of a “trusted third party” forsocieties and individuals.’ The role has a particular responsibility, through its professional practices andethical rules.
It is the pinnacle of journalism, the justification for its existence, to provide a methodology to seek
and impart information and ideas. Considering that journalism is composed, even defined, by rights
and duties, Freedom of the press is an indispensable condition for this social function, as are editorial
independence and a pluralist context. However, this freedom cannot remain theoretical. It needs a wayof putting it into effect.
This report lays the foundations of this New Deal for Journalism, which involves an effort by democratic
governments and also media organisations themselves, as well as digital stakeholders. This effort should
facilitate the exercise of journalistic freedom and responsibility. Its purpose is to strengthen the social
function of the ‘trusted third party’.
In the information chaos of the globalised digital public domain, the New Deal for Journalism consists oflinking together various points that up to now have been separate, i.e. how the market is organised, thetechnological environment, and the work of journalists, with its working practices and ethics.
In other words, the New Deal assumes that regulation and off-market policies link issues that have so
far been treated separately. This amounts to rebuilding journalism, not as a ‘media sector’, but as an
essential element of freedom of opinion and expression, predicated on the right to information.
As the philosopher Hannah Arendt observed: ‘Freedom of opinion is a farce unless factual information is
guaranteed and the facts themselves are not in dispute.’
The potential for deep fake-style manipulation, disinformation on a world-wide scale, the spread of
rumours and claptrap has reached an unprecedented level, creating an emergency for democracy
and human rights. A secondary effect of the Covid epidemic has been to help ‘infodemics’ and also toundermine the best vaccine against disinformation, namely journalism.
Even if we wanted to, we shall not return to the old world. For the future we need an impetus and a plan,
based on innovation and idealism.

4For U.S. President Franklin D. Roosevelt, the New Deal was a political commitment, an economic
investment and a call to action by each and every citizen. There were three principles behind the plan:relief, recovery and reform. The plan put forward here deals with these three aspects in a dynamic visionof the media sector. The New Deal for Journalism is driven by the need for regulatory as well as selfregulatory initiatives.
According to the Declaration on Information and Democracy: ‘The social function of journalism justifies
an effort by societies to ensure journalism’s financial sustainability.’ Democracies would be mistaken if
they merely offered support to an industry in danger. The spirit of the declaration is that they must makean effort to restore, de jure and de facto, the social function of journalism which will be the most relevant
for future generations.
The New Deal for Journalism will provide both an impetus and a plan.

Mitigate the poison, strengthen the antidote
Let’s go back a little.
Gutenberg’s invention of printing in the 15th century, a fundamental event of the Renaissance, was amajor step forward for humanity, while at the same time inflaming minds and setting the stage for laterwars of religion. Journalism was a vehicle for the ideals of human rights and progress, bringing the notionof citizenship to fruition once these ideas were in place, but newspapers also aroused passions to thepoint where destructive warfare erupted.
‘Means of communication’ carries the two-fold significance of pharmakon, distilling both the poison andits antidote. This is clearly the case in the digital world. The digital revolution that began in the late
20th century provides humanity with an almost unlimited ability to communicate. The communication
explosion has nonetheless had seismic effects, upsetting the balance that allowed democracies to enact
freedom of opinion and expression.
It is up to us to mitigate the poison and strengthen the antidote by being aware of the potential fortragedy in the exercise of freedom of expression, but without imposing restrictions on it. It is trying tosquare the circle, but it is a guiding principle of democratic systems to manage contradictions. That isbehind the International Initiative on Information and Democracy which we launched in 2018, together
with its commission comprising 25 figures and from 18 different countries.
The initiative aims to rebuild a system of democratic guarantees in the public domain, adapted forthe digital age, since the guarantees established in the history of democracies have been overtaken
by technological upheavals. Inspired by the declaration produced by the Commission, the International
Partnership on Information and Democracy was launched during the United Nations General Assemblyin 2019. So far 42 countries have signed up to it.
The Commission on Information and Democracy has built on the doctrine’s past development, stating:‘The right to information consists of the freedom to seek, receive and access reliable information.’ Ascommunication has exploded and anyone can take full advantage of it without assuming any sense of
responsibility, it is vital to coordinate the rights of providers and recipients of information, who faceuncontrolled capability for manipulation and disinformation.
A paradigm shift requires a new judicial balance in order to be truly faithful to basic principles. The

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Commission has stated: ‘Information can only be regarded as reliable when freely gathered, processedand disseminated, according to the principles of commitment to truth, plurality of viewpoints and rational
methods of establishment and verification of facts.’
Journalism increasingly fulfilled this social function, from the turn of the 19th century and throughout the
20th, through its professionalization with the creation of journalism schools and the establishment of abody of ethics at the instigation of organizations representing journalists.
Note that tragic conflicts often bring new awareness. In the course of the history of democracy,
parliaments have brought in media regulations to promote, in various forms, pluralism, independence
and honesty of information.
Ideals can, of course, be corrupted. A considerable section of the media has been (and is still) able tofocus on trivial facts in the guise of entertainment or to promote pointless arguments. Some media
organizations in the pay of governments or wealthy industrialists serve partisan or individual interests.
It would take an encyclopedia to list the cases where such criticism would be legitimate. Nevertheless, if
we weigh up the advantages and disadvantages of journalism, it is clear there would be no democracy
without journalism.

Crises and a decisive decade
We have entered the digital era but, on a historical scale, we are just at the dawn. News media have losttheir monopoly over the flow of information and communications and there is no use crying over it.
The problem is that journalism is now in direct competition with content of all kinds, from government
propaganda to advertising, from rumors to disinformation campaigns, and competitive pressure
threatens content quality.
Journalism has been weakened by a potentially devastating series of major crises: a geopolitical crisis(growing power of despotic anti-models), a crisis of democracy (polarization and condemnation), a crisisof conscience (widespread mistrust), a technology crisis (information chaos) and an economic crisis(financial issues leading to a downward spiral). The Covid epidemic has amplified all these.
When the 2020 edition of the World Press Freedom Index was published, Reporters Without Borders(RSF) noted that the 2020s would be a decisive decade for journalism, particularly for its sustainability.
Journalism’s future existence is at stake. In order to avoid the decade becoming a disaster, grand words
and piecemeal actions will not be enough.

End of the road for journalism?
The figures are dismal and dismaying, made more serious by the effects of the economic crisis triggeredby the COVID-19 pandemic. In 2020, the Reuters Institute for the Study of Journalism at the Universityof Oxford worked with members of the Independent News Emergency Relief Coordination (INERC) on
an initiative to support news media affected by COVID-19. The responses and interviews paint a somber
picture: news media alone could be looking at losses of US$30 billion in 2020.
According to Ken Doctor, a news industry analyst with Newsonomics, the toll of the coronavirus on thenews media could be worse than the 2008 financial crisis, which saw newspapers experience a 19%
decline in revenue. This trend was confirmed by an analysis by PricewaterhouseCoopers, which forecasts

6

that the global newspaper industry’s revenue will fall from US$108 billion to US$86 billion between 2019and 2024.
An additional factor is the change to the way that the younger generation consumes information. Just
12% of Americans aged between 18 and 29 use television as a means of accessing news and information,compared with 43% of people aged over 65. Almost half of all millennials never read a daily newspaper.
In France, 1% of those aged between 15 and 29 buy daily newspapers and 20% of them use their cell
phones to access news and information (5% more than the national average). Journalism must be
reinvented urgently to encourage the creation of a more sustainable way of operating.

The death of pluralism
The danger concerns not just the information industry but, more broadly, citizen communities, since
the seeds of division have been sown. Extreme polarization of the media, and consequently society, is inprogress. During Donald Trump’s presidency, public debate was confined to just a few publications andTV channels which embodied entrenched political positions and preached to the converted, galvanized
by increasingly radical interpretations of the facts.
It’s not just algorithms that create filter bubbles, news media (or discussion groups, talking shops andclaptrap forums) can also do so. Editorial staff can also harden their position. It is to be feared that thediversity of opinions is shrinking among opinion formers themselves. Such polarization strategies are
unfortunately financially profitable. Even in the main democracies, media organizations that take part inpartisan squabbling enjoy record audiences and can be highly profitable.
Another worrying phenomenon is the increase in information deserts. Studies show that local journalism
is particularly at risk. A growing feeling of mistrust and criticism of the lack of representativeness among
journalistic stakeholders and content can be seen as a direct consequence of such desertification.
Journalism is an art that decentralizes and brings together, of distance and proximity, and its narrative
must cover what happens everywhere, locally and globally.
If things continue as they are, societies will soon be faced with a pluralism of unsupported partisan
visions, of propaganda, i.e., diversity of content consisting only of public relations and institutional
communications. Democracy is underpinned by the pluralism of media organizations with distinct
editorial policies that follow the rules of honesty, such as fact-checking and adhering to ethical rules.

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Funding and more
When asked what kind of support would benefit their business, a sample of news media organizations
quoted funding support (84%), product development and innovation support (61%), and technicaltraining in digital media skills (39%).¹
How to develop resources and stimulate demand are among the subjects covered in this report. But
our work goes further and proposes practical ways of creating an environment that favors journalism
and focuses on enabling the press, which is struggling to adjust to the new digital order, to steer its way
through the technologies of the future.
All parts of the equation must be taken into account to ensure the survival of the social function ofjournalism, which is essential for societies and individuals. The report’s recommendations are intended
to meet this deficit in resources and investment by proposing innovative solutions that foresee up to
0.1% of GDP a year worldwide guaranteed for news organizations.
If this is part of what democracy costs, and it is, 0.1% of GDP a year is not too high a price to pay.

The need for an historic commitment
On behalf of the Forum on Information and Democracy, I express our gratitude to all those who helpedin the development of this initiative, especially the Alliance for Multilateralism, under the leadership of
the French and German Foreign ministers, Jean-Yves Le Drian and Heiko Maas.
We also thank the steering committee of the working Group on the Sustainability of Journalism, chairedby Rasmus Kleis Nielsen, director of the Reuters Institute for the Study of Journalism at the University of
Oxford and the team of rapporteurs, led by Sameer Padania.
We expect the leaders of democratic countries to square up to these historic issues. The New Deal for
Journalism needs leadership. It must have international scope and must be implemented at all levels,
global as well as local.
The summit on the International Initiative on Information & Democracy, due to take place in New Yorkduring the UN General Assembly in September this year, will be the ideal place to announce such acommitment.

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CONTENTS
About this Report 

2

Preface – Historic Action for an Historic Time4

Foreword by Rasmus Kleis Nielsen 

10Executive Summary12A ‘potential extinction event’ 

12The need for a New Deal for Journalism

12

Our methodology

13What governments can do to help independent journalism

13

Key Recommendations15

Introduction

18

CHAPTER 1: Freedom

23

CHAPTER 2: Funding

27

CHAPTER 3: Environment

44

CHAPTER 4: Future

56

Appendices

66

List of interviewees and submissions66

Consultation in Africa in partnership with Canal France International (CFI)

67
70

Notes

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FOREWORD
BY RASMUS KLEIS NIELSEN
Professor Rasmus Kleis Nielsen, director of the Reuters Institute for the Study ofJournalism at the University of Oxford, and chair of the working groupof the Forum on Information and Democracy on the Sustainability of Journalism.
Less talk, more action?
“Quality, clear, and truthful information is essential for a democratic society based on the values ofhonesty and respect, fairness and justice, freedom and dignity,” Canadian Prime Minister Justin Trudeau
said on World Press Freedom day this year, thanking journalists everywhere who “give us the facts tomake better sense of the world, contribute to our communities, and lead freer, richer lives.”2
This is more than just words. While journalism is imperfect, and sometimes problematic, years of research
have documented how independent, professional journalism helps people stay informed, take part inpolitical processes, and engage with their local communities, just as it can help hold power to accountand reduce corruption and malfeasance in both the public and the private sector.
But journalism’s ability to do this is threatened on several fronts today, by powerful people all over theworld waging war on journalism as media freedom erodes, and by the inexorable decline of the traditional
business of news as people abandon print and broadcast in favor of digital media and platforms, achallenge sometimes compounded by journalism’s unwillingness to reckon with its own shortcomings oradapt to a changing world.
If governments want to do more than talk about the value of journalism, and actually help the journalists
and news media who are leading on forging new ways forward for the profession and the industry, they
will need to step up and take real action.
Whether this is a priority is for the public and its elected officials to decide, but one thing is clear. Speeches
alone will do little to help journalists. They need action, and the reality is that, at best, most governments
have done little or nothing.
What can governments do? One place to start is with existing policies that have proof of concept,
command broad-based support in the countries where they are in place, and are oriented towards the
future of journalism. Blue-sky thinking is always welcome, but it should not distract us from proven tools
already at hand. This report identifies a range of the most important steps governments could take –right now – to help ensure the freedom, funding, and future that journalists need to do their job. Noneof them is perfect, but all of them are practical, and all can be structured so they avoid simply privileging
incumbents or lining the pockets of proprietors and shareholders.
They include, perhaps most importantly:>S upporting private sector news media through indirect forms of support such as tax exemptions,direct support specifically tied to investment in professional journalism and structured to prioritize
local media and media serving minorities, and supporting innovation, without tying these forms of
support to increasingly marginal forms of distribution like print. Such an option is demonstrated in
Denmark.

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> Supporting public service media with a clear remit and ability to serve the public acrossall media, not just broadcasting; strong insulation from political pressure to ensure their editorial
independence from government, sufficient funding to deliver on their mission, and a clear focus onserving those communities least well-served by private sector media. Such an option is demonstrated
in the United Kingdom.
>S upporting the creation of nonprofit news media by easing the creation of journalistic
nonprofit organizations, whether from scratch or by converting legacy titles, and creating
incentives for both individuals and foundations to support nonprofit news media, is a third option.
Non-profit media are already making important contributions in some countries.
>S upporting independent news media globally by committing at least some official development
assistance (ODA) to journalism in other countries is a fourth option, whether done bilaterally or
through joint vehicles. We can all benefit from stronger journalism, not just at home, but also abroad– if anyone needs a reminder that our futures are tied together in an age defined by the climate
emergency and intertwined economies, the coronavirus pandemic has certainly provided it.
None of these policies is a silver bullet, but they can all make a difference for the better, as long as
they are deployed within a framework of fundamental rights and respect for free expression and media
freedom (otherwise they can quickly turn into instruments for state capture).
They all also come with proof of concept, and avoid the uncertainty of betting on opaque arrangementsthat can entrench dominant players and risk primarily benefiting a few large publishers who are often
already doing relatively well.
All these policies, and more reviewed in the report, can offer inspiration for governments who are serious
about supporting independent journalists and news media as they carve out a new sustainable future forthemselves. They offer a chance to break with years of inaction, and an opportunity to reform inherited
arrangements tied to waning media, such as print or broadcast.
A few countries already have some of these policies in place; many countries at least a few of them, but
no country has done all it can to help ensure journalists can continue to do their indispensable work, so
central to the functioning of democracy. The United States, for example, has long been an outlier among
democracies in terms of how little it does to actually support independent news media, and of course
also illustrates the vitriol with which some politicians attack news media that seek truth and report it.
President Biden has at least changed the tone. But will he and other political leaders around the globe
who recognize the real public value of journalism take more tangible steps to support news reporting at
home and abroad?
If governments are seriously committed to creating an enabling environment for independent
professional journalism, they will commit real resources. Journalists – and the public they serve – don’t
need comforting speeches. They need concrete steps. This report identifies some of what can be done.
Now it is up to elected officials and the public to decide if they want less talk, and more action.

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EXECUTIVE SUMMARYA ‘POTENTIAL EXTINCTION EVENT’
Independent journalism is an essential force for democracy and open societies, but is facing an existential
threat from a set of interlocking challenges that, in their scale, complexity, and systemic nature, is akinto its own version of the climate emergency. A hostile political environment at best, and an authoritarian
resurgence at worst; declining revenues as a result of the move to a more digital, mobile, and platformdominated media environment; and fraying public trust has left journalism in a precarious state.
The crisis facing independent journalism is of historic proportions, and it requires those with the power
and foresight to act to confront this crisis with an historic response. The industry is experiencing a‘potential extinction event’ as the certainties (chiefly the advertising-supported model) under whichjournalism operated for 40 to 50 years fall away.
The challenges journalism is facing in many societies are the result of failures, notably by the news
industry itself, in which many have failed to serve significant parts of the public, to truly reckon with why
many people do not trust the journalism they see, and to adapt to the realities of the new environment.
Policymakers, too, have largely continued to apply 20th-century policy and regulation to 21st-century
media and communication environments, and may value incumbent or vested interests over thebroader public interest. And governments, political and private interests are waging a war on journalism
symptomatic of broader democratic failures.

THE NEED FOR A NEW DEAL FOR JOURNALISM
The COVID-19 pandemic has worsened the sustainability crisis of journalism and accelerated the impactof these still unsolved systemic issues. The need for concerted action to overcome these challenges – fora New Deal for Journalism – is urgent, across societies from rich to poor, from the international to the
local level, from cities and suburbs to villages and rural areas: in short, for all communities. Ensuring thesustainability of independent journalism will require action by governments, as well as by journalists,
news media, platform companies, investors, funders, civil society and others.
This report focuses particularly on what governments can do to help ensure sustainable journalism forthe future. As with the climate emergency, there is an urgent need for action, but no single, easy, quick
solution. There are just two alternatives. Governments can do nothing, or, worse still, follow the pathof those governments who are undermining media freedom or dismantling policies already in place tosupport independent journalism. The cost of inaction, or of actively weakening journalism, is incalculable,
as this will weaken our societies and put our political systems at risk.
Alternatively, governments can show their commitment to enabling independent journalism by protecting
fundamental rights, by committing financial and institutional resources, and by convening collaboration
among diverse and even competing stakeholders for the common good.
Acting now will require a commitment of public resources, but will deliver a significant democratic andsocietal return on investment.
It is, we believe, a matter of choice.

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OUR METHODOLOGYThis report identifies a set of policy options for governments that want to act to improve the sustainabilityof independent journalism in their country. It also provides a basic outline for those who want to assess
how their government is doing relative to established international examples of good practice. The
response requires governments to make financial investments, but also investment in institutions andfundamental rights.
We focus on policy options that are evidence-based or at least have demonstrated proof-of-concept, thatcommand broad-based political and public support in the countries where they are already in place. We
look at policies that are oriented towards ensuring the future sustainability of independent journalism,
and not towards protecting the specific interests of any one incumbent industry or organization.

WHAT GOVERNMENTS CAN DO
TO HELP INDEPENDENT JOURNALISM
These options are structured around four areas for action. First, ensuring the freedom that is a necessary
precondition for genuinely independent journalism. Second, enhancing the funding that enables
independent professional journalistic work by supporting independent private sector, public service, andnonprofit news media. Third, creating a more enabling future environment for independent journalism
in part through institutional reform. Fourth, highlighting solutions that point to a more sustainable futurefor journalism.
1. Freedom comes first on our list, because without respect for fundamental rights and media
freedom, no amount of funding or focus on the future will ensure genuinely independent journalism
and, without respect for human rights, government support to media would turn into the means ofmedia capture. Conversely, freedom without funding and an enabling future would leave journalism,
and by extension our societies, diminished and vulnerable. Governments that do not respect free
expression and media freedom typically do more harm than good when they intervene in other partsof the media environment. Media freedom, domestically and internationally, is the bedrock for thesustainability of journalism.
2. One	
substantial indication of whether governments are serious about ensuring the sustainability of independent journalism is their willingness to commit real resources. If governments
globally committed just 0.1% of GDP – half of what some countries already do through direct andindirect measures – the total figure could amount to several tens of billions of dollars annually. To put
this in perspective, this is just 20% of what governments spend worldwide every year on subsidizing
fossil fuels. Public commitments of that order among, for example, the countries that make up the G7,
G20, the Media Freedom Coalition, the International Partnership on Information and Democracy, andparticipating states in the Summit for Democracy would be utterly transformative and could greatly
enhance the quality, diversity, and equity of news coverage globally.
While these funds should ideally come from general taxation rather than hypothecated taxes, thoseworried about the potential additional pressures on public finances can take heart from the fact thatpublic expenditure on journalism may be offset by receipts from new sources. The OECD estimates,for example, that addressing the tax challenges arising from multinationals and digitalization (e.g.,
from companies such as Alphabet, Amazon, Apple, Facebook, and Microsoft) can help raise at least
US$100 billion in tax revenue annually.

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3. By	 contrast, if governments do not act to strengthen the enabling environment for independentjournalism, and if market forces are allowed to play out on their own, there will be few
winners and many losers. The winners will primarily be the platform companies who have grown
to enormous size in the digital media environment, as well as a limited number of up-market, eliteoriented national and international news media serving already well-served audiences. The losers will
include not only the already threadbare independent news media struggling to deal with the impactof the pandemic on top of the already considerable pressures of a more digital, mobile, and platformdominated media environment, but also the citizens they serve across the world, especially in poor
countries, at the local level, and in underprivileged communities.
Acting to ensure the sustainability of independent professional journalism in this situation is notabout propping up ailing incumbents, handing money to proprietors and shareholders, or collapsingback into outdated forms of state aid trying to preserve industries in terminal decline, but about
creating an enabling, competitive environment where it makes sense to invest in news production.
That includes favoring nonprofit journalism, developing competition and platform policies that enable
journalism to thrive in digital markets, and opening multiple routes through which journalism can findsupport.
4. The	
report highlights other areas for support that can help journalism transition at speed andat scale to a new and more equitable future. While the challenges the field faces are real, there arealso positive signs in many places that point to a future in which independent journalism can have agreater say over its own future.
Internet users have access – where barriers or controls are not put in their way – to more diverse
news and information than ever before in human history, and new ways to access content, express
themselves, connect and communicate with others, and organize. We are also seeing the rise ofcollaborative journalism; open source investigation and data journalism; a strong growth in reader
revenue and donations among high-quality news publishers; improving business practices; newforms of engagement with audiences, including through membership and co-operative ownership;
and increased donor and investor interest.
This report provides a list of recommendations for those who prefer action over inaction, a list thatprovides policymakers with options that already have evidence or proof of concept, and that provides
citizens and others who hold policymakers to account with a simple scorecard for assessing how theirgovernment is doing.
Acting now, by funding journalism, comes with a cost. But the cost of inaction is incalculably
greater.

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KEY RECOMMENDATIONSTO ENSURE THE SUSTAINABILITY OF INDEPENDENT PROFESSIONAL JOURNALISM
AND NEWS MEDIA, THERE ARE A NUMBER OF MEASURES THAT GOVERNMENTSSHOULD TAKE.

FIRST, ENSURE THE FREEDOM THAT IS A NECESSARY PRECONDITION
FOR INDEPENDENT PROFESSIONAL JOURNALISM AND NEWS MEDIA AND THEIRSUSTAINABILITY:> Honor all their domestic and international commitments to fundamental human rights andclose the implementation gap between treaties and the situation on the ground when it comes tofreedom of opinion and expression, media freedom, and the safety of journalists.
>E nlarge, deepen and implement the Partnership on Information and Democracy, which is aframework for the creation of democratic safeguards in the global information and communication
space, including for the right to information.
>D omestically, they should ensure:• full transparency of media ownership as part of broader transparency, anti-corruption andfinancial integrity measures – especially disclosure of the beneficial (ultimate) owners of media
outlets – so citizens can form their own view about any potentially undue political or commercial
influence.
> Internationally, they should ensure that:• the international community uses the instruments and means at its disposal to push all states
to progressively realize their obligations: to counter regression, this will require new levels ofcooperation through existing and emerging bilateral, plurilateral and multilateral relationships,
instruments and mechanisms, including trade & aid;
• online content moderation, whether done entirely unilaterally by individual for-profit privatecompanies, under some form of self-regulatory or co-regulatory oversight, or done on the basisof regulation and/or at the behest of governments submitting requests to companies, is done on
the basis of Community Standards/Terms of Service and/or a legal basis that is fully compliant
with international standards, and is consistent, transparent, and provides due process.

15

SECOND, PROVIDED CITIZENS CAN BE CONFIDENT GOVERNMENTS ARE DEMONSTRABLY
COMMITTED TO THE FREEDOM AND NOT THE ‘CAPTURE’ OF INDEPENDENT JOURNALISM
AND NEWS MEDIA, CONSIDER IMPLEMENTING DOMESTIC AND INTERNATIONAL
POLICIES THAT HAVE A PROVEN TRACK RECORD OF ENHANCING THE PLURALITY ANDSUSTAINABILITY OF FUNDING, AND CAN COMMAND BROAD POLITICAL AND PUBLICSUPPORT TO ENSURE A STABLE ENVIRONMENT, INCLUDING:> Direct domestic support for independent professional journalism and news media, on a legal, fair,transparent and equitable basis, and with safeguards against real or perceived ways of influencing
editorial content, such as:• direct subsidies, whether direct or through independent intermediaries, in ways that do notprivilege old-fashioned forms of distribution and that are tailored to support local journalism andjournalism serving underserved, underprivileged and marginalized communities;• full transparency of government advertising, and ensure, through consultation, legislation andregulation, fairness, equity and transparency in how, by whom and to whom it is allocated, inorder to prevent market distortion, the strengthening of government-friendly media and the ‘soft
censorship’ of independent media;• ensuring that public service media are genuinely independent from political interference orcontrol in their governance, operations, finance, and editorial, with a clear remit, ability to operate
across all relevant platforms, and appropriate, stable, long-term public funding.
> Indirect support for independent professional journalism and news media, offered with safeguards
against real or perceived ways of influencing editorial content and not tied to specific forms of
distribution, such as:• VAT and tax exemptions, tax relief on editorial roles, and other forms of tax credit;• mechanisms for citizens to support independent media of their choosing through media vouchers,
tax relief on subscriptions, or income tax designations.
>D irect international support for public interest journalism and its enabling environment by committing
publicly a substantial, increased part of official development assistance (ODA) budgets as part of broader
support for democracy, transparency and good governance, ensuring the proper independent, fair andtransparent governance and allocation of such funds, and improving data standards and knowledgesharing around such funding.
>S upporting the growth of mission-driven investment for journalism businesses by:• supporting and underwriting national and international blended finance vehicles or other social
investment mechanisms;• providing specific incentives (e.g., write-offs) to investors who sell or transfer local media topublic-interest/mission-driven investors;• incentivizing investors to provide greater access to capital for public interest journalism founders
and investors from diverse or marginalized backgrounds.
>E nsuring that philanthropy has the freedom to operate within and across borders, and that
regulatory frameworks enable philanthropy to fund for-profit as well as nonprofit media.

16

THIRD, BEYOND IMPLEMENTING ONE OR MORE OF THESE POLICIES,
GOVERNMENTS COULD FURTHERMORE CREATE A MORE ENABLING
FUTURE ENVIRONMENT FOR INDEPENDENT JOURNALISM AND NEWSMEDIA BY:
> Easing the creation of and incentivizing support within and across borders for nonprofit news
media, through, where relevant, reform of tax codes, charitable frameworks, company formation andinternational equivalence, in order to enable the emergence of a class of independent professional
media focused solely on public interest goals.
>S upporting, adopting and improving proposed international measures on taxation such as aminimum global corporate tax rate (including the proposed OECD, G7 and METR [Minimum Effective
Tax Rate] models), and supporting independent journalism out of the increased tax take.
>A cting to ensure commercial digital markets are competitive, by examining the need formeasures on, for example:• data access, portability, and multihoming/interoperability;• increased focus on data and non-price competition in competition enforcement;• greater scrutiny of mergers and acquisitions, including considering data collection and otherissues that may not raise traditional red flags;• and greater scrutiny of situations where there are dominant players who may both be the market
and be in the market.
> Instructing independent regulators in media, internet, communications, privacy, & competition
to examine the interplay of privacy, digital ad markets, social media and related fields.
> Funding and supporting the domestic and international field infrastructure that can carry out
policy and advocacy work to defend the rights of journalists and news organizations, and advocate forpolicy and regulations in line with those rights and standards.
> Lowering the costs of independent journalism and open-source intelligence, through:• respect for and implementation of freedom of information access laws;• adoption and implementation of international open government standards, including on public
procurement and contracting, and publicly accessible open data.
>P roviding structural support to the knowledge infrastructure of the field, such as funding for:• lifelong training of journalists and updating of curricula and methods;• increased resources for industry-relevant applied research and industry data;• increased funds and incentives for R&D for innovation;• the inclusion of journalism and media as a strategic sector in national AI strategies, and as acomponent or focus of centers of expertise in AI/ML and other advanced computation methods.

17

INTRODUCTION
The world is in the grip of multiple crises: the climate emergency, a global pandemic,3 a democratic
recession,4 an authoritarian resurgence,5 growing inequality,6 gender inequity,7 labor rights andautomation,8 and mis- and disinformation.
Solving these crises will be exponentially harder unless we solve a crisis that weaves through them all:the crisis facing independent professional journalism, a crisis that the Secretary-General of the United
Nations says could result in an ‘extinction event’.9
Independent journalism is essential to democracy and open societies. But journalism is facing an
existential threat in the form of interlocking challenges that in their scale, complexity, and systemic nature
are akin to its own version of the climate emergency. Responding to this emergency requires immediate,sustained, and substantial action, collaboration among diverse, even competing stakeholders, and thecommitment of financial and institutional resources – within and across borders.
As with the climate crisis, if those with the power to act do nothing, delay taking action, or worse, actively
harm journalism, the consequences for society and democracy are likely to be catastrophic. Allowing – or
causing – independent journalism to atrophy is already increasing information inequality, undermining
democratic participation, and even, as we have seen during the COVID-19 pandemic, threatening publichealth and national security.
To avert this crisis, tens of billions of dollars over the next decade are needed worldwide to secure andstabilize the journalism and high-quality information that our societies need. This report sets out ways inwhich this challenge can be met.

An essential service at risk of extinction
In the early stages of the pandemic, some governments took the opportunity to further weaken andcontrol independent journalism.10 Others, however, chose to recognize the centrality of journalism toopen, healthy societies by designating it an essential service, and journalists as key workers,11 defending
freedom of expression.12
Independent journalism is essential to how societies establish and make accessible shared facts andtrusted information, so that citizens can make sense of and participate in the world around us, andmake better informed decisions about our lives13 – never more crucial than in a global health emergency.
Independent journalism in its various forms – whether from broadcasters or podcasters, newspapers
or YouTubers, fact-checkers or cartoonists – contributes to a more informed and active public, serves
the public interest, not just the interests of those who use the news, and is as a result a cornerstone ofdemocracy and open societies.
Academic research provides evidence that following the news helps people stay more informed aboutpublic affairs, participate in the political process, and engage with their communities.14 Independentjournalistic scrutiny also serves the public interest above and beyond the value it provides to those
who follow the news. Research suggests investigative journalism can help hold government and private
institutions accountable to the public by exposing abuse of power by politicians or corporations, canreduce the risk of corruption and misuse of resources, and help ensure elected officials represent theirconstituents’ views.
18

Civil society15 and citizens can of course contribute to these things too, but they can’t replace the roleof journalistic scrutiny. Many have come to realize that the extinction of independent journalism will
damage the wider democratic ecosystem irreparably.

Why is independent journalism under pressure in a changing market?
The market dynamics that underpinned the advertising-enabled model of journalism for 40 to 50 years
have undergone radical disruption and erosion in the last 20 years.16 The trends driving these changes
have only intensified and sped up across the globe – at different speeds and with different effects
depending on local conditions – as a result of the pandemic, digitalization and the ‘war on journalism’.17
One interviewee described this as a ‘slow-motion car-crash’.
This leaves independent journalism in an incredibly precarious position, with negative impacts on citizens’
ability to access quality information. Policymakers and decision-makers need to understand how this hascome about in order to reach for the right levers in this time of crisis.

An attention economy
In short, journalism, newspapers in particular, used to be an attention business. Those who could meetthe high barriers to entry had fewer competitors, and were able to bundle together many types of content
and services – including journalism – as ‘news’ for their captive audiences, whose attention they could
package and sell at high rates to advertisers who wanted to reach them. The healthy profits they wereable to make from giving the advertisers access to their audiences gave the impression that journalism
itself was a profitable business, but merely masked the fact that advertising revenues paid for the bulk ofjournalism because advertisers had fewer other options. This was important because in many societies,
newspapers did and still do produce most original reporting.18
Print circulations were already in decline in many societies when news was unbundled – undercut asservices once bundled together as a newspaper, such as weather, sports scores, classified ads, have eachbeen done better, faster and cheaper by digital upstarts. Barriers to entry have dropped sharply, making
the market more crowded and more competitive. The share of media use represented by news – 10%
to15% during the offline world – is no more than 3% to5% of users’ time in the digital, mobile and social
era.19 Just 17% of respondents to another study were highly engaged news users,20 making news media
even less attractive to advertisers, and former advertising rates and profits impossible to regain.

Winners take most in advertising and in journalism
Advertisers will follow users’ attention to venues where they get more value for money, and many clearly
prefer the cheap, targeted advertising offered online, where publishers compete with platforms for bothusers’ attention and advertisers’ budgets. The platform economy is a winner-takes-most market, characterized by economies of scale, network effects, and data network effects – the big get bigger, attract moreusers, stockpile more valuable data, and attract advertisers. A few big platforms now dominate digitaladvertising: nine of top ten sellers of digital advertising globally are platforms and one media-owning
telecommunications company.21 For independent news media, the considerable pressures produced by
the rapid move to a more digital, mobile, and platform-dominated media environment are now combined with intense – and in some contexts cross-border – competition for attention, advertising, andconsumer spending.
19Similar winner-takes-most dynamics are playing out within journalism, in which a handful of already successful media become more so, and thus are able to invest across their businesses, attract ever-greaterpaying audiences, produce high-quality content, and entrench their dominance over the market. The
English-language New York Times, for example, has driven a tenfold increase in its digital subscribers(now 6.7m internationally) between 2012 and 2020.22 In most national markets, a few upmarket titles,
often legacy newspapers, account for a majority of digital subscriptions, and a limited number of new
digital-born entrants are doing well.23 But even in wealthy markets, other independent news media – especially at the local level – are fighting over scraps.24

The cost for open societies
These dynamics mean that the journalism most crucial in open societies – public interest, investigative,
local – can no longer be paid for in the same quantities as in the past, and if journalism is not to disappear,
new and diverse ways of financing must be found. If market forces are allowed to play out on their own,
there will be few winners and many losers, with widely documented negative impacts for democracy,
scrutiny, and social cohesion, especially at the local level.
While a few winners manage to succeed, most cannot. Many independent media shrink or close; alreadythreadbare public interest reporting shrinks further; news deserts continue to grow, and, as natureabhors a vacuum, other forms of less reliable information take their place. The gap between the havesand have-nots is worsening, both in terms of those who can afford to access high-quality journalism, andthose who are producing it. A privileged minority of affluent, highly educated news lovers have morechoice than ever, with many different publications catering to their interests and needs. But most of the
public in most places around the world risk being worse off in terms of news provision and coverage.
Because of the public value of independent journalism, we will all suffer as a consequence.

The rationale for intervention to meet citizens’ information needs
Independent journalism is crucial to meeting the evolving information needs of societies and citizens.
But the equation of how this gets paid for cannot be solved with magical thinking. As with the climate
emergency, resources should focus on urgently supporting measures that are already shown to improve
the sustainability of independent professional journalism – by which we do not mean positive topline
revenues, but models that prioritize investment in editorial, have diversity of provision, and reach andequity across the population at large (as well as addressing their own climate impact).
Acting to ensure the sustainability of independent professional journalism in this situation is not aboutpropping up ailing incumbents, handing money to proprietors and shareholders, or collapsing backinto outdated forms of state aid trying to preserve industries in terminal decline. It is about creating an
enabling, competitive environment where it makes sense to invest in news production.
Ultimately, investment in journalism, not media industry revenues, is the central issue. The percentage
of industry revenues going to news production varies hugely by sector – from a low 4% in television anda somewhat higher 23% in newspapers, according to one UK estimate, to more than 50% in many digitalborn news media.25 There are no guarantees that a set portion of advertising or consumer spending will
go to specific companies (revenues are not a right – they have to be earned). Instead, the focus should beon incentivizing investment in journalism and ensuring that news media have a fair chance to compete in
the marketplace. What matters from a public interest view is not whether proprietors and shareholders

20

get rich or what industry topline revenues are, but whether money is invested in independent professional
journalism, and whether journalism serves the whole public, not just affluent, educated, urban elites.
As with the climate emergency, which affects all of us but disproportionately impacts on the poor andmarginalized, addressing the challenges facing journalism and helping it to adapt and transition to newmodels is urgent for all of us at all levels and in all sectors. No single actor or measure can ‘save journalism’
alone – responding to the crisis will take many years and multiple steps, and will involve many different
actors with different interests and incentives.

The role of governments
Governments are one such actor and have an important role to play. The pandemic has shown that,when circumstances demand, governments can choose to recognize the scale of the challenges, forgetbusiness as usual, and take decisive action. The crisis facing journalism calls for similarly bold decisions.
The working group does not believe that governments can on their own avert all the challenges independent
professional journalism faces, or that governments should try to act to avert all these challenges on theirown. They can do more harm than good, especially in countries where neither citizens nor journalists canhave confidence that government interventions are in the public interest and will respect fundamental
rights, journalistic independence, and media freedom. But, as with the climate emergency, governments
must decide where they stand – as part of the problem, or as part of the solution.
The purpose of this report is to enumerate evidence-based, broadly supported steps that policymakers
in rights-respecting governments could take to create a more enabling environment for independent
professional journalism to thrive. These steps that governments could choose to take – alone and together– would make a meaningful difference without distorting the market, creating perverse incentives, orundermining fundamental rights. It is important to identify and describe positive examples of such steps
so that elected officials and other policymakers can consider their options, and adapt these measuresin their specific settings to stabilize, unshackle and grow their independent journalism sectors, because
this is beneficial to society. And it is important to recognize that continued inaction is a political choice
too – and brings its own costs.
This report highlights the most promising and feasible steps that can help to unlock substantial andtransformative resources for independent professional journalism. What this report identifies is that,while many actors can take actions that could make an incremental and material difference to thesustainability of journalism, systemic change will only come when underpinned by concerted government
action, domestically and internationally.
This report encourages those who can to muster the political will and know-how to act.

Approach
In the following sections, we set out the principal interventions that meet the central criteria for thisreport: that they are future-focused, and not seeking to restore a romanticized or anomalous past; thatthey are evidence-based; and that they might be able to command broad support. The working group21

approached this in two ways – by extracting general, high-level types of action that governments andothers can take, in the expectation that these need to be discussed and set within a local context; and by
spotlighting a few specific examples of good practice that merit closer examination.
There are few countries and markets that are not affected by the dynamics described above, or somecombination of them. What kinds of principles and values are essential parts of fostering an environment
in which independent professional journalism can thrive, can be sustained, in the context of this changing
market and changing audience preferences, and the implications this has for the way journalistic work
is organized and paid for? If the aim is to ensure that the overall enabling environment for independent
professional journalism has access to a diverse range of potential sources for revenue, governments
and other actors have a range of levers that they can pull in order to create better conditions for this tohappen – and a range of indicators against which to score progress.
Alongside the work of press freedom organizations to document abuses and violations (for instancethrough the World Press Freedom Index published by Reporters Without Borders [RSF]), the media
development sector has built media viability indicators – notably UNESCO26 and a related set by Deutsche
Welle Akademie27 – to help diagnose healthy or unhealthy media environments that support the viability
and sustainability of journalism organizations. These evolving approaches encompass the full range
of factors bearing on independent media, from the political, legal and regulatory, to the financial andtechnological, and are a key tool for assessing whether media environments would foster sustainable
journalism. Wider industry research includes World Press Trends (and other reports) from WAN-IFRA (theWorld Association of Publishers).28 The unevenness and lack of reliable open data constrains the range
of options that can be presented to policymakers. We have seen little evidence of combination of thesekinds of data with data on, for example, inequality, gender, health, digital inclusion, and other public
interest factors. For policymakers working on the sub-national level, however, there is work of increasing
sophistication emerging on local media ecosystems.29
Other relevant research includes the European University Institute’s Media Pluralism Monitor, the Media
Ownership Monitor, initially launched by RSF, which evaluates ownership of media companies in a
selection of countries around the world, the forthcoming EU Media Ownership Monitor, and research
emerging on financial flows in a number of media environments, conducted by the Center for Data,Media and Society at Central European University.30 We point to relevant indices and data sources on the
Enabling Environment – such as greater government transparency – in more detail in the Appendices.
The interventions outlined below are only appropriate in countries that have established their credibility
in this area through high media freedom and low corruption, or are demonstrably on a direction of
travel towards these benchmarks. The risk of undertaking these measures in countries that do not meetthese criteria is that either they will be used to advance media capture, or citizens will perceive them asillegitimate and being used for media capture.
Where states have not taken these measures or ones like them, and find their media sectors in crisis andthe information needs of their citizens poorly met, this has to be considered in part the result of politicalor ideological choices, rather than of rational consideration of the evidence, and the most appropriate
course of action to protect and promote journalism (in accordance with their international obligations).
There are also numerous risks for governments embarking on such measures and reforms, some ofwhich have been on display already this year.

22Chapter 1:

Freedom

23

There are, however, a number of factors threatening independent professional journalism, and there aremany things governments and others can – indeed must – do to address them.
Governments and policymakers are aware of their positive obligations31 under international and national
law to protect and promote freedom of expression and of information, media freedom, and the safetyof journalists (including the disproportionate impacts for women online and offline).32 Despite this, it haslong been a challenge getting states to live up to those obligations, and to find effective enforcement
mechanisms when they don’t.
A growing number of governments, politicians, judiciaries,33 and sometimes private interests34 actively
undermine free expression, independent professional journalism, and media freedom. From crude
physical and personal threats, through more insidious financial and economic measures,35 judicial
and legal harassment (‘lawfare’), and digital attacks, these all occupy the time, energy and resources of
independent journalism, leaving it less able to pursue its core mission of serving the public interest. This
severely curtails the sustainability of journalism at the level of individual journalists, of the outlets theywork for, and of the independent sector overall. The COVID-19 pandemic has exacerbated the financial
and operational fragility of thousands of already precarious journalism organizations worldwide, asituation which some governments have exploited to enact more restrictive and punitive measures.36
This is occurring both within and across national borders, is often disproportionately targeted at womenand minorities, and comes within a wider context of erosion of democracy and rising authoritarianism.
These methods are now being used by democracies and institutions of democracy, making backsliding
hard to spot and push back against.
Initiatives through the Council of Europe37, the Media Freedom Coalition38 and the High-Level Panel on
Media Freedom39 are attempting to tackle this. States in these and other forums like the Initiative on
Information and Democracy,40 the Community of Democracies, and the Summit for Democracy mustback up the symbolism of their participation and endorsements with concrete measures to protect andresource independent journalism.
Other multilateral and plurilateral venues in which media freedom and sustainability are standing or
emerging issues include the Alliance for Multilateralism, the G7, (most firmly in its Foreign & Development
Ministers Communiqué on 5 May 2021), the G20, OECD, the Open Government Partnership, theInternet Governance Forum, and the World Trade Organization (WTO).41 As noted below in the section
on Taxation, recent reports from the UN’s FACTI panel and the 2025 Declaration of the Addis Taxation
Initiative particularly note the enabling role that media, and investigative journalism in particular, play incombating illicit financial flows, and in upholding financial integrity – something that international andregional development banks ought also to pay attention to.

24

FREEDOM

Without media freedom, journalism cannot be sustainable, because there is no journalism worthy of thename. And without financial viability and sustainability, media cannot be free.

CHAPTER 1

WITHOUT MEDIA FREEDOM, THERE IS NO
JOURNALISM SUSTAINABILITYOur research tells us that a key limitation of progress in media freedom is the burden on understaffedand overstretched policymakers and public servants, outside a handful of better-resourced jurisdictions,to:> operate within the right combination of law, policy and regulation that responds to both thecurrent and future environment;> have independence from or capacity to face off against lobby interests.
This leaves these policymakers reliant in part on trickle-down analysis and legislation from the EU, USA,
UK, Australia, Scandinavia and similar jurisdictions, although these are fundamentally different societies,
markets and journalism cultures. One interviewee said that a lack of strategic action and support bymajor democracies for policymakers in low- and middle-income countries, and in smaller countries, hadleft the terrain free for “the competition”: off-the-shelf legislation and other measures from Russia andChina.
There are many current and recent analyses of media freedom, with many recommended steps that states
can take to come into compliance with these standards, as well as promoting them. We will not retread
these here, beyond providing recommendations on this area that bear directly on the sustainability ofjournalism.

R ECOMMENDATIONSTO STATES> Enlarge, deepen and implement the Partnership on Information and Democracy,
which is a framework for the creation of democratic safeguards in the global
information and communication space, including for the right to information.
> Honor their commitments and obligations under international human rights law
to respect, protect and promote freedom of expression and other fundamental
rights.
> Close the implementation gap between treaties to which they are signatories
and the actual situation on the ground in terms of freedom of expression and of
information, media freedom, and the safety of journalists (e.g., by developing a
multistakeholder National Action Plan for the Safety of Journalists), and ensurethat domestic policy and foreign and development policy on these rights arealigned.
States should also take regulatory measures that strengthen media sustainability
and independence, including:> As part of broader transparency, anti-corruption and financial integrity
measures, implement and publish transparency of direct and beneficial
ownership of media, in order to facilitate full transparency of media ownershipand true measures of media concentration as a key enabler of citizen anddemocratic scrutiny of commercial and political influence in society.
25

CHAPTER 1>h ave the actual tools and instruments to do something about it, including in concert withcolleagues in related departments, or regulators;42

FREEDOM>u nderstand the complexity, and interlocking parts of the new environment and what policy cando;> Ensure sufficient and stable funding for the work of Representatives andRapporteurs for international institutions (e.g., UN, OAS, Organization for
Security and Co-operation in Europe [OSCE], African Commission) and of theHigh-Level Panel of Legal Experts on Media Freedom, to document abuses ofpress and media freedom (including under COVID-19), develop solid, practicable
responses to evolving threats, and reaffirm and rearticulate the value ofjournalism.
> Engage in plurilateral and multilateral forums focused on media freedom, and inother international and regional forums such as the G7, G20, OECD, Organizationof American States (OAS), Association of Southeast Asian Nations (ASEAN), theAlliance for Multilateralism, the Open Government Partnership, the Communityof Democracies, and the WTO, in order to engage, influence and collaborate
with other governments, and to hold to account governments violating their
obligations.

26

CHAPTER 1> Ensure the transparent operation and governance, operational independence,adequate funding and staffing, and financial autonomy of regulatory bodies
overseeing these and related areas.

FREEDOM> Ensure transparency around advertising markets, including digital andpolitical advertising markets, and specifically, an independently governed andoperated, transparent, fair and equitable system of oversight and allocation forgovernment advertising in media, including transparency of related data.

Chapter 2:

Funding

Contents
2.1 REACH 0.1% OF GDP ANNUALLY FOR A DECADE TO ENSURE JOURNALISM’S SURVIVAL AND
TRANSITION
2.2 PUBLIC FUNDING
A note on public resources for journalism
2.2.1 D irect subsidies, funds and incentives
Direct domestic subsidies through independent intermediary funding bodies
Direct international subsidies through independent intermediary funding bodies
2.2.2 Public service media
2.2.3 Direct international subsidies: Aid, trade and democracy assistance2.2.4 Indirect subsidies and incentives
Indirect subsidies for news media
Indirect subsidies via citizens
Limitations of indirect measures
2.2.5 Transparent, fair government advertising
2.2.6 Investment – including public/private agreements
2.3 PRIVATE PHILANTHROPIC FUNDING

27

The commercial advertising-driven model that was held to be the cornerstone of independence for solong is under great pressure in many societies. The vacuum left by commercial advertising revenue has
been in part replaced in many societies, especially lower-income countries, by government advertising.
Often untransparent and politically aligned, this funding is directed away from independent media,
towards politically loyal media, strengthening the latter, and further weakening the former.
Some governments – and private media – are aggressively pushing for cuts to funding for independent
public service media at the same time as their universal service obligations require stretching into new
platforms: never more crucial than during a global health emergency. With independent journalism
weakened and public service media spread ever thinner or co-opted, pushing back on information
disorders43 becomes ever more difficult – especially when politicians and media are playing a role infueling and manipulating that disorder, often against independent media themselves.
The result for citizens is an ever-deepening information inequality – some superserved with high-quality
journalism, others reliant on an unpredictable mix of distributed sources – and greater vulnerability
and volatility. Of course, journalism is not sitting on its hands during this crisis. We have seen countlessexamples (highlighting some in Chapter 3) of great entrepreneurialism and reinvention, in addition to
the creativity, commitment, and public value that are core to journalism, which offer hope to the field.
As with other complex emergencies, however, it is now clear that the nature of the crisis facing journalism
is so extensive that governments need to play a role – beyond usual political cycles and calculations – in
confronting and overcoming it. The size of the crisis, and the potential impact of not addressing it, merits
thinking on the scale of the New Deal, and the Green New Deal. The consensus in our research is that thiswill take multiple steps and the combined effort – over a decade or more – of governments, regulators,
industry bodies, investors, funders, the tech sector, civil society and independent journalism itself toarrest and move beyond this crisis.
Accordingly, we believe that, for the next ten years, rights-respecting governments globally shouldcommit 0.1% of GDP to confronting this emergency both at home and abroad. Some governments
already do, and if more governments honored their commitments to fundamental rights andmade similar support, the value directly and indirectly to the journalism field could amount totens of billions of dollars a year.

28

CHAPTER 2

Why are we calling on rights-respecting governments to intervene to support independent journalism
when the orthodoxy of recent decades has been that – in general – governments should be kept as far
from journalism as possible? The new market conditions in which journalism – even nonprofit journalism– lives mean that it is all but impossible to achieve independence, stability, pluralism, diversity, and quality
without a major reset.

FUNDING

2.1 REACH 0.1% OF GDP ANNUALLY FOR
A DECADE TO ENSURE JOURNALISM’SSURVIVAL AND TRANSITION

Tens of billions of dollars a year appears to be a large, unattainable figure – but taking into account thevalue of many measures already in place, aspiring to reach it begins to seem less fanciful:> Direct funding, such as direct subsidies, as in Denmark (0.21% of GDP) or in France (€1.7 billion),competitive or selective funds, as in New Zealand, and through the funding routed through public
service broadcasters (PSB) to the wider independent sector, which collectively would amount toperhaps the low hundreds of millions of dollars.

> ODA for media currently amounts to just US$450 million worldwide, of which just 17% is spent onjournalism, and against the backdrop of the larger domestic assistance given in some countries,
raising this to US$1billion annually appears persuasive.
> Any public expenditure on journalism could perhaps be offset by the revenues raised throughglobal tax agreements related to multinationals and digitalization, and aside from any global
corporate tax changes, platform companies might also be persuaded to upscale and systematize
their corporate giving to journalism.
For comparison, in Europe, the European Broadcasting Union (EBU) estimates44 that total operating
revenues for public service media are approximately €35 billion, and while this is declining year-onyear, it still represents 0.16% of GDP in the 56 countries of the EBU. Reaching 0.1% to fund the wider
independent professional journalism ecosystem through other measures seems, in that context, lessunrealistic and more achievable.
Making a concerted effort across dozens of countries to approach this figure would represent a huge andtransformative leap in funding to the field, and the best possible chance for societies around the world
to protect and grow pluralism in the journalism sector, in its sources of finance and funding, and in its
future directions.
Rights-respecting governments have numerous tried-and-tested levers that they can choose to pull tostart to make a difference. Some involve structural or systemic changes, some involve compliance withinternational processes and standards, and others are measures that would have a cost, but in all thesecases, such measures cannot come too soon. Inaction, delay, timidity, and short-termism46 have tangible
and damaging costs too. Taken together, we believe these measures offer a springboard from whichgovernments and other stakeholders can launch a New Deal for journalism, in their own countries andinternationally, so that, by 2030, independent professional journalism will be in good health.

29

CHAPTER 2> Philanthropic grantmaking to and private investment in the journalism and news media sector
is nascent and/or constrained in many markets and across many borders – with more conduciveand consistent rules, with wider possibilities for funding for-profits and nonprofits, and withmore options for blended finance vehicles, these would only grow.

FUNDING> Indirect measures, such as reduced or zero value-added tax (VAT) for news publications, which
can amount in some countries to hundreds of millions of dollars, and if applied more consistently,
could represent many billions globally; tax relief on digital subscriptions, or even media voucher
schemes, would represent further hundreds of millions globally as reader revenue grows inimportance and advertising revenue diminishes.

2.2 PUBLIC FUNDING

The multiple crises facing journalism are forcing even countries with a supposed history of nonintervention to consider targeted measures, and those with existing schemes to re-evaluate theireffectiveness. Governments can anchor, convene, underwrite and catalyze broad efforts to address awide range of seemingly intractable problems like the crisis in the sustainability of journalism.51 Twoexperts specifically justified such good-faith government interventions in the sector domestically andthrough foreign aid (see section on ODA below) as a means of defending not only democracy (including
electoral integrity), but also national security and sovereignty, with the caveat that this is an argument
also employed by governments with more authoritarian tendencies, like Poland and Hungary in the EU.
Research indicates that there are a number of measures that have been taken in some countries, regions
and cities that, with appropriate analysis and localization, could be applied elsewhere – with a number ofcaveats about the credibility, independence and arm’s-length relationship with such measures being ofparamount importance. Such measures could have a material impact on the viability and sustainabilityof journalism businesses and organizations across the sector, as well as those most specifically focusedon the public interest.
The Recommendations focus on five particular means of direct and indirect subsidy to media organizations,which are broadly speaking transparent and accountable to the public (though, if improperly applied,
noting the risk of media capture).
1. Direct domestic subsidies from governments to journalism and infrastructure organizations.
A few governments (e.g. Denmark) provide direct ongoing transfers of funds to all qualifying
journalism organizations within certain public interest criteria – this has also occurred during the
pandemic in the form of emergency relief funds (e.g. New Zealand). (See 2.2.1)
2. Direct domestic subsidies through independent intermediary funding bodies.
Governments at the national, regional and local levels have begun to provide sums to independentintermediaries – nonprofits, philanthropic foundations, and other expert bodies – for selective,competitive grants and investment schemes to support journalism. (See 2.2.1)

30

CHAPTER 2

Research has found that in high-income countries, indirect subsidies such as VAT exemptions forprivate print media and newspapers match and sometimes outweigh direct subsidies to public service
media.49 The nature of the support needs reinventing for the new environment, however, as ‘public
support remains, first, heavily weighted in favor of legacy organizations and industry incumbents, mostimportantly public service media organizations and print publishers; and, secondly, is overwhelmingly
built around inherited media platforms like broadcasting and print.’ 50

FUNDING

There is widespread precedent47 for governments using subsidies to reduce the costs of market entry,
production and distribution for journalism. Subsidies48 can be direct, to individual businesses andorganizations, including public service media, or indirect, by removing or reducing costs at the systemlevel, for example, through tax exemptions or relief.

3. Direct subsidies to public service media through a range of mechanisms.
At their best, these provide a government-legislated, publicly-paid, long-term settlement for public
service media, anchoring public interest values and information, and enabling them to play acatalytic and commissioning role in the wider creative economy. (See 2.2.2)
4. Direct international subsidies, including through independent intermediary funding bodies.
Government departments focused on aid and trade may choose to supporting journalism andmedia freedom internationally through development and democracy assistance, by providing
funds to independent intermediaries to disburse locally, regionally or internationally, or in rarecases, through direct grants to larger organizations and incentives in the trade system. (See 2.2.3)

The report also highlights the pivotal role played by:> Investment capital and mission-driven investors (See 2.2.6)> Philanthropy (See 2.2.7)> The wider enabling environment (See 2.3)

A NOTE ON PUBLIC RESOURCES FOR JOURNALISM
Any commitment of public resources to enhance the sustainability of independent journalism should
ideally come from general taxation. While hypothecated taxes (also known as ring-fenced or earmarked
taxes) are widely advocated and tempting to include in policy options, partly because they appear
transparent and must be spent on the area to be financed, they have long been considered ineffective,
can fluctuate wildly, and are vulnerable to unintended consequences.52
That said, in situations where public trust in government is low, and where the public finances can ill
afford additional pressures alongside other pressing needs, it is possible that public resources may
be offset by receipts from new sources. Momentum generated by the June 2021 G7 agreement on a‘minimum level of global taxation’ will carry forward into wider discussions and frameworks at the G20 andOECD. The OECD estimates, for example, that addressing the tax challenges arising from multinationals
and digitalization (in large part associated with platform companies such as Alphabet, Amazon, Apple,
Facebook, and Microsoft) can help raise U$100 billion in tax revenue annually53, although what this will
look like in lower- and middle-income countries is still uncertain.54 (See also section 3.1.3.)

31

CHAPTER 2

Governments, and finance ministries in particular, provide significant support to publishers throughindirect means, such as lower or zero VAT rates, and other taxation or fiscal benefits, althoughthese are often designed for legacy rather than contemporary media environments. (See 2.2.4)

FUNDING

5. Indirect domestic subsidies through the tax system and other means.

2.2.1 DIRECT SUBSIDIES, FUNDS AND INCENTIVESDIRECT SUBSIDIES FROM GOVERNMENT

Such subsidies are provided in Denmark55 according to clear criteria,56 including investment in editorial,
and are capped at a very low bottom threshold and at a medium-sized top threshold to avoid oversupporting bigger market players and to concentrate their focus on local and smaller niche publishers.
The Danish model, which emerged partly from a 2011 report advocating a shift from funding basedon circulation,57 has succeeded in commanding widespread support partly due to the multistakeholder
negotiations, between the government, the news industry at large, and the unions. The EU has examinedand praised the Danish settlement for not violating State Aid rules. That said, this came against a backdrop
of a 20% cut in 2023 for Danish public broadcasters.58
In France, direct support to the media, in the form of les aides de la presse amount to €1.8 billion a year
(almost €6 billion including audiovisual and a grant to Agence France Presse),59 but are widely felt torequire urgent reform, as they particularly focused on print distribution, which privileges media serving
predominantly older audiences, rather than being more equitably distributed through the contemporary
media system. In April 2021, the French Ministry of Culture announced a proposed set of changes to thescheme, including linking eligibility to the number of editorial posts.60
Canada’s package of support61 has received both praise for the scale of its ambition (CA$600 million), andcriticism for its preferential treatment for certain kinds of organizations that qualify for support.62 New
entrants have criticized it and have been spurred into creating a new association of smaller independent
publishers in response.
During the early stages of the COVID-19 pandemic, some journalism sectors were able to persuade theirgovernments to release emergency relief funds to journalism organizations, including Australia, Canada,
Denmark,63 New Zealand, Norway, and Sweden. A number of these were renewed as the pandemic
continued to create ever more adverse conditions for media organizations.

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CHAPTER 2

Direct subsidies are generally allocated on a proportional basis for a particular purpose against certain
criteria (e.g., level of editorial investment, nonprofit status, membership of an official industry body,geographic location). These require multistakeholder consultation, so as to ensure that they do notprovide perverse or unbalanced incentives to particular market participants, and that they incentivize
the kinds of journalism provision that delivers public value over and above the sum of the subsidies.

FUNDING

Direct subsidies from government out of general taxation have a range of benefits – particularly that,in rights-respecting countries, they are transparent, publicly accountable, and relatively predictable.
Direct general ongoing subsidies for private news media (whether for-profit or nonprofit) make a directcontribution to organizations that are providing public value through their journalism.

DIRECT DOMESTIC SUBSIDIES THROUGH INDEPENDENT INTERMEDIARYFUNDING BODIES

There is also an increasingly strongly expressed preference in the public interest and nonprofit field
for core or unrestricted funds that can be used flexibly, including on organizational development,
rather than for more instrumental funds that focus on one-off projects or on the production of editorial
content. Philanthropic funding in some regions is moving in this direction, for example, when funding
more precarious organizations such as investigative journalism centers.68 However, government donor
preferences are still largely towards project funding.

DIRECT INTERNATIONAL SUBSIDIES THROUGH INDEPENDENTINTERMEDIARY FUNDING BODIES
Direct subsidies also factor in the provision of public interest news internationally, in (small) parts ofinternational aid budgets69 among nations notably in the OECD-DAC grouping – e.g., Canada, USA, UK,
Sweden. For more detail on this, see section 2.2.3.

R
 ECOMMENDATIONSTO STATES> Direct ongoing support packages to the news industry should involve direct
cash transfers to particular kinds of journalism-producing organizations, tied
to organizational size (small and medium-sized enterprises [SME], not large
groups, for example), turnover, editorial investment, and potentially otherfactors including diversity of staff/board/ownership, and aspects of democratic
governance.

33

CHAPTER 2

A growing number of governments have recognized that some of the most societally important forms ofjournalism, and the ones that help deliver better democratic outcomes, need additional targeted support,
through dedicated selective funding instruments or programs. They can also – and increasingly appear
to – address an equity rationale, such as imbalances in distribution or structural inequalities in accessto representation, capital, or ownership for historically or systematically marginalized groups, such as
women, people of color,64 rural communities and so on. These can range in timescale from a one-off
program, through medium-term innovation or catalytic funds,65 to the establishment of large and longterm funds (including ‘patient finance’),66 or dedicated funding for one-off public support, whether for
editorial projects, innovation or investigative journalism. A unique example to which governments at thenational, state and city level in many countries might take note of is the State-funded Civic Information
District in New Jersey, USA, which has a grants program.67

FUNDING

Governments (including local and city governments) have frequently set up or provided funds to set
up funding bodies and schemes to achieve particular public purposes, often through public tender. At
their best, and to guard against capture, these are fully independent from government in governance,
operations, decision-making, and allocation, and can be administered by trusted third-party organizations
in business, investment, the charity sector or philanthropy. In respect of journalism, however, somegovernments have been wary of building such domestic funds, even when passed through independent
expert intermediaries, to avoid the impression, in one recent example, that directing government funds
to the media is perceived as interference in the media, and a violation of press freedom.

> Governments ought to establish and endow independent intermediary bodies
with large-scale, stable, long-term funding that can act as independent sourcesof patient finance for the independent professional sector, and to support
transformation and innovation in the sector. These must be independent ofpolitical, corporate or other interests in their governance and administration,
should have field and technical expertise, and should have at least a 5-year, if
not 10-year funding commitment.

2.2.2 PUBLIC SERVICE MEDIAThe COVID-19 pandemic revealed how central to healthy societies truly independent public service media(PSM) can be. PSM are, in many countries, an essential part of meeting citizens’ information needs70 – attheir best, they provide editorially independent, high quality information on a universal and platformagnostic basis,71 are required to represent all parts and diverse levels of society, are independently andtransparently governed, predictably and stably funded through a society-wide mechanism, for example
a. licence fee (BBC), media tax (Germany, Finland), or from the state budget (Denmark). This provides a
powerful counterbalance to other, more niche or paywalled media, a counter to information disorder,72
and an anchor for quality information for the widest possible public.
Public service media are, however, under pressure and attack from multiple angles in many societies.
Already pressured budgets are being cut further, there is political interference in management,
appointments, and even editorial. In Europe – in Central and Eastern Europe in particular, in Poland,
Hungary and Slovenia, for example – respective governments are co-opting, undermining and weaponizing
public service media, using and misusing a variety of legal and other instruments.73 Swiss public service
media only retained its license fee (with concessions) after a bitter public and political campaign – NO
BILLAG – and referendum, with a narrow margin of victory.
There is a wealth of research74 about public service media internationally – though where they truly meetthe criteria of independence from state and other interests biases this towards a smaller subset of highincome democracies. For some, PSM are seen primarily as a way of remedying a market failure, providing
something that the market cannot. Some policy responses are rooted in this response, and can lead tohelpful outcomes, such as the way the BBC has been mandated to subsidize ‘democracy reporters’ in
150 local independent newsrooms across the UK, a model that has been replicated in New Zealand andCanada.
However, recent research finds little evidence, for example, that PSM unfairly ‘crowd out’ privatecommercial media,75 indeed sometimes the opposite.76 An interesting experiment in the USA saw local
PSM take over struggling or failed commercial digital media startups.77 Attempts to re-conceive and re-34

CHAPTER 2> Support to field infrastructure organizations, both focused on the financial andoperational sustainability and development of the sector, and on the media
freedom aspects of the sector.

FUNDING> Governments, international organizations and other bodies engaged in the
media freedom and sustainability field may consider establishing internal units
that can bring stronger in-house expertise on issues pertaining to journalism
and the digital economy.

articulate the public value that public service media provide are not yet widespread, though one example
receiving some international attention78 is a BBC-commissioned scoping report in which economist
Mariana Mazzucato presents a framework79 that shifts away from the market failure analysis towards
one in which the BBC and other PSM provide essential public value as market shapers. PSM can also act
as a catalyst of wider change in industry practices – in respect of gender diversity, for example, as theBBC’s 50:50 project has attempted to do.80

There are many other countries in which state budget or license fee funded media do not live up to theideals of public service media, as a result of a number of threats:>P olitical capture and politicization of PSM,81 despite apparent regulatory or legislative protections
either to blunt or to weaponize it, as in Poland and Hungary, but also a risk factor identified evenfor the BBC.82> Inefficiencies or failures in their funding model, which, if state-derived, risks government
interference, and if fee-based, is dependent on the efficiency of their collection system and on
compliance levels.
> The failure to evolve into the new communication and media environment, and to connect withand adequately serve younger demographics, storing up a cliff-edge in public support or consent.
> PSM’s independence was partly intertwined with their control of their technology and transmission
networks. Some are advocating for a ‘Public Interest Internet’ that partly restores this control,
though the Working Group did not find workable or widely applicable proposals for anything inthis domain.

R ECOMMENDATIONSTO STATES> Governments should ensure that PSM have full institutional, editorial andfinancial independence, and independent, transparent governance, guaranteedin law and/or regulation, to reduce the possibility of political interference.
> Governments should develop locally appropriate means of providing PSM
with sufficient, stable, autonomous, collectively based funding that meets
international standards of independence and freedom from interference.
> Consult widely and transparently on the contemporary meaning of universal
reach and access on all relevant carriers and platforms, with consideration given
to possible prominence requirements.

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CHAPTER 2

Threats to PSM:

FUNDING

Many interviewees – including those from a purely commercial media background – believe that truly
independent public service media answering to the description above, whether in the Americas, Africa,
Asia or Europe, can be both a good in itself, and a potential engine for the sustainability of other parts ofthe media ecosystem. But they cautioned against measures that – as in some EU countries particularly– appear to meet minimum standards of policy measures, but are in fact ways of bringing PSM further
under state control.

	RECOMMENDATIONS

TO PUBLIC SERVICE MEDIA> PSM to continue to provide and commission high-quality content, bothinternally and across the independent sector, where this exists.
> PSM should have fully transparent policies, procedures and finances, in orderthat the public can see into their practices, and assess the extent to which they
are representing all parts of society.

Official Development Assistance (ODA) – alongside democracy assistance – is a key part of supportingand developing healthy environments for independent journalism in aid-recipient countries, wheresome of the other measures outlined in this report may not yet be as feasible. Yet according to the mostrecent research, the annual percentage of ODA dedicated to supporting journalism and media freedom
worldwide is just 0.3%, or US$450 million.83
Most funders, government departments, international institutions and other non-specialist organizations– apart from small specialized units at the European Commission84 and Council of Europe,85 for example– do not have in-house expertise, especially of the interdisciplinary kind that understands the new media
environment, to advise on or build strategies, often relying instead on external consultancies, peer funder
networks, or expert consultations and meetings.86
In order to persuade donors to increase their levels of support, experts, such as advocates for international
media development, have in the past presented evidence that a healthy independent journalism sector
is not only a good in itself, but is also linked with poverty reduction, effective trade, good governance,transparency and accountability, public health, election integrity, national security and a range of otherdesired outcomes. Yet aid flows have not increased. In the last five years, however, a wider range ofactors in many societies have understood that independent journalism is facing an ‘extinction event’and needs support on its own merits, and there are signs that this is filtering through to key donor
governments (particularly as their domestic journalism sectors are threatened by the same interlocking
challenges as those in recipient countries).
Emerging funding instruments at the international level, such as the proposed International Fund for
Public Interest Media87 (IFPIM) and the Global Media Defence Fund (GMDF),88 are now arguing bothfor increased levels of ODA to support independent media and its enabling environment, and for thisincreased funding to be channeled through independent, specialized structures (including IFPIM and
GMDF) at the international, national and local levels.
As noted elsewhere in this report, these efforts come during a period of democratic recession and of a‘war on journalism,’ including in countries with which rights-respecting states trade and to which they36

CHAPTER 2

2.2.3 DIRECT INTERNATIONAL SUBSIDIES: AID, TRADEAND DEMOCRACY ASSISTANCE

FUNDING> PSM should earmark a portion of its funding to enable research anddevelopment (R&D), contribution to standards development, andexperimentation and innovation that benefits the wider sector.

provide aid (and to which development banks provide investment, loans and support). Views differ ininterviews and the literature on whether and how existing instruments and incentives to encourage
better behavior from trading partners and recipient governments, such as the EU’s Generalised System
of Preferences-Plus system89 or anti-corruption requirements, can be used more purposefully andeffectively to help protect and strengthen independent journalism.

R ECOMMENDATIONSTO STATES> Commit to spending 1% of ODA (circa US$1.5bn) on support for independent
media and their enabling environment – ensuring that this goes through distinct
and independent avenues.
> Engage diplomatically in multilateral forums and other bodies (e.g.,development banks), which can be important allies for incrementally setting
standards, providing incentives, encouragement and pressure – and where
necessary, create bespoke coalitions to address particular media freedom andsustainability.
> Engage with IFPIM and other national, regional and international funds(including philanthropic funders, mission-driven, social and impact investors,
and intergovernmental funds like EEA/Norway Grants) as viable routes forproviding support at scale, mobilizing large new funds, visibility and subsidiarityof fund strategies, and convening in-country and cross-border coalitions.
> Governments, international organizations and other bodies engaged in the
media freedom and sustainability field should consider establishing specializedinternal units that can bring stronger in-house expertise on issues pertaining tojournalism and the digital economy.
> Improve data, coordination, learning on ODA and democracy assistance spent
on media development and journalism support.
> Build partnerships on funding independent journalism between established andemerging donors, especially if in same region as recipient.
> More agile, uncertain development contexts mean different and more agile
approaches are needed – including, for example, partnerships with local-level,
locally owned labs and other stakeholders (e.g., the research and tech sectors).

37

CHAPTER 2

With a fundamental pillar of democracy and open societies at stake, it is time for governments to decide
where they stand.

FUNDINGIn the absence of an equivalent of the International Panel on Climate Change (IPCC) for the journalism andinformation sector, the upcoming Summit for Democracy in the USA,90 and the roadmap of internationalsummits and conferences leading up to it, such as the G7 in the UK, G20 in Italy, the UN Special Session
on Anti-Corruption, and the UN General Assembly, offer an unprecedented opportunity both for donor
governments to lock in firm, measurable and increased commitments themselves, and to encourage
peer governments to do the same.

2.2.4 INDIRECT SUBSIDIES AND INCENTIVES
Indirect general ongoing subsidies are applied at the system level, and are less obviously visible thanactual transfers of funding, but provide equally significant value to private news media (whether forprofit or nonprofit). Such indirect subsidies can make a decisive and cumulative difference to the viabilityof individual businesses and are far outweighed by the public value such organizations provide. The
OECD has cited the work of such organizations as an ‘essential—albeit untapped—source of detection incorruption cases’.91> Business rates, tax reductions or exemptions for particular kinds of journalism businesses,
including nonprofit media, startups, or in particular business zones or districts (sometimes timebound). Tax rebates were offered by the Ghanaian government as part of a COVID-19 package ofrelief to arts and creative businesses, including journalism.
> Tax credits or relief on editorial roles focused on the production of journalism, to reduce thecost of hiring journalists (Canada) 93 though some critique this as benefiting larger organizations.
Other proposals to provide tax rebates or R&D-style credits94 merit further exploration by
governments, regions and cities in many jurisdictions.
> Tax breaks and other benefits (such as business loans) for journalists, especially freelancers(alongside other essential professions). With the growth in freelancing, there is a greater need forsupport for freelancers in the gig/creator economy, and the need for new forms of protections
outside of institutional media, access to insurance, healthcare, and legal support.95> Spectrum allocation was regarded as a subsidy, and now, with demand for spectrum continuing
to grow rapidly, the Australian government has proposed that freed-up spectrum from TV
broadcasters could be auctioned off to help fund a Public Interest News Gathering fund.96

INDIRECT SUBSIDIES VIA CITIZENS> Tax relief on digital subscriptions, as in Canada.97> Tax designations for citizens to direct a portion (1–2%) of their income tax to a journalism.
organization, as in a number of Central and Eastern European countries.98> Relief on legacy/bequests.
> Media vouchers to cover or subsidize the cost of a subscription99 in France and proposed in theUSA.

LIMITATIONS OF INDIRECT MEASURES> They are hard to design in ways that do not reinforce existing market dynamics, including ‘winnertakes-most’, or line the pockets of shareholders, or bypass public scrutiny.

38

CHAPTER 2> VAT exemptions or reductions are widespread for print publications, but have been introduced
only unevenly for digital publications. There is a perception in some countries that subsidies toprivate media are low or non-existent, but the actual value to newspapers of the VAT exemption in several European countries is considerable.92

FUNDING

INDIRECT SUBSIDIES FOR NEWS MEDIA

> They can generally only be applied domestically, and are less relevant to low income countries
where public revenues would not prioritize such subsidies – reinforcing the need for ODA,
philanthropy and other funding.

> Governments should explore or expand indirect subsidies, including allocation
mechanisms that empower citizens to freely make choices about which media
they want to support with public money.
> Governments and regulators should consult inclusively on, and set transparent,
fair and administratively manageable eligibility criteria for indirect subsidies.
> Industry bodies or other advocates should consult with experts in taxation
locally to explore weaknesses and loopholes in proposed measures, and to test
them in sandboxes.

2.2.5 TRANSPARENT, FAIR GOVERNMENT ADVERTISING
As noted in section 3.1.2, there has been a groundswell of scrutiny of digital advertising markets. In manymarkets, however, government advertising is one of the most prevalent sources of funding for media.
During the pandemic, government advertising has been crucial for disseminating important public healthmessaging to wide publics, and to keeping media afloat while other sources of revenue dry up. In an
ideal world, this advertising would be allocated by an independent agency, using clear and consensual
eligibility criteria, based on up-to-the-minute data, and allocated in transparent, fair and equitable ways,
without privileging legacy or incumbent media.100
In practice, a growing number of governments, particularly where other sources of revenue are weak or
scarce, are using government advertising as a tool of control over independent media, and as an indirect
form of capture.101 Watchdogs are punished with the withdrawal of advertising revenue, and lapdogs are
rewarded with even larger budgets.102 In the wake of the COVID pandemic, this is a particularly dangerous
and ruinous tactic. In other countries, the system is not so much actively abused, as tacitly accepted, inspite of its weaknesses. This may be as it favors incumbent recipients, and there are few incentives tochange it.
A decade ago, the Organization of American States (OAS) and the Inter-American Commission on Human
Rights (IACHR) published a set of principles for regulating government advertising,103 in response to theactual state of affairs in Latin America – ‘arbitrary and discriminatory allocation of government advertising’39

CHAPTER 2R ECOMMENDATIONSTO STATESFUNDING> In many countries, the organizations at which these might most likely be targeted – independent,
nonprofit, investigative or other public interest journalism organizations, for example – arealso less likely to have sufficiently strong finance and operations capacity to be able to takeintended advantage of such benefits. Other actors, such as infrastructure and industry bodies
and philanthropic foundations, could reinforce the impact of such measures by supporting thesekinds of capacities through technical assistance and grantmaking. Governments and regulators
would need to make significant efforts to ensure that such measures are clearly communicatedto those who might benefit from them.

as a method of ‘indirect censorship.’ More recently, a legal think-tank in India has proposed reform of theway government advertising is overseen by the Ministry of Information & Broadcasting’s Department ofAdvertising and Visual Publicity (DAVP) ,104 and provides a national example of how principles like thoseof the OAS/IACHR could be applied within a national context.

R ECOMMENDATIONSTO STATES> Government advertising must have:>p rinciples set out in legislation, including the promotion of media pluralism;>o pen data on allocations and contracting made available publicly through an
independently governed registry;> specific
rules for public procurement related to government advertising andother forms of media financing, in order to be able to see total budgets andallocations across all departments, subsidiaries and related businesses.

2.2.6 INVESTMENT – INCLUDING PUBLIC/PRIVATEAGREEMENTS
An emerging model in the for-profit independent media sector, which investors are beginning to use –and governments and philanthropic organizations are becoming aware of – is blended finance vehicles
bringing finance, expertise and stable governance to viable media. Examples drawing on philanthropic,
investor, and field expertise include SAMIP in South Africa and Velocidad in Latin America, and the newly
launched MDIF Ventures – these are not government-underwritten, but as initiatives like the European
Union’s multi-billion Euro InvestEU programme, which includes media as a qualifying sector for which it
will underwrite investments,105 come on stream, we can hope to see new funds emerge.
Financial rates of return in the independent media sector are low compared to the returns in otherpotential investment sectors. Rather than seeking a tenfold or even fivefold return, patient capital in the
independent journalism sector needs to be extremely patient, with a decade or more as the minimum
outlook. Public funds could be used to incentivize and de-risk investments from smaller mission-driven
investors,106 or to partner with investors who align with public interest. Interviewees cited returns of
4%, where this is supplemented by submarket rate of return (RoR) philanthropic capital, and where, forexample, risk for institutional investors is underwritten by government guarantees. Media freedom isa factor, as countries where investments are made must be chosen carefully, to avoid sudden shifts inpolicy targeting international investors, or where media capture is rampant, such as in parts of Central
and Eastern Europe.
Engagement with impact investors is nascent in a few countries, including the UK and South Africa, but
this can be expected to grow. The Global Impact Investing Network estimates the size of the global
impact investing market in 2019 to be US$502 billion managed by more than 1,340 organizations. One infour dollars of professionally managed assets (amounting to US$ 13 trillion) now consider sustainability

40

CHAPTER 2> independent oversight;

FUNDING>c lear, transparent and objective allocation criteria;principles and this share will continue growing in the next decade.107 (See Section 3.1.3 on the use of
dormant assets to fund social causes, including through endowing social investment funds.) One
interviewee suggested that major market-leading media companies and conglomerates (the ‘winners’ in‘winner-takes-most’) might be offered incentives to invest in smaller media in other parts of the sector,
such as local or underserved communities, or for participating in public interest investment vehicles.

RECOMMENDATIONSTO STATES> Support the growth of mission-driven investment for journalism businesses by
incentivizing the creation of, and participating as a guarantor in, national andinternational mission-driven blended finance vehicles or other social investment
mechanisms, enabling such funds to leverage much higher amounts.
> Incentivize and potentially temporarily underwrite private mission-driven and/or ESG investment in the media sector – with the dual purpose of increasing
the expert business support available to such organizations, and of helping toguarantee their independence of ownership and resistance to capture.
> Support and incentivize investors – including from other, profitable or marketleading media companies – by underwriting costs for investment in independent
media.111> Provide specific incentives (e.g., write-offs) to investors who sell or transfer local
media to public-interest/mission-driven investors.
> Identify access to capital and specific incentives for journalism founders andinvestors from diverse, historically marginalized, systematically underfundedbackgrounds, or with a public service or interest focus, and offer additional
support.
> Depending on local regulatory arrangements, similar options such as national or
local government match-funding could be explored for crowd-equity or similar
instruments.

41

CHAPTER 2

Investment can also act, if market conditions are stable and fair, as a bulwark against media captureor neglect. Mission-driven investment can be – through tools like the Golden Share or asset locks – apowerful guarantor of values and provider of business expertise to the independent journalism sector,
while at the same time safeguarding the independence of their ownership. In the USA, two funds aim toraise enough capital, including from the US government, to be a competitive-enough investor to be able
to acquire failing local media, or to liberate them from asset-stripping ownership. One such fund, theNational Trust for Local News, made its first acquisition on World Press Freedom Day110 in 2021, and may
provide an innovative new model for public interest investors in other countries.

FUNDING

Much focus has fallen in recent years on the disproportionate availability of investment capital to men,
often from particular communities, in major investment markets. Women and minority communities
have much lower access to capital in many societies.108 Investors can incentivize diversity, equity andinclusion among investees, for example, by setting up investment vehicles aimed specifically at founders
from historically marginalized communities, or from underrepresented communities.109

2.3 PRIVATE PHILANTHROPIC FUNDING

Data in the sector is slowly improving, and it is possible to get some idea of the scale of philanthropic
funding of journalism through databases like Candid in the USA and data standards like 360Giving in theUK.114 While Candid’s map details 304,384 grants to media totaling US$21.6 billion over the decade from2009,115 it was estimated in 2017 that the vast majority of this was in the United States, and just 17% ofmedia funding went towards independent journalism.116
Journalism-focused philanthropic vehicles and networks are beginning to take root at both the regional117
and national118 levels in Europe – but less so in other regions. In many jurisdictions around the world,
philanthropy may be focused only on charitable works, such as poverty relief or health; it may be nascent,regarded with suspicion, or it may not even be present in society. In other jurisdictions where philanthropy
does exist, philanthropic giving to independent causes like journalism can be seen as adversarial bygovernments, and has led to self-censorship, scrutiny, harassment, sanctions, and even closure. Thiscan be complemented by restrictions on international or cross-border philanthropy, as a result of which
recipients of such grants are dubbed ‘foreign agents’ or other deliberately polarizing terms.
While there is considerable potential for philanthropy to contribute to the advancement of independent
professional journalism in the public interest, research indicates that, to do so, it needs to confront a
series of challenges, including in its own practices:>A n historic disinclination to fund for-profit businesses exists, although this is how the majority ofnews is produced globally.
>T his is compounded by the fact that many philanthropic organizations can only fund registeredcharities, a status, as the section on nonprofit media above shows, that is extremely complicatedand costly for journalism organizations to acquire, if it is possible at all.
>A
 focus on short-term or annual project funding (restricted to specific use) rather than core
operating support over longer periods (usable however the recipient sees fit) – often out of adesire for control, or a fear of creating dependency.
>A bias towards supporting the production of journalism content, or to editorial or technicaltraining of journalists – sometimes specifically on the topics of interest to specific funders – rather
than support for better organizational, management and business practices.

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In terms of domestic philanthropy in democracies, giving to journalism in the USA dwarfs that ofeverywhere else, though it, too, is small in comparison to the sums spent by governments and their allies
on government-friendly media in pursuit of media capture, for example, in Central and Eastern Europe,or other regions.113

FUNDING

Philanthropic giving to journalism organizations is often cited as a potential solution to part of the crisis
facing the sector.112 This is particularly the case in many low- and middle-income countries, where themedia market is captured, weak or threatened, and philanthropic giving or ODA are the only viable
sources of independent funding. Initiatives like the International Fund for Public Interest Media are
specifically designed to address these dynamics.

> Reluctance to fund field infrastructure or systems orchestrator organizations that can help tobuild field collaboration, solidarity and advocacy, including on structural issues like media policy,
as well as more direct issues.

	RECOMMENDATIONSTO PHILANTHROPIES> Focus on multi-year, core/unrestricted funding and reduce reporting burdens.
> Increase access to funding for business and organizational development.
> Find mechanisms to fund for-profit as well as nonprofit or charitable media.
> Fund infrastructure, service and civil society organizations that grow,orchestrate and advocate for the field.
> Make grants data available through Candid, 360Giving or other open data
standards.
> Involve and empower external independent experts in shortlisting and selection
processes.
> Participate in or start peer groups for journalism funders and investors at the
local, national and international levels; pool research and learning.
> Collaborate with and participate in other kinds of financing bodies, such as
investors, pooled funds, and international and regional funds.

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CHAPTER 2

These are not exclusive to philanthropic organizations, and some of these and other dynamics canmanifest themselves in international institutions supporting the media, and even in the funding
structures created by the tech platform companies Google and Facebook. (Google has most recently
committed €25 million to a new European Media and Information Fund,119 which will not support news
companies directly but will contribute to a supportive environment). While some journalists and news
media have welcomed financial support from technology companies, and the sums involved in casessuch as the Google News Initiative and the Facebook Journalism Project are significantly larger thanmost governments have committed (as far as the data released by the companies appears to show), it isimportant to stress that unilateral corporate philanthropy is no substitute for public policy.

FUNDING> A lack of direct or indirect field expertise among foundation staff, whether by working as ajournalist or in the journalism sector, or in for-profit, investing or other relevant business areas.

Chapter 3:

CHAPTER 3

ENVIRONMENT

Environment

Contents
3. ENABLING ENVIRONMENT
3.1 Nonprofit journalism
3.2 Competition and platform policy
Imbalances in digital markets, and the impact on journalism
Competition policy as a big stick
What impact will these measures have on the sustainability of journalism?
3.3 International taxation policy and financial integrity
3.4 Adjacent fields and issues
Access to Information legislation
Open data regimes
Research
Interfaces between journalism and other industries
Data about the market and the industry

44

3. ENABLING ENVIRONMENT> Nonprofit journalism and charitable status – how can enshrining these in law help thesustainability of public interest journalism?
> Competition and platform policy – how might stronger regulation of search and social media
platforms help journalism?
> International policy on taxation and financial integrity – how might global minimum tax
rates and other financial and anti-corruption mechanisms support media freedom?
> Right to Information legal frameworks – how do the RTI and journalism sectors support andreinforce each other?
> Better access to high-quality industry data – could more trustworthy and open data about
media markets, in addition to better access to data from search and social platform companies,
drive more and better transformation in journalism?

3.1 NONPROFIT JOURNALISM
In the past ten years, the number of nonprofit journalism organizations around the world – especiallyin investigative journalism – has grown steadily. Nonprofit news organizations – journalism-producing
organizations founded with sole focus on the public interest, and in which profits are ploughed back into
the business and the reporting – have emerged as a way of meeting society’s need for public interest
journalism, and of reversing news deserts. Governments should ease the path for the creation andfunding of, and support systems for, such organizations through the tax system, innovation in businesstypes, and updating of charities frameworks.
It is a principle recognized in law in a few jurisdictions – and in practice in many others – that public interest
journalism provides public benefit. Many organizations provide some level of public interest news, butthere is a growing class of private nonprofit organizations that exist primarily to do so. The provision ofthis kind of public benefit ought to confer on the producer certain privileges and responsibilities, suchas being able to take advantage of certain tax breaks, or to incorporate as a charitable organization,
but this is, even in many democracies, a convoluted and costly legal process, with the outcome rarely
guaranteed.120

45

CHAPTER 3

A number of areas that recurred in the working group’s research and in expert interviews are highlighted
here:

ENVIRONMENT

The wider enabling environment in which journalism sits and operates, and with which it is interdependent,
also needs policy attention and, in some cases, similarly long-term funding. While this report will not go
into these areas in detail as their impact on the economic sustainability of journalism is not as direct as
the measures outlined in earlier sections, it is important for those devising ways to support journalism tomake sure that these adjacent fields and issues also receive focus, as they can reinforce other freedoms
and compound gains, as long as media freedom is also being respected and extended.

A secondary layer of organizations focused on the provision of support to the sector – infrastructureorganizations domestically, and media development organizations internationally – are likely to haveor be able to access charitable status already, and offer a viable option for the routing of government/
ODA or philanthropic funds. This includes other funds for public interest news that may represent a
valuable additional source of potential income for some niche and local journalism organizations.
Charitable status for these funds would incentivize donating to them (e.g., France, where two platforms –J’aime l’info & Presse & Pluralisme – allowed citizens to make regular or one-off tax-deductible donations
to media organizations).128 Crucially, ways must be found to marshal support internationally for the
nonprofit journalism sector from the legal sector at pro bono or low bono rates, alongside practicalbusiness formation resources of the type once offered by the Digital Media Law Project in the USA.

RECOMMENDATIONSTO STATES> Governments and regulators should examine, support and act on the growinginternational research and analysis that recommends establishing or improving
the regulatory framework for nonprofit and charitable media, and supporting
the infrastructure bodies that service the independent and nonprofit sector,
in accordance with the regulatory arrangements in their particular jurisdiction(e.g., centralized vs federal structures).
> Revise or reform national – and where relevant, regional – rules permitting
journalism as a nonprofit or charitable activity, including through theconsultation on and creation of specific kinds of charitable or hybrid company
form, and incentivizing philanthropic grants and personal donations, including
through tax relief and diaspora donations.
> Ensure equivalency of the regulatory frameworks for nonprofit and charitable
media across borders and between jurisdictions.

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The largest nonprofit journalism sector is in the USA, where a change in the law permitting the registrationof nonprofit journalism organizations unlocked very large sums from philanthropy, giving rise to manynational and local investigative journalism centers like ProPublica (though some have observed winnertakes-most dynamics in this field too).122 Other countries where this is a live and active discussion
between the sector, philanthropy, legislators and regulators include Canada,123 the UK,124 Germany,125
Australia126 and France.127 This relies on the integrity and independence of the charitable framework ineach respective country – in some jurisdictions, charitable status is an invitation for closer scrutiny by theauthorities, and therefore in these jurisdictions it may be more prudent to operate as a for-profit entity.

ENVIRONMENT

To incentivize the production of this kind of journalism, some countries have taken measures to ease thecreation of nonprofit news organizations, and the recognition of journalism as a charitable activity. These
open up the possibility both of being able to receive philanthropic grants, and for those who donate
to such organizations to receive relief on the tax they pay, where such arrangements exist. Nonprofit
organizations also benefit from other privileges such as low-cost services, and pro bono or ‘low bono’
legal support.121

> Establish collaborative funds – co-funded or match-funded with other sourcesof funding, such as local philanthropy or mission-driven investment – for newjournalistic enterprises and nonprofits in response to evidence showing gaps innews provision (‘news deserts’) for geographic or other communities.
> Explore how nonprofit journalism frameworks might interact with paralleldevelopments in community ownership or takeover of assets, or democratic
governance mechanisms, including co-operative ownership, newsroom
involvement in governance, golden shares, asset locks.

> The public interest, nonprofit and charitable journalism sector and its
supporters should network and engage more effectively both domestically andinternationally to better share expertise, experiences and common cause.
> Philanthropic networks and organizations supportive of the nonprofit
journalism sector should consider making collective representations to relevant
government departments or regulators to indicate potential levels of support
for the sector.
> Media, tax and charity law experts in jurisdictions where nonprofit journalism isemerging or struggling should develop (and philanthropies subsidize) pro bonoor low bono assistance programs to support the registration or incorporation of
new nonprofit journalism entities.

3.2 COMPETITION AND PLATFORM POLICY
As noted in the introduction, much debate has centered on the relationship between the platforms andthe journalism industry, and if and how the platforms can be made, through regulation or other means,
to contribute financially to the sustainability of journalism.
The threat to the sustainability of journalism has been cited in a number of policy processes as evidenceof the need for action to better regulate digital markets ,including for advertising – including in the UK’s
Cairncross Review and the Furman Review which have led to the establishment of a Digital Markets Unit
within the UK Competition and Markets Authority 129,the European Commission’s Crémer Report ,which
has led to the EU’s Digital Services Act and Digital Markets Act 130,and in Senate and Federal Communications Commission( FCC )hearings in the USA.
These issues are, however, extremely fluid. Journalism is not a key stakeholder or beneficiary, andresponses are in their early days. The working group addresses these below, but largely points to theoptions being explored, and their relative merits and demerits, rather than advocating for any single
approach at this point in time.
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CHAPTER 3

TO THE NONPROFIT JOURNALISM SECTOR,
PHILANTHROPY AND THE LEGAL SECTORENVIRONMENT	
RECOMMENDATIONSIMBALANCES IN DIGITAL MARKETS ,AND THE IMPACT ON JOURNALISM

While it is beyond the scope of this report to address AdTech and digital advertising markets, the working
group did note that the phenomenon of blocklists used by advertisers and companies for brand safety
reasons – preventing ads from being shown alongside stories on controversial public-interest topics liketerrorism, sexual violence or racism – has had unintended consequences for journalism. In 2019, one
study suggests US news publishers may have lost as much as US$2.8 billion in revenues due to keyword
blocking,131 and at the beginning of the COVID-19 pandemic, at a time when advertising revenues
collapsed, Newsworks UK reported publisher revenue losses of up to £50 million due to brands pulling
their advertising spend and blocking keywords associated with COVID-19.132
A number of large-scale and collaborative initiatives are underway to try to address some of theseissues (which intersect with similar challenges with mis- and disinformation),133 including the Journalism
Trust Initiative (JTI) by RSF. At the core of these efforts is a logic of redistribution of economic rewards,
including ad-revenue, driven by compliance with professional norms. To that end, the JTI offers a unified
list of criteria enshrined into an ISO-type standard (CWA17493:2019), an online self-assessment andtransparency tool (the jti:app) to translate these datasets into machine-readable signals for algorithmic
indexation of search, social media and programmatic advertising, and a compliance and accountability
feature through independent, third-party certification. 134
Demonstrating the trustworthiness of their work is in the best interest of media outlets first andforemost, as it might not only remedy users’ concerns, but also drive reach and revenues of news media.
In addition, it is supposed to cater to the ‘brand-safety’ demands of the advertising sector and, last notleast, to a healthier information ecosystem at large.
In a co-regulatory context, initiatives like the JTI fit into the current discourse around discoverability anddue prominence of credible sources of information. Building on the “must-carry” legacy of broadcast
regulation, it suggests to further it towards a “must-be-found” logic, which would not only incentivize
ethical journalism, but could also help to turn credibility into sustainability.
While professional norms in journalism must remain a fully self-regulatory responsibility of the sector inorder to safeguard its independence, state actors could foster an enabling environment through legal
due prominence obligations for distributors and intermediaries.

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CHAPTER 3

Societies are also recognizing the democratic and social value of journalism, which is particularly affectedby the new market dynamics, and attempting to find new arrangements to route funding from the large
tech platforms to the journalism sector.

ENVIRONMENT

Academic and regulatory focus has fallen on the outsized power of specific companies, especially
Amazon, Apple, Facebook, Google (Alphabet) and Microsoft, the harms this dominant position can cause,and how to protect and promote competition in digital markets. Public perception and debate in manysocieties has centered on the idea that big tech platforms are too pervasive, too powerful, are not paying
their way (in part driving proposed emerging global corporate tax agreements), and are unaccountable.
Appreciation is growing worldwide that current regulatory arrangements in many societies are no longer
coherent or fit for purpose for the digital economy, as how it creates and captures value has become
decoupled from democratic oversight. In parallel, prosecutors and legislators are scrutinizing related
market failures and underlying anti-trust issues, leading to court cases and regulatory initiatives to tackle
them.

COMPETITION POLICY AS A BIG STICK
In the last two years in particular, efforts by governments to regulate tech platform companies in searchand social media, such as Google, Apple, Facebook and Amazon, commonly referred to as ‘GAFA’, havecoalesced around both copyright and competition policy.

As regulators start to get to grips with the tools they need, they are finding that their work intersects withand must be coordinated with the work of other regulators: competition and markets, information andprivacy, media and telecommunications, for example, as with the UK’s Digital Regulation Cooperation
Forum;139 or around the EU’s multi-faceted efforts to introduce new legislative and regulatory instruments
across the region.140 Not all regulatory bodies have this level of inter-disciplinary expertise or resources
and capacity to act in this manner, yet.141

WHAT IMPACT WILL THESE MEASURES HAVE ON THE
SUSTAINABILITY OF JOURNALISM?
The relationship between these companies and other sectors is complex, and equally so with the news
and journalism industry. As we have noted, print was already in worldwide decline before the emergenceof GAFA. In the attention economy, journalistic media have lost their cachet and their monopoly overattention, and this is where GAFA and other companies excel, in attracting, holding, and extracting value
from our attention and collecting enormous amounts of commercially valuable data along the way, datathat is often central to their lucrative businesses.142
Analysts and researchers do not necessarily anticipate that corrections in digital markets achieved throughthe means described above would have direct impacts on the revenues of media organizations, but may
provide them with a greater choice in respect of providers, counteract vendor lock-in effects, encourage
open standards and interoperability of major players enabling journalism organizations to more easily
switch, provide more data, and encourage the development of more niche and varied providers.
Where there is direct negotiation between the news industry and the platforms, it may require someform of process of enabling collective bargaining, which has manifested in a number of jurisdictions
now – for example, in Spain, France, and Australia. The USA is getting close to a position where the news
industry will be granted a collective bargaining safe harbor in its negotiations with big tech.143 We suspect

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CHAPTER 3

Analyses from various bodies, including competition regulators136 and international organizations,137 havefocused less on specific companies (although such analyses are also prominent, especially in the US)138
than on how to create better market ecosystems, in which concentrations of power – and the conflict ofinterest of some companies’ dual roles, as both market/upstream and market participant/downstream– are reduced or removed, and in which other market participants (e.g., second position, new entrants)
stand a better chance of competing. Remedies can range from requiring the tech platforms to reachnegotiated settlements with particular industries, as attempted through the Australian News Bargaining
Code and member state implementation of the European Union Copyright Directive, to discussion andanalysis over whether these companies should be broken up like previous generations of corporatemonopolies.

ENVIRONMENT

Antitrust, in particular, is a complex and fast-evolving area worldwide, with inquiries into digital markets
being announced by governments and regulators in a growing list of countries, including Japan, Indonesia,
South Africa, Korea, and Turkey, and the appointment by the new US president of prominent antitrust
scholars to key regulatory positions.135

that this cannot be (a) inalienable (i.e., you cannot opt out), and (b) mandatory (decisions are binding).
This collective bargaining ought to be conducted on genuinely collective and transparent principles, withdetails and terms of any bilateral deals available to all, ensuring that sweetheart deals cannot be cut.
The risk of poorly thought through or imbalanced policies in this space is that they benefit only a few
already large publishers, or legacy incumbents at the expense of digital-born entrants; that they make it
impossible to reach an agreement, leading to disruptive market exits; and/or that they give government
more direct sway over the independent news media meant to hold power to account.

TO STATES, REGULATORS AND ONLINE SERVICE PROVIDERS> We recommend to advocates as well as to governments that any commitment ofpublic resources to enhance the sustainability of independent journalism should
ideally come from general taxation, rather than from hypothecated (earmarked
or Pigouvian) taxes. These have been considered ineffective, can fluctuate
wildly, and are vulnerable to unintended consequences.
> In rights-respecting states where additional pressures on public finances would
ordinarily preclude funding journalism out of general taxation may wish to take
into account that the OECD estimates addressing the tax challenges arisingfrom digitalization (in large part associated with platform companies such as
Alphabet, Amazon, Apple, Facebook, and Microsoft) can help raise $100 billion intax revenue annually, covering the investment.
> In countries or regions where competition and other regulators requirenegotiations between the news industry (including independents, nonprofitsand digital entrants) and the platform companies, collective bargaining
arrangements ought to be conducted on genuinely collective, inclusive andtransparent principles, with details and terms of any bilateral deals available
to all, ensuring that sweetheart deals cannot be cut, and that the journalism atgreatest risk is protected in any negotiated outcome.
> Incentivize and reward professional journalism with due prominence byusing transparently and independently developed, governed and enforced,
self-regulatory industry standards to enhance discoverability and reach oftrustworthy sources of information; implement the resulting data channels, forexample the one provided by the Journalism Trust Initiative, to index content
in news feeds and to build partnerships in news products with a particularfocus on local media, vulnerable communities and the Global South; continue tocontribute actively - like in the past - to the further R&D efforts in this field witha strong focus on impact assessment.

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CHAPTER 3

 RECOMMENDATIONSENVIRONMENT

Since, however, journalism is a key part of the rationale for taking action, whatever mechanisms emerge,
the outcome ought to involve the provision of substantial funds supporting independent, public interestand local journalism. If not, this may result in a poor outcome that involves monopolies strengthening
other monopolies, reinforcing, as many analysts have observed, existing concentration dynamics, as is
the case in Australia.

3.3 INTERNATIONAL TAXATION POLICY AND FINANCIAL
INTEGRITYThe UN Panel on Financial Accountability, Transparency and Integrity (FACTI) recognizes in its final report
the pivotal role played by journalists in anti-corruption, and calls for a legally binding international
instrument for ‘minimum standards of protection for human rights defenders, anti-corruption advocates,
investigative journalists and whistle-blowers’.147 The Addis Taxation Initiative’s 2025 Declaration148
includes a new Commitment 4, focused on support and protection for civic space and ‘accountability
stakeholders’ such as the media. A 2020 UN report for the G20 on combatting corruption in the response
to COVID-19 noted that ‘[t]he role of [...] the media, cannot be understated in times of crises. They remain
crucial and vital actors to the achievement of any tangible results that are to reach the general public.’ Wealso note that some recent reports149 addressing the phenomenon of Russian-sponsored media capturein Europe specifically advocate that a ‘solid, transatlantic, anti-corruption, and financial transparency
response should be the first line of defense to anti-democratic media capture in Europe.’
Allied to such investigative and anti-corruption efforts, taxation policy, if carried out fairly, transparently
and equitably, can be a driver of public confidence in government, and of more open societies: ‘Where
governments are more open and trusted, citizens are more likely to support and pay taxes. And wherestates tax more, and more openly, taxpayers are more likely to demand effective services in return.’150
Recent evidence also shows that greater fiscal transparency is correlated with increased inward
investment flows.151
Interviewees, and research carried out by the working group, suggest that there is scope, within thegrowing consensus on global tax agreements, for raising the issue of funding journalism. With proposals
on how to tax the digital economy gathering momentum internationally, including ones such as the
METR (Minimum Effective Tax Rate) that may more equitably benefit low- and middle-income countries,152
Finance ministries can and should consider – among the complex balance of interests and incentives indomestic tax regimes – how extra tax receipts mean that support for independent professional journalism
can be funded out of general taxation. In limited form or perhaps as a short-term bridging measure,hypothecated taxes, while unsatisfactory, may be the only or most viable option in some jurisdictions inorder to unlock such funding.

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CHAPTER 3

Usually, when a report on journalism mentions taxation policy or financial integrity, it is likely to focus on
the role that investigative journalists and whistle-blowers might play in tracking and exposing corruption
and illicit financial flows. In the five years since the publication of the international collaborative
investigation The Panama Papers, for example, governments have recouped at least US$1.36 billion,
80 countries have launched investigations144, and laws have changed in at least 18 countries.145 Anothercross-border investigative journalism network, the Organised Crime and Corruption Reporting Project(OCCRP) estimated in 2016 the US$5 million it had at that point received in grants had led to the recovery
of US$2.6bn in public funds.146

ENVIRONMENT

Journalism is a key driver of greater domestic and international fiscal transparency and financial integrity,
which in turn increase public trust, prosperity and open societies. Moves to develop global tax agreements
should include discussion of funding (ideally out of general taxation) for such investigative and public
interest journalism, spent through properly governed independent funding bodies at the national andlocal level. The proposed Global Pact for Financial Integrity should ensure that some of the funds it
disburses are dedicated to SDG 16.10 of the United Nations Sustainable Development Goals, including tojournalism. Growing efforts to use dormant assets, such as inactive bank accounts, to fund social causesshould similarly include public interest and investigative journalism as eligible recipients.

These are complex and technical areas, and with unique arrangements in each jurisdiction. The working
group has noted the measures it believes are broadly globally relevant – for example, those advocated by
the UN’s FACTI panel (and endorsed by the UN General Assembly),153 as part of the OECD/G20 Inclusive
Framework on BEPS addressing tax avoidance, the Global Forum on Transparency and Exchange ofInformation for Tax Purposes, and the Addis Taxation Initiative’s 2025 Declaration.154 The national orregional solutions needed will require original research and impact studies (such as in this South African
proposal.)155

RECOMMENDATIONS> The proposed UN Tax Convention includes new arrangements on digitalplatforms (12b) and a potential route to taxing them. UN ECOSOC and relatedbodies should actively explore whether the model laws provide an additionalroute to funding media.
>T he FACTI panel calls for a Global Pact on Financial Integrity, under whichcountries would use the proceeds recovered from illicit financial flows for UN
projects related to the Sustainable Development Goals. Journalism and media
come under SDG Goal 16.10, and, given the pivotal role played by journalism,
and investigative journalism particularly, the Global Pact ought to consider
journalism a priority area for support from funds derived through this route.
(The OCCRP has proposed a similar idea for a fund specifically dedicated toinvestigative journalism.)156> The Addis Tax Initiative’s 2025 Declaration includes a new commitment toincrease civic space for accountability actors, including the media, and member
states should include consideration of how the economic sustainability of media
can be better supported through the ATI’s agenda.
> As multilateral consensus approaches on taxes on online advertising (beyond
unilateral approaches such as those implemented in Canada and India)157– additional resources could be used to create, as proposed in the USA,158
independent funds for ‘local, independent and noncommercial news andinformation’. Similar calls have been made for taxes on telecommunications
companies (FTC, 2009).
> A small group of countries has been leading international practice on the use of
dormant assets unclaimed after 10 years to fund social causes, including the UK,
Japan, the USA and Canada.159 These and other governments implementing or
considering such funds should include journalism as an eligible area of support.

52

CHAPTER 3> Adoption of an equitable minimum global corporate tax rate, and countryby-country reporting, would bring significant new revenues to exchequers
worldwide, potentially enabling Finance ministries to provide resources for
direct subsidies or to endow or fund properly governed independent journalism
funding bodies at the national or international level.

ENVIRONMENTTO STATES

> Some countries restrict donations to resident citizens and income taxpayers
only, potentially cutting off a valuable source of income for local media
nonprofit organizations from diaspora or migrant populations. The tax
authorities in these countries should explore how to expand the range of
permitted donors.

3.4 ADJACENT FIELDS AND ISSUESRECOMMENDATIONSTO STATES> Governments should implement not only the letter but the spirit of their
FOIA laws, comply with response times, and set out clear penalties for noncompliance from official bodies.
> Governments must protect FOIA advocates and users, including journalists,from attacks, reprisals and other forms of threat and harassment.
> Philanthropic, aid, democracy and other funders should see the FOIA sector as
part of the overall public interest information ecosystem and include it within
their strategies and funding priorities.

OPEN DATA REGIMES
Independent journalism, especially emerging forms that are facilitated by new ICTs, such as data
journalism and open source intelligence (e.g., Bellingcat, Forensic Architecture),163 benefits hugely fromopen data and openly available sources, some of which is driven by transparency and reporting obligations

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CHAPTER 3

Access to information is a critical part of the transparency and accountability infrastructure for open
societies, and more than 100 countries now have a Freedom of Information Act (FOIA) law on the statute,but the quality of implementation and observance is extremely uneven.160 Governments routinely
frustrate and reject FOIA requests, whether from advocates, citizens, or journalists, even in democracies
such as the UK.161 The FOIA sector itself is chronically underfunded across the world, and advocates insome jurisdictions have met with harassment, attacks and even disappearances and killings.162 Investingin the FOIA field and its capacity to strengthen and monitor the implementation of FOIA legislation, andits ability to work with media, will in turn strengthen independent professional journalism.

ENVIRONMENTACCESS TO INFORMATION LEGISLATION

on governments. Important sources for journalism include OpenContracting, and legal information
provided through Legal Information Institutes, for example.164 The aid transparency movement hasbrought about significant advances in how governments report on and release data of their expenditure,and organizations like Publish What You Fund are key in using and analyzing this data.165 This is also quite
widespread at the national and local levels in some countries (e.g., IndiaSpend, OpenBudgets).166 As theOpen Data Barometer showed, and as its successor, the forthcoming Global Data Barometer will further
investigate,167 the state of policies and practice around open data is extremely uneven, and governments’approaches to open data can vary hugely. (Ironically, there is not that much open data available about
the media.)RECOMMENDATIONSRESEARCH
There is a need for better coordination around journalism and media policy research, nationallyand internationally, and especially in the developing world, and to improve communication between
researchers and the journalism industry. Government (and other funders) can consider supporting
institutes that do directly practically relevant applied research, such as the Center for Media Engagement
at the University of Texas-Austin,168 and especially research directed at the needs and priorities of smalland medium-size publishers, who will not always have the resources to do their own research. Institutes
for interfacing with new challenges like the rise of artificial intelligence and machine learning, shouldbe established to develop applied research on, for example, the impact of automation on journalism
content, labor, and coverage.169 Such institutes are already being established in other sectors.
Similarly, public funding can play an important role in enabling industry collaborations around innovation.

RECOMMENDATIONSTO STATES> Countries that have or are developing an AI roadmap should include journalism
and media as a strategically important sector.170> Support and fund applied research relevant for independent news media,
especially small-and medium-sized news media.
> Support and fund industry collaborations on research and innovation.

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CHAPTER 3> Governments should adhere to and, where possible, exceed international
standards on open government, transparency and open data.

ENVIRONMENTTO STATESINTERFACES BETWEEN JOURNALISM AND OTHER INDUSTRIESJournalism can benefit from more cross-fertilization with research, tech companies, and the creative
economy. Examples of how to facilitate this include:>A friLabs (Africa-wide), a network of 268 innovation centers across 49 countries which aims toencourage technology, innovation and entrepreneurship in an environment characterized byopen collaboration and networking.171> Baraza Media Lab (Kenya) provides space and resources to enable media and entrepreneurs tocollaborate, innovate and drive the growth and capacity of independent media.172> Media City Bergen (Norway) is the headquarters for a cluster of 100 companies including news
publishers, broadcasters and tech companies, along with eight major universities.175> Media Lab Bayern (Germany), funded by the Ministry of Economics and Regional Development, isa co-working and incubation space dedicated to media innovation startup companies, focused onenhancing digital journalism and developing media projects.176> WAN-IFRA’s Global Alliance for Media Innovation (global) seeks to build bridges between news
publishers, academia, research centers, tech companies and start-ups, with the goal of bringing
both new technological solutions and new mindsets to journalism.177

DATA ABOUT THE MARKET AND THE INDUSTRY
Investors and philanthropists rely on high-quality data to know where to find opportunity and how to act
once they do. For this, transparent and common standards on data on audiences are needed, as well as
advertising market and rates, including government advertising. Licensing on fair, reasonable and nondiscriminatory (FRAND) terms should be encouraged.
Projects that contribute to a better understanding of the wider environment in which journalism operates
are useful, for example:> In some areas of the US, researchers have mapped local news provision to understand where‘news deserts’ are located and subsequently where any efforts to fill the gaps should be targeted.178
Far more systematic research about the nature and extent of ‘news deserts’ is needed outside
the USA,179 and philanthropic and other funders, including regulators or ministries with oversightof the media sector, should consider supporting or commissioning such research.
>A report from the Netgain Partnership looks at the challenges of studying social media data andhighlights approaches that encourage platforms to be more open to providing their data (ideallylongitudinal) to researchers, in order to make this field more accessible and comprehensible.180
Whether this figures as part of broader negotiations with the platforms remains to be seen.

55

CHAPTER 3> Digital Media Viability Lab (MENA), which aims to be a leading provider of services, knowledge andexchange on media viability in the Arab region.174

ENVIRONMENT> Clwstr is a collaboration between universities and media in Wales, to create a platform forindependent companies, SMEs, micro-businesses and freelancers to compete with global, highly
integrated media companies.173

Chapter 4:

Future4. FIGHTING FOR THE FUTURE OF JOURNALISM
4.1 Putting readers at the heart of revenue strategies: subscriptions, memberships, donations,micropayments
Subscriptions
Membership
One-off contributions or donations
Experiential: Events, training, masterclasses
4.2 Improving the business of independent professional journalism
E-commerce
Reclaiming Media Ownership
Progressive, expert investors
Democratic ownership and governance
Increasing the diversity of founders and owners
4.3 Collaboration and sharing

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FUTURE

Contents

4. FIGHTING FOR THE FUTURE OF
JOURNALISM
The challenges facing the independent professional journalism field are real and urgent worldwide, andthe cost to society, to democracy, to citizens worldwide, if these challenges are not met immediately, isequally real and urgent.
COVID-19 has caused already-declining revenue streams to dry up, and afforded governments and others
opportunities to attack and weaken journalism further. It has exposed weaknesses that need immediate
structural, policy and practical support. But this can also help to free journalism from its addiction to thefossil fuels of its old business model, and in doing so, more fully meet its public interest mission and its
role in democracy.

Across the world, within and across borders, organizations, and networks, individual journalists havebeen launching, experimenting, learning, investigating, collaborating, organizing, and building. Many are
producing exceptional journalism in every conceivable format and on every available platform. And manyare embracing transformation181 by becoming more user-centric, product-focused,182 better skilled,183
and more data-driven.
Advertising is and will remain a central source of revenue for many news media, whether legacy
broadcasters and newspapers or digital-born entrants.184 But as advertising moves to digital, andpublishers have to compete with big platforms and a large number of smaller online competitors,
advertising will in most cases become a relatively less important and less lucrative part of the businessof news. It may bring in billions of dollars globally, but not the tens of billions that print and broadcast
generated in a very different pre-digital market.
Looking beyond advertising, amid the broad sweep of revenue types that publishers can consider,185
here the working group highlights four key fronts on which journalism is already advancing, and which,with the support of the measures in this report, could herald a brighter, more stable, equitable future:> Putting readers at the heart of revenue strategies.
> Building stronger business and tech skills alongside editorial.
> Pushing against capture by securing independent ownership.
> Going further, faster and more efficiently through collaboration.

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Meanwhile, journalism is not simply sitting on its hands, waiting passively for rescue.

FUTURE

Transition to the hybrid digital, mobile and social environment will not be easy, and not everything in thefield will survive this necessary transition, but without large-scale, sustained intervention, far fewer willsurvive, especially at the local level. The measures outlined here to governments and others with power
and resources to kickstart a New Deal for Journalism around the world, can make a tangible difference
over the next two years, and can help journalism to start to turn the tide over the coming decade.

4.1 PUTTING READERS AT THE HEART OF REVENUESTRATEGIES: SUBSCRIPTIONS, MEMBERSHIPS,DONATIONS, MICROPAYMENTS

If and how this translates into the news industry –which is based on very different premises toentertainment-content businesses – is not yet clear, especially in middle- and lower-income countries.
For news organizations, this profound shift from an advertiser-supported, content-focused business toa reader-supported, customer-focused business needs not only new skills, knowledge and training, but
often a reorientation and rethinking of an entire organizational culture. A 2019 study for the Lenfest
Institute191 estimated that ‘1 new subscriber is worth [up to] 48,000 new page views’, and that, especiallyfor local and digital journalism organizations, providing value to these new subscribers through highquality, distinctive journalism that ‘helps them live better’ is the key to attracting and retaining subscribers.
Moving in this direction entails becoming far more focused on understanding what readers’ needs are,as customers, users, citizens, inhabitants, and communities. It also requires an understanding not onlyof the obligations and costs of the first-party data that such direct relationships with audiences bring, butalso how independent journalism could be at the forefront of learning how this data can be protected
and managed productively and ethically, amid broader thinking on Personal Identity Management.
Interviewees were concerned that the journalism industry lacks, undervalues, or cannot afford to hire in
the strategic skills and the data and product experience required for such transformations.
The research focused on four main methods for acquiring reader revenue:> Subscriptions – paying for online access to content, resulting in recurring revenue.
> Membership – paying to become a member of a media organization, with some ancillary benefits,
and resulting in recurring revenue.

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The shift towards a focus on readers has come alongside a broader mindshift in much of the industry,that high-quality journalism needs to be paid for, and the most stable potential source of income to pay
for that appears to be readers themselves. The tens of millions worldwide subscribing to entertainment
services suggest that the public, and the young especially, are willing to pay for digital subscription
products, a trend accelerating during COVID-19 lockdowns.189 According to PwC’s Global Entertainment
and Media Outlook: 2020-2024 report, spending on digital entertainment and media is shifting from being
considered discretionary expenditure to being increasingly regarded by many as ‘a utility on par withwater or electricity, leaving it less susceptible to changes in macroeconomic conditions’190 – but it remains
to be seen whether the economic shocks caused by the pandemic, and other forces such as automation,
reverse this trend. Even in wealthy countries, the number of media subscriptions each individual isprepared to pay for is not unlimited.

FUTURE

Journalism is in the midst of a transition from an advertiser-focused business to one focused on readers(and listeners and viewers). Advertising will remain important, but less so, and consumer revenues will
become more important. In an incredibly competitive environment, generating this revenue will require amuch clearer value proposition, and distinct, high-quality content that target audiences clearly recognize
as relevant, useful, and important for them. Part of this is a rediscovery and refocusing of the value of
public interest journalism, and its role in fulfilling the information needs of communities. This has been
most recently thrown into relief through the literal life-and-death scenario of the pandemic, during which
demand for trusted sources of news and information increased hugely. Core to this shift is reinventing
relationships with audiences through, for example, engagement,186 membership187 and co-operativeownership.188

> One-off contributions or donations – paying ad hoc amounts to a media organization orjournalist, when motivated to, as part of one-off campaigns, through tax designations, or as partof wills, legacies or bequests.
> Experiential income – paying to participate in talks, gatherings, conferences or other events
created or curated by the organization.

SUBSCRIPTIONS
For many news outlets in wealthier countries, selling subscriptions to access online content has become
the highest priority source of potential revenue. The Reuters Institute’s Trends and Predictions 2021
report, which surveyed 234 digital news leaders from 43 countries (weighted largely towards Europe andthe US), found that driving digital subscriptions was rated as important or very important by 76% of thosesurveyed.192 This reinforces, for example, the policy option outlined in France and the USA of providing
citizens with media vouchers to cover the cost of a digital subscription.

A similar dynamic plays out in other national media markets, where leading newspapers are able to drive
similar market-leading rises in subscriptions, such as Dagens Nyheter (Sweden), Helsingin Sanomat (Finland), and Gazeta Wyborzca (Poland).197
A second type of subscription – newer digital-born organizations serving niches, new markets orunderserved communities or languages with specialized content and services – is also showing signs ofsuccess. Stears in Nigeria is growing its subscriber base and attracting investment because it provides
original journalism and high-quality data in a market where these are hard to come by.198 Factors for
success noted by interviewees include strong brand identity, high-quality journalism, and providing hardto-find niche services, such as market data, or information relevant to job-hunting or livelihoods, suchas agriculture, that might be valuable in certain kinds of economies. The best among these niche media
produce original reporting, or specialized investigations, contributing to wider coverage and debate.
Other digital-born organizations making a success of subscriptions to the point where they are alsoable to start offering more in-depth membership schemes include Malaysia’s Malaysiakini,199 Slovakia’s
Dennik N, and South Africa’s Daily Maverick – all in countries where press freedom is not a given, where
media capture is rife, and where subscriptions, memberships and donations can all act as a form ofsolidarity and support as well as a financial bulwark against attack. Many newspapers in India, Kenya200

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There are a number of high-profile success stories among upmarket, established print media, especiallythose able to grow subscribers internationally by being published in the English language, including, in theUSA, The New York Times (6.7 million digital subscribers), The Washington Post (3 million) and The Wall Street
Journal (2.5 million), and in the UK, The Guardian (0.9 million), The Financial Times (0.96 million) and The
Economist (0.87 million).195 Such dynamics can also play out in other global languages, such as Spanish.196
These are all beneficiaries of the winner-takes-most dynamic described above, and with increased
subscription revenues and reach, are able to command better advertising rates, sponsorship and othercommercial opportunities, and therefore to grow, invest and scale further, including by offering free or
heavily discounted – and potentially habit-forming – subscriptions to school and university students.

FUTURE

That said, the authors of the same institute’s 2020 Digital News Report were clear that although there
had been significant increases in payment for online news in a number of countries, across all themarkets they surveyed the majority of people are still not paying for online news, and many say that
nothing could ever persuade them to pay.193 There is some evidence that media and information literacy
education might correlate with an increase in willingness to pay.194

and other democracies have been forced into enforcing hard paywalls, as other sources of income, suchas government advertising, have become tools of political influence and capture. Subscriptions are aniche and quickly-saturated option in many poorer countries, and they are less likely to work for tabloids(which also provide public interest journalism) which prioritize wide reach and target demographics who
are less likely to pay for news.
The risk to society of a mass introduction of ‘paywalls’ is the creation of a two-tier information system,
where in those countries which lack a strong, independent public service media presence, quality
information is only available to those who can afford to pay for it. Even those who do pay are likely
to get news from a narrower range of sources as most are likely to take out a very small number ofsubscriptions, reinforcing the winner-takes-most effect.

MEMBERSHIPONE-OFF CONTRIBUTIONS OR DONATIONS
Attracting one-off payments from individuals in large enough numbers to make a difference to the mix ofrevenues is also time-consuming and requires expertise and experimentation, whether one is operating
at the level of a major news organization or of an individual freelance journalist.
For-profit organizations might call these one-off direct payments contributions, where nonprofits might
see them as donations, but the net effect is the same – unpredictable but flexible money that helps tooffset and replace revenues that used to come from other sources.203 In a practice that is spreading
rapidly through many global social platforms,204 many Asian digital media sites, content producers,
and freelance journalists, taking advantage of the tight integration of payment solutions into so-calledsuper-apps, enable ‘tipping’ functionality alongside their journalism, and interviewees report that this is a
growing and important revenue stream for independent – particularly service – journalism in the region.
While voluntary payments, or ‘tips’, are growing, more systematic micropayment solutions – for example,
paying a small sum to read an article -– have not yet made a major contribution to solving the revenue
crisis by reaching wide adoption. The rebundling of media into a ‘Spotify/iTunes/Netflix/SetApp for60

CHAPTER 4

Some have used crowdfunding sites to build a core base of supporters, as a proxy form of membership,such as independent Spanish news site El Español, which raised €3 million, or newly independent Polish
radio station Radio Nowy Świat, which raised over 4 million zlotys (over US$1 million) in the second halfof 2020. But for every success, there have been myriad unsuccessful campaigns, and while crowdfunding
markets in many countries are growing extremely quickly, the donation-based and reward-based
crowdfunding relevant to most independent media represent just 0.5% or US$1.5 billion of global
crowdfunding volumes.202

FUTUREThe membership model201 is similar in that it provides recurring revenue to the organization, but markedly
different from subscription in that it centers less on providing the member with access to content thanon inclusion within and solidarity with a community. What was once a novelty practiced notably byindependent Dutch digital media organization De Correspondent is now a core strategy embraced byindependent sites around the world, and mirrored by individual journalists through publishing platforms
such as Substack. In some settings (e.g., Mexico), membership can be a way for communities to express
solidarity with and protection of independent journalists serving their locality.

journalism’ that this would require still seems counter to the grain of the larger industry, although it
might be a possible model for small local, independent or alternative media.
One-off campaigns fall into this category, including some crowdfunding efforts, such as appeals to coverlegal costs that many independent sites face.205 Other routes for asking potential donors for one-off
support include campaigns to persuade citizens to allocate a small percentage of their income tax (taxdesignations permitted in some Central and Eastern European countries) to their journalism outlet, andas part of wills, legacies or bequests.

EXPERIENTIAL: EVENTS, TRAINING, MASTERCLASSES
A way to take advantage of the expertise developed by journalists along with a trusted brand, events,
training, and masterclasses can be stand-alone or coupled with access to content as part of a membershipmodel, and could bring in revenue through a ticket price or sponsorship.

Many independent media in the Global North and South, from Animal Politico in Mexico, or Follow
The Money in the Netherlands, to Rappler in the Philippines, may conduct third-party work for clients,
whether research, data, design, branding, content production or other services. This can be a steady andhelpful source of commercial revenue. Other organizations can turn their own expertise into consulting
work or products for other media organizations – such as The Financial Times’ FT Strategies unit, or The
Washington Post’s Arc software suite.
A mission-linked source of potential revenue, mentioned by one interviewee, for public service media –but also for commercial media in some circumstances – could be to build on the early pandemic period
by increasing educational experiences, and the increasing demand for lifelong learning.

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Interviewees noted two other uses of expertise that could contribute to the sustainability of public
interest journalism organizations.

FUTUREThe pandemic forced many news organizations to make a quick pivot to online as a result of lockdown
restrictions: online events can be put together more quickly and easily and can attract participants from awider geographic area than in-person events, as well as far larger audiences for only a marginal increasein cost. It is harder to charge high prices, however, so might increase dependency on sponsorship.
According to The Financial Times, which has a well-developed events business that swiftly moved online
as the pandemic set in, virtual event ticket prices tend to be 30% to 50% of the cost of in-person event
tickets.

4.2 IMPROVING THE BUSINESS OF INDEPENDENTPROFESSIONAL JOURNALISMMedia viability continues to be affected by the failure to act on journalists’ safety online and off,206 lack ofcollective solutions on insurance, legal defense, and other protections, battles over worker organizing,207
and uncertainty over the freelance and gig economy. Several interviewees expressed concern about thenews industry’s lack of preparedness, lack of strategic competency and in some cases lack of motivation
to make or advocate for the necessary changes in time.
Interviewees repeatedly underscored the need for media of all types - for-profit or nonprofit, co-operative
or commercial, membership-driven or industry-focused - to invest in core business competencies, as wellas in key editorial roles. The hybrid skills, roles and structures required to start, run and grow digital
media businesses (especially member-focused ones) are markedly different than those needed fornon-digital media businesses,208 and are still not part of journalism curricula in large parts of the world,
although entrepreneurial journalism is being more widely recognized.

Tied to this is a widespread recognition among interviewees and in the literature that journalism educationand training needs a significant reform and renewal in many societies and institutions in order to meetthe present and future needs of the sector. This extends from those training to become journalists andmedia managers, to those undergoing on-the-job or mid-career training, and to those founding media
startups.
Improved field infrastructure also helps to identify ways in which sustainability can be improved. The
spread of a new generation of digital-native media support organizations including SembraMedia in Latin
America, jamlab in Africa, Fathm in Northern Europe, The Fix in Eastern Europe, and Splice Media in
Asia, alongside more established local and international media development organizations such as themembers of the Global Forum for Media Development has brought greater diversity and new capacities
to the field. Combined with open-access self-assessment tools such as Deutsche Welle Akademie’s
VAM360 canvas,210 a wider range of organizations around the world can access some level of expertise tohelp them address organizational challenges, and to be better placed to take advantage of commercial
opportunities – although extending such resources beyond global languages into local languages remains
a persistent barrier to wider uptake of potentially useful and transformative methods.

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Awareness of the need for such skills as a key motor of sustainability is growing in the sector and its
supporters, and opportunities both for education and training for individuals, and for assessment andsupport for organizational strategies are mushrooming around the world.

FUTUREInterviewees reported that, for smaller journalist-led startups or ones operating in constrained
environments, this kind of investment is crucial to sustainability, with the lack of financial management
and planning expertise noted as a particular risk and brake on growth.209 Digital media leaders we
consulted noted that many philanthropic organizations had, until recently, prioritized short-term grants
for editorial functions or content, rather than longer-term grants to grow the resilience of the overall
organization and business.

E-COMMERCE
The COVID-19 pandemic has seen a huge increase in online spending, alone with declines for physicalstores. A McKinsey report suggested that global e-commerce sales had effectively compressed 10 yearsof growth into 8 weeks.211
Journalism outlets can use their brand’s credibility to review and recommend products or services whileproviding affiliate links to enable the audience to make purchases, or to offer specific discounts andbenefits for an additional fee.212 This does come with a risk of losing reader trust when making moneyout of recommended products that might not live up to reader expectations. Some noted the particularvalue of trusted intermediaries and consumer advocates such as Consumer Reports in the USA and
Which? in the UK; and in Asia, many individual consumer journalists working online.

RECLAIMING MEDIA OWNERSHIPPROGRESSIVE, EXPERT INVESTORS
There are three principal roles that mission-driven investors can play in protecting the independence andsustainability of journalism through ownership.
>B uying a controlling stake or a golden share in independent media organizations to prevent theirtakeover by or liberate them from other interests – for example, investment fund MDIF has taken
stakes in South Africa’s Mail & Guardian, and in Slovakia’s Petit Press.213> Buying a stake in larger, strategically important media organizations in order to safeguard their
independence, and to veto unsuitable sales. The Dutch hybrid philanthropy/investor Stichting
Democratie & Media owns a minority stake in Belgian-Dutch media conglomerate De Persgroep,
but this ‘golden share’ ensures that any sale of the group can be vetoed by the SDM’s nominatedboard representative.214 A crowdfunded version of this idea was launched in France in 2021 byProfessor Julia Cage, when her organization Un Bout du Monde crowdfunded €150,000 in order
to be able to buy a potential stake in newspaper Le Monde.
> Buying captured media from their owners to convert them to public interest journalism
organizations, possibly nonprofits. MDIF’s purchase of Petit Press in Slovakia has elements of this,but two initiatives in the USA – the National Trust for Local News, and the Replanting Newspapers
strategy – are arguing for a raft of larger-scale measures, including public and philanthropic
funds, and tax incentives for potential sellers.

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Here we highlight three ways in which the sector and those that support it might begin to turn the tide infavor of independent ownership.

FUTUREThe quality of media ownership, as noted earlier, has important effects on the diversity and independenceof the journalism field, which concentration of ownership can erode. This is also a significant problem
in local journalism markets in some countries, where weakened local media are vulnerable to takeoverand asset-stripping. This weakened state can be the result of market dynamics we described earlier, ofgovernment actions, of lack of skills, or of black swan events. Although a measure of concentration can
act as a counterbalance to government power in some market situations, when compounded by statesponsored media and/or regulatory capture, it facilitates attempts to control and silence dissenters, withthe aim of prolonging a regime’s survival.

DEMOCRATIC OWNERSHIP AND GOVERNANCE
There has also been a steady increase in recent years in cooperatively owned and governed journalism
organizations around the world,215 and other forms of democratic involvement in and governance ofmedia. This parallels other forms of community participation in ownership and management of othercommunity assets, such as the 50+1 scheme at German football clubs.
While there are numerous models of co-operative ownership, governance and participation among thecurrently existing media and journalism cooperatives around the world (ranging from photo agency
Magnum to Egyptian investigative outlet Mada Masr), they all essentially seek to involve journalists andeditors – and sometimes readers – in the ownership and democratic governance of the media housethey work for. This is also the principle underlying the Un Bout du Monde fund mentioned above, andserves to protect the organization from being undermined or taken over. In 2016, after a bankruptcy
following a decline in government advertising, Tiempo Argentino was relaunched as a cooperativelyowned newspaper.
Latterly, in the USA, co-operatives researcher and advocate Nathan Schneider has developed the conceptof Exit to Community, a method by which organizations, rather than seeking a financial exit, can choose
to convert into a co-operative or other form of community ownership.

Structural interventions to redress and correct the imbalances in access to capital and funding are
underway in many societies, but need to be scaled up for the public interest journalism sector specifically,
as noted throughout Section 2 of this report.

4.3 COLLABORATION AND SHARING
There is growing momentum – driven partly by the rise of collaborative, cross-border investigative
journalism – for editorial collaboration. While the report addresses editorial collaborations and theirimpact on sustainability elsewhere, the focus here is particularly on business collaborations.
As defined by the Center for Cooperative Media (CCM), the idea behind collaborative journalism is towork together to ‘supplement each organization’s resources and maximize the impact of the content
produced.’217 The CCM lists more than 400 collaborative journalism projects in its database,218 but issteadily expanding its database globally, most recently with a project researching collaborations between
journalism organizations and civil society organizations.
The business-level collaborations that promise to support greater sustainability in the local news sector
particularly involved shared infrastructure and services. These include the Canadian network of local

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Access to capital to start media businesses – whether for-profit or nonprofit – has historically beenskewed overwhelmingly towards male founders. Ethnicity can also be a factor, meaning that founders
from minority communities find it harder to access capital or funding too. This limits the diversity ofminority- and female-owned businesses in the journalism field, which may compound the already large
gender216 and race pay gaps. This is mirrored in the largest markets (USA, Europe, Australia, India) by alack of senior decision-making investors and funders from minority communities or that are women.

FUTURE

INCREASING THE DIVERSITY OF FOUNDERS AND OWNERS

news sites, Indiegraf, which provides a shared infrastructure for launching local news sites, including
technology, accounting, marketing and other central services, leaving journalists and editors free to focus
on developing local publications at low-cost. The Tiny News Collective in the USA has similar methods
and ambitions, as does the German-British collaboration beabee.

CHAPTER 4

FUTURENow more than ever, with the journalism and media sector fragile, those who represent and advocate
for the industry need to take a whole-industry approach in order to defend and advance its interests
with other powerful bodies. It is no longer tenable for governments to interact only with the largest, andmost powerful media organizations, just as it is not in the interests of the largest or the oldest media
organizations to keep separate from the emerging independent or nonprofit digital sector. Coalitions
built around common interests can defend media freedom, attract funding, and build towards the future.

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APPENDICESLIST OF INTERVIEWEES AND SUBMISSIONSInterviewees• Minna Aslama, docent, University of Helsinki, Media and communication studies• Prof. Charlie Beckett, Polis, London School of Economics (LSE)• Julia Cagé, associate professor of economics, Sciences Po Paris• Premesh Chandran, CEO, Malaysiakini• Styli Charalambous, co-founder and CEO, Daily Maverick• Alex Cobham, chief executive, Tax Justice Network• James Deane, head of policy, BBC Media Action (and written submission)• Marius Dragomir, director of the Center for Media, Data & Society (CMDS), Central European University• Naresh Fernandes, editor, scroll.in• Stephen Fozard, project director, Global Alliance for Media Innovation (GAMI) at WAN-IFRA• Elizabeth Hansen Shapiro, senior research fellow, Tow Center for Digital Journalism• Dr C. Ann Hollifield, professor emerita, University of Georgia; media research and management consultant• Nadine Jurrat, head of research and evaluation (maternity cover), Deutsche Welle Akademie• Prof. Dr Arne H. Krumsvik, Kristiania University College, Oslo
• Prof. Dr Lucy Kueng, senior research associate, Reuters Institute, Oxford University• Nishant Lalwani, managing director, Luminate.
• Amanda D. Lotz, professor, Digital Media Research Centre, Queensland University of Technology• Harlan Mandel, CEO, Media Development Investment Fund
• Mira Milosevic, executive director, Global Forum for Media Development• Tania L. Montalvo, deputy editorial director, Animal Político
• Prof. Rasmus Kleis Nielsen, director of the Reuters Institute for the Study of Journalism at the University of Oxford• Peter Noorlander, Lead adviser, Global Rights Hub• Ory Okolloh, impact investor and governance expert• Jakub Parusinski, lecturer at the Stockholm School of Economics in Riga
• Rishad Patel, co-founder and head of product, and Alan Soon, co-founder, Splice Media (joint interview)• Henri Pigeat, former president, Agence France Presse• Corinne Podger, director, Digital Skills Agency• Damian Radcliffe, Carolyn S. Chambers Professor in Journalism and Professor of Practice, School of Journalism andCommunication, University of Oregon• Sibylle Rizk, policy director at Kulluna Irada. Former editor-in-chief of Le Commerce du Levant.
• Patrice Schneider, chief strategy office, Media Development Investment Fund (MDIF)• Ross Settles, adjunct professor, Journalism and Media Studies Centre, The University of Hong Kong
• Francesca Silvani, key expert freedom of expression, Media4Democracy• Olaf Steenfadt, Head of the Journalism Trust Initiative at Reporters Sans Frontières (RSF)• Kirstine Stewart , head, Shaping the Future of Media, Entertainment and Sport / executive committee member,World Economic Forum• Dr. Damian Tambini, London School of Economics (LSE)• Ramsey Tesdell, Executive Director, Sowt Media• Patricia Torres-Burd, Media Development Investment Fund (MDIF)• Jordi Vaquer, director, Foresight and Analysis / acting director, Strategy Unit, Open Society Foundations• Sheetal Vyas, founding executive director, International Fund for Public Interest Media (and written submission)• Lisa Witter, co-founder, Apolitical & CEO, Apolitical Foundation

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Written submissions
The Forum issued an online call for evidence and submissions from around the world, and received 26 submissions
via email and webform, including from those listed below:• Patrick Boehler, head of digital strategy, Radio Free Europe/Radio Liberty• George Brock, journalist, and chair, Public Benefit Journalism Research Centre• Maria Catalina Colmenares-Wiss, media development and sustainability consultant• Prue Clarke, executive director, New Narratives• Mark Glaser, associate, Dot Connector Studio• Luciana Gurgel, editor-in-chief, MediaTalks, and Eduardo Ribeiro, publisher, J&Co, Brazil• Dr Mark Lee Hunter and Kevin J. Davis• Prof. Dr Marlen Komorowski, guest professor and senior researcher at imec-SMIT-Vrije Universiteit, Brussel• Jason Lambert, senior director, Media Business, Internews• Una Murphy, co-founder/publisher, VIEWdigital Northern Ireland• Dr Mary Myers, consultant and independent researcher• Jean-Jacques Sahel, Google• Dr Martin Scott, University of East Anglia, Dr Mel Bunce, Department of Journalism, City, University of London, andDr Kate Wright, senior lecturer in Media and Communications, University of Edinburgh (joint submission)• Dominic Young, founder, Axate

Consultation in Africa in partnership with CFI,
the French media development agency
The Forum, in partnership with Canal France International (CFI), ran a consultation in 15 countries in Africa between
November and December 2020. 82 media practitioners, researchers and representatives of civil society organisations
were interviewed:• Jean Eudes Mitokpè, Journalist, Les pharaons (Benin)• Eric Azanney, Journalist, Awalé Afriki (Benin)• Marcel Kpogodo, Journalist, Le mutateur & Stars du Bénin (Benin)• Zouberou Koukou, Journalist, Union des Professionnels des Médias du Bénin (UPMB) (Bénin)• Léonce Gamaï, Journalist, Banouto (Benin)• M’ma Camara, Journalist, VOA Afrique (Côte d’Ivoire)• Oumar Kobena, Journalist, Gbêkê FM (Côte d’Ivoire)• Honoré Kokouda Adontui, Editor in chief, Le Correcteur (Togo)• Fabrice Pétchézi, Chair, Observatoire Togolais des Médias (OTM) (Togo)• Loïc Lawson, Chair, Union Internationale de la Presse Francophone section Togo (UPF Togo) (Togo)• Tchagnao Arimiyao, chair, Conseil national des patrons de presse (Conapp) (Togo)• Jerry Edouard, Journalist, Dream’in TV (Madagascar)• Solondraibe Rajaonson, Freelance journalist (Madagascar)• Ketakandriana Rafitoson, Jurist, Transparency international (Madagascar)• Didi Ratsimbazafy, Journalist, Conseil de l’ordre des journalistes (Madagascar)• Lova Rabary-Rakotondravony, Editor in Chief, 2424.mg (Madagascar)• Rassin Vanier, Journalist, Seychelles News Agency (Seychelles)• Clive Camille, Journalist, Radius Studios (Seychelles)• Kamal’Eddine Saindou, Journalist, National Press Council (Seychelles)67

• Moinadjoumoi Papa-Ali, Journalist, Office de Radio et Télévision des Comores (Comores)• Hayate Abdou, Journalist, National Magazin Comores (Comores)• Ngom Moussa, Director, Maison des reporters (Senegal)• Ibrahima Ngom, Researcher on media business models (Senegal)• Hamadou Tidiane Sy, Director, School of Journalism EJICOM, (Senegal)• Abdou Diaw,economic journalist (Senegal)• Daouda Mine, Director, digital media at Groupe Futurs Médias (GFM) (Senegal)• Jean Meissa Diop, teacher, Center for the Study of Information Science and Technology of Dakar (Senegal)• Dr Mamadou Ibra Kane,President, the Council of Publishers and Press Distributors in Senegal (CEDPS) (Senegal)• Bamba Kassé, Secretary General of the Union of Information and Communication Professionals of Senegal l(SYNPICS) (Senegal)• Ibou Fall, director of publication, Le Petit’Railleur (Senegal)• Mamadou Thior, President, Council for the respect of ethics and deontology in the media (CORED) (Senegal)• Maké Dagnokho, Director, Alkuma Groupe (Senegal)• Aristide BOUNAH, Developer, Afrik-inform.com (Cameroun)• Guidai Gatama, Director of publication, l’Oeil du sahel (Cameroun)• Evelyne, Owona Essomba, Journalist, CRTV News (Cameroun)• Thierry Ndong Owona, Journalist, Journal Integration (Cameroun)• Dipita Tongo Etonde, Journalist, STV (Cameroun)• Corine Esse, Teacher, University of Yaoundé II, MINTP(Cameroun)• Olive, Atangana, Journalist, lurgentiste.com (Cameroun)• Jean Paul Tchoumdou, Owner, In&Out (Cameroun)• Alain Denis Mbezele, Journalist, National Communication Council (Cameroun)• Joseph Thierry Okala Ebode, Teacher, Movement for the Renaissance of Cameroon -MRC (Cameroun)• Andzongo Sylvain, Journalist, Expression économique (Cameroun)• Georges Alain Boyomo, Journalist, Mutations (Cameroun)• Roland Tsapi Tatsitsa, Journalist (Cameroun)• Guy Hervé Fongang, Director of publication,www.eurecanews.info (Cameroun)• Rodrigue Tongue, Journalist, Canal 2 international (Cameroun)• Martin Camus Mimb, Journalist, Radio Sport Infos (Cameroun)• Augustin Armel Minka, Analyst (Cameroun)• Louis Marcel Satou, Cameraman, Vision4 TV Congo (Republic of the Congo)• Privat Tiburce Massanga, Journalist, Radio MUCODEC (Republic of the Congo)• Blanche Ngokoumounga, Journalist, Radio Congo Pointe-Noire (Republic of the Congo)• Laudes Martial M’Bon, Editor-in-chief, nouvellesducongo.info (Republic of the Congo)• Arsène Severin, Journalist, Vox TV (Republic of the Congo)• Jean Claude Afa’a, Chair, National network of independent journalists (Gabon)• Achille Mouanda Moussotsi, Journalist, Radio Gabon (Gabon)• Géraud Wilfried Obangome, CEO, Plusinfos.com (Gabon)• Thomas René She, Journalist, Globe Infos (Gabon)• Jean-Yves Ntoutoume, Journalist, Pyramid Media (Gabon)• Sbu Ngalwa, chairman, The South African NaLonal Editors’ Forum (South Africa)• Branko Brkic, founder and editor, Daily Maverick (South Africa)• Anton Harber, adjunct professor of journalism at the University of the Witwatersrand, author, former editor (South
Africa)• Sipho Kings, Editor-in-chief, Mail & Guardian (South Africa)• Harry Dugmore, senior professor, Rhodes University’s School of Journalism and Media Studies (South Africa)• Izak Minaar, Media consultant (South Africa)• Idris Akinbajo, Managing Editor, Premium Times (Nigeria)• Dayo Aiyetan, Executive Director, International Centre for Investigative Reporting (Nigeria)

68• Joshua Olufemi, Founder, Dataphyte (Nigeria)• Soni Daniel, Head of Northern Operations, Vanguard Newspaper (Nigeria)• Ibanga Isine, Managing Editor, The Next Edition (Nigeria)• Anyenekpon Ukpong, Managing Editor of Guide News (Nigeria)• Inibehe Effiong, Legal counsel (Nigeria)• Balthazar Kitundu, Lawyer, Deutsche Welle (Tanzania)• Paul Mbaraga, Director, Radio Salus (Rwanda)• Innocent Musafari, Project Manager, ROJAPED (Rwanda Organisation of Journalist Advocating for Persons with
Disabilities and other Vulnerable People through Media) (Rwanda)• Jean Charles Kanamugire, Managing Director, Kigali Today (Rwanda)• Jean Bosco Rushingabigwi, Independent media practitioner (Rwanda)• Martin Semukanya, Independent Media Professional (Rwanda)• Peacemaker Peacemaker, Executive Secretary, Peacemaker (Rwanda)• Musafiri Mulopwe, Independent Media Professional (Rwanda)• Jacques Kikuni, Journalist and Radio Director, Radio Tele Muungano (Rwanda)• Clothidle Aziza, Program Manager, Diakona RDC (DR Congo)

69

NOTES[1]

Nielsen, R. K., Federica Cherubini & Simge Andı, (2020). Few Winners, Many Losers: The COVID-19 Pandemic’s Dramatic and Unequal Impact on Independent News Media. Reuters Institute Report, October 2020.

[2]

See, https://www.whitehouse.gov/briefing-room/statements-releases/2021/05/03/statement-by-president-joe-biden-on-the-occasionof-world-press-freedom-day/[3]

Radcliffe, D. (2020). The Impact of COVID-19 on Journalism in Emerging Economies and the Global South. London: Thomson Reuters Foundation. http://covid-report.trust.org/[4]

Repucci S. & A. Slipowitz, (2021). Democracy under Siege. Freedom House. https://freedomhouse.org/report/freedom-world/2021/
democracy-under-siege[5]

Alizada, N. et al. (2021). Autocratization Turns Viral. Democracy Report 2021. Gothenburg: University of Gothenburg: V-Dem Institute.
https://www.v-dem.net/media/filer_public/74/8c/748c68ad-f224-4cd7-87f9-8794add5c60f/dr_2021_updated.pdf[6]See, for example, World Inequality Lab: https://wid.world/world-inequality-lab/[7]

See, for example, World Economic Forum, (2021). Global Gender Gap Report 2021. https://www.weforum.org/reports/global-gender-gap-report-2021[8]

See, for example, International Labour Organization, (2021). World Employment and Social Outlook 2021. https://www.ilo.org/global/
research/global-reports/weso/2021/WCMS_771749/lang--en/index.htm[9]United Nations Secretary-General, (2021). Secretary-General’s video message: COVID-19: How do we prevent the pandemic from becoming a media extinction event? https://www.un.org/sg/en/content/sg/statement/2021-04-28/secretary-generals-video-message-covid-19-how-do-we-prevent-the-pandemic-becoming-media-extinction-event%E2%80%9D[10]International Press Institute, (2021). IPI Covid-19 Press Freedom Tracker. https://ipi.media/covid19/ (accessed 21 April 2021).

[11]

See, for example, across Europe (https://coronanewsroom.org/stories/policy-reactions-from-news-media-to-covid-19-situation), South
Africa (https://ewn.co.za/2020/03/26/mthembu-explains-why-media-s-classified-as-essential-service), UK (https://www.pressgazette.
co.uk/government-gives-key-worker-status-to-all-journalists-reporting-on-coronavirus-pandemic/), USA (https://www.newsmediaalliance.org/important-news-publishers-essential-during-pandemic/) and Zimbabwe (https://www.newsday.co.zw/2020/04/government-includes-journalists-media-in-list-of-essential-services/)[12]

Columbia Global Freedom of Expression, (2021). Jurisprudence related to COVID-19. https://globalfreedomofexpression.columbia.
edu/updates/2021/03/jurisprudence-relating-to-covid-19/[13]

Snyder, J. M. Jr. & D. Strömberg, (2008). Press Coverage and Political Accountability. National Bureau of Economic Research (NBER)
Working Paper No.13878. https://www.nber.org/system/files/working_papers/w13878/w13878.pdf; Rubado M. E. & J.T. Jennings,(2020). Political Consequences of the Endangered Local Watchdog: Newspaper Decline and Mayoral Elections in the United States.
Urban Affairs Review, 56(5), pp.1327-1356 https://journals.sagepub.com/doi/abs/10.1177/1078087419838058?journalCode=uarb;
Bruns, C. and O. Himmler, (2011). Newspaper Circulation and Local Government Efficiency. The Scandinavian Journal of Economics, 113,
pp.470-492. https://doi.org/10.1111/j.1467-9442.2010.01633.x; Yazaki, Y. (2017). Newspapers and political accountability: evidence
from Japan. Public Choice, 172, pp. 311–331. https://doi.org/10.1007/s11127-017-0444-x[15]Powers, M. (2018). NGOs as newsmakers: The changing landscape of international news. New York: Columbia University Press.

[16]

Nielsen, R.K. (2018) The Changing Economic Contexts of Journalism. The Handbook of Journalism Studies. https://rasmuskleisnielsen.
files.wordpress.com/2018/05/nielsen-the-changing-economic-contexts-of-journalism-v2.pdf[17]See, for example, RSF on the ‘unprecedented level of hostility towards media personnel’ in 2018. https://rsf.org/en/news/rsfs-2018round-deadly-attacks-and-abuses-against-journalists-figures-all-categories[18]

For example, Mahone, J. et al. (2019). Who’s Producing Local Journalism? News Measures Research Project, DeWitt Centre for Media and
Democracy. https://dewitt.sanford.duke.edu/wp-content/uploads/sites/27/2019/08/Whos-Producing-Local-Journalism_FINAL-1.pdf[19]

See, for example, Allen, J., B. Howland, M. Mobius, D. Rothschild & D. J. Watts, (2020). Evaluating the Fake News Problem at the Scale ofthe Information Ecosystem. Science Advances 6 (14): aay3539. https://doi.org/10.1126/sciadv.aay3539[20]

Newman, N. et al. (2018). Reuters Institute Digital News Report 2018. University of Oxford: Reuters Institute for the Study of Journalism(RISJ). https://s3-eu-west-1.amazonaws.com/media.digitalnewsreport.org/wp-content/uploads/2018/06/digital-news-report-2018.pdf[21]

See, for example, Jasmine Enberg (2019). Global Digital Ad Spending. eMarketer. https://www.emarketer.com/content/global-digital-ad-spending-2019[22]

Turvill, William. (2021). Mark Thompson interview: How New York Times defied ‘scepticism’ to build digital subscriptions powerhouse.
Press Gazette. https://www.pressgazette.co.uk/mark-thompson-new-york-times-interview[23]

Newman et al. 2020. Op cit.

[24]

Richard Fletcher (2020). How and why people are paying for online news. Digital News Report, University of Oxford: Reuters Institute for
the Study of Journalism (RISJ). https://www.digitalnewsreport.org/survey/2020/how-and-why-people-are-paying-for-online-news/[25]

See Mediatique, (2012). Ofcom report. The Provision of News in the UK. https://www.ofcom.org.uk/__data/assets/pdf_file/0030/54597/
annex6.pdf.pdf, and Nielsen, R. K., F. Cherubini & S. Amdi (2020). Few winners, many losers: the COVID-19 pandemic’s dramatic andunequal impact on independent news media. University of Oxford: Reuters Institute for the Study of Journalism (RISJ). https://reutersinstitute.politics.ox.ac.uk/few-winners-many-losers-covid-19-pandemics-dramatic-and-unequal-impact-independent-news-media[26]

UNESCO (2017). Media Development Indicators (MDIs). https://en.unesco.org/programme/ipdc/initiatives/mdis (April 27, 2021).

70

[27]

Jurrat, N. & L. Moore (2020). Media Viability: New indicators show what is at stake. Deutsche Welle (DW) Akademie. https://www.
dw.com/en/media-viability-new-indicators-show-what-is-at-stake/a-47874028[28]

World Association of News Publishers (WAN-IFRA). World Press Trends. https://wan-ifra.org/world-press-trends/[29]

Napoli, P. M., S. Stonbely, K. McCollough & B. Renninger. (2017). Local Journalism and the Information Needs of Local Communities.
Journalism Practice, 11(4), pp. 373–395. https://doi.org/10/gfkqbz; Stonbely, S. (2021). What Makes for Robust Local News Provision?
Looking at the Structural Correlates of Local News Coverage for an Entire U.S. State, and Mapping Local News Using a New Method.
Columbia Journalism Review. https://www.cjr.org/tow_center_reports/what-makes-for-robust-local-news-provision-looking-at-the-structural-correlates-of-local-news-coverage-for-an-entire-u-s-state-and-mapping-local-news-using-a-new-method.php/.

[30]

European Commission. (2020). Call for Proposals: Media Ownership Monitor | Shaping Europe’s Digital Future. https://digital-strategy.
ec.europa.eu/en/funding/call-proposals-media-ownership-monitor; Media Ownership Monitor. https://www.mom-rsf.org/en/; Centre
for Media Pluralism and Freedom. Media Pluralism Monitor. https://cmpf.eui.eu/media-pluralism-monitor/.

CHAPTER 1[31]

UN Special Rapporteur on Freedom of Opinion and Expression, OSCE Representative on Freedom of the Media, OAS Special Rapporteur on Freedom of Expression and ACHPR Special Rapporteur on Freedom of Expression and Access to Information (2018). Joint
Declaration on Media Independence and Diversity in the Digital Age. https://www.osce.org/files/f/documents/1/e/379351.pdf[32]International Media Support. (2019) .The safety of women journalists: Breaking the cycle of silence and violence. https://www.
mediasupport.org/publication/the-safety-of-women-journalists/; Chen, G. M. & al. . (2020). ‘You really have to have a thick skin’:A cross-cultural perspective on how online harassment influences female journalists. Journalism, 21(7), pp. 877–895 https://doi.
org/10.1177/1464884918768500[33]

The Rt Hon Lord Neuberger of Abbotsbury, Amal Clooney, Baroness Helena Kennedy QC, Can Yeginsu (2021). The Need for Independent Judges and a Free Press in a Democracy. International Bar Association. https://www.ibanet.org/Article/NewDetail.aspx?ArticleUid=44be9e5d-1f05-4cf8-b8ac-b0f47ed50844[34]

Private sector entities have obligations towards independent journalism too, as the UN Guiding Principles on Business and Human
Rights make clear, and which are noted in Bennett Freeman’s 2021 report for Chatham House on ‘The role of the private sector inprotecting civic space’: https://www.chathamhouse.org/2021/02/role-private-sector-protecting-civic-space[35]

Schiffrin, A. ed. (2017). In the Service of Power: Media Capture and the Threat to Democracy. Center for International Media Assistance. https://www.cima.ned.org/resource/service-power-media-capture-threat-democracy/; Dragomir, M. (2018). Control themoney, control the media: How government uses funding to keep media in line. Journalism, 19(8), pp. 1131–1148. https://doi.
org/10.1177/1464884917724621[36]

See the International Press Institute’s Covid-19 Press Freedom Tracker: https://ipi.media/covid19/?alert_type=0&language=0&years=0&country=0; and RSF’s #Tracker_19 project mapping press freedom violations under Covid-19: https://rsf.org/en/tracker19-Coronavirus-Covid19.

[37]

Council of Europe. (2019). Draft Recommendation of the Committee of Ministers to Member States on promoting a favourable
environment for quality journalism in the digital age. Retrieved from: https://rm.coe.int/msi-joq-2018-rev7-e-draft-recommendation-on-quality-journalism-finalis/168098ab76; Boev, B. & B. Bukovska. (2011). Public Service Media and Human Rights. Council ofEurope. https://rm.coe.int/16806da766[38]

Gov.uk (2021). Media Freedom Coalition: An Overview. Retrieved from https://www.gov.uk/government/publications/media-freedom-coalition-an-overview/media-freedom-coalition-an-overview; Gov.uk (2019). Global Pledge on Media Freedom
https://www.gov.uk/government/publications/global-pledge-on-media-freedom/global-pledge-on-media-freedom; Gov.uk (2021).
National Safety Plan for Journalists. https://www.gov.uk/government/publications/national-action-plan-for-the-safety-of-journalists/
national-action-plan-for-the-safety-of-journalists[39]

International Bar Association (n.d.). IBAHRI Secretariat to the High-Level Panel of Legal Experts on Media Freedom. https://www.
ibanet.org/HRI-Secretariat/Reports.aspx#enforcement[40]

Forum on Information & Democracy. (2019). Principles on Information & Democracy. https://informationdemocracy.org/principles/.

[41]

Benequista, N. (2019). Confronting the Crisis in Independent Media: A Role for International Assistance. Center for International Media
Assistance (CIMA). https://www.cima.ned.org/wp-content/uploads/2019/03/CIMA_Entry-Points-Report_web150ppi-1.pdf; Internet Governance Forum (IGF). (2019). Dynamic Coalition on the Sustainability of Journalism and News Media (DC-Sustainability). https://www.
intgovforum.org/multilingual/content/dynamic-coalition-on-the-sustainability-of-journalism-and-news-media-dc-sustainability; Open
Government Partnership (n.d.). Media Freedom and the Open Government Partnership (OGP). https://www.opengovpartnership.org/
wp-content/uploads/2019/07/Media-Freedom-and-OGP.pdf; Theyworkforyou (2020). Press Freedom. https://www.theyworkforyou.
com/wrans/?id=2020-12-10.128312.h; Alliance for Multilateralism (n.d.). What Is the “Alliance for Multilateralism”?. https://multilateralism.org/the-alliance/.

[42]

Networks like Apolitical have emerged for public servants to address these skills gaps: https://apolitical.co/[43]

Wardle, C. & H. Derakhshan, (2017). Information Disorder: Toward an interdisciplinary framework for research and policymaking.
Harvard Kennedy School: Shorenstein Center for Media, Politics and Public Policy. https://shorensteincenter.org/information-disorder-framework-for-research-and-policymaking/[44]

European Broadcasting Union (2020). The Funding of PSM 2020. https://www.ebu.ch/files/live/sites/ebu/files/Publications/MIS/login_
only/funding/EBU-MIS-Funding_of_PSM_2020_Public.pdf[45]

See OECD figures on fossil fuels: https://www.oecd.org/fossil-fuels/, and IMF 2019 estimates, which are even higher: https://www.
imf.org/en/Publications/WP/Issues/2019/05/02/Global-Fossil-Fuel-Subsidies-Remain-Large-An-Update-Based-on-Country-Level-Estimates-46509

71

[46]

Such as innovation funds that are abandoned as quickly as they are established: https://www.nesta.org.uk/report/future-news-pilotfund-end-programme-report/

CHAPTER 2[47]Živkovic, M. (2016). Who will pay for journalism? Alternative Models for Independent Media Funding. South East Europe Media Observatory. Retrieved from http://mediaobservatory.net/sites/default/files/Alternative%20Models%20for%20Media%20Funding%20-Who%20
Will%20Pay%20for%20Journalism.pdf[48]

Deane, J. (2021). Is independent media a public good and is public subsidy to support it realistic? PRIMED Working Paper 1. http://
downloads.bbc.co.uk/mediaaction/pdf/primed-pathways-media-sustainability-april-2021.pdf[49]

Schweizer C., et al. (2014). Public Funding of Private Media. LSE Media Policy Project, Media Policy Brief 11. http://eprints.lse.
ac.uk/56427/1/LSEMPPBrief11.pdf[50]

Nielsen, R. K. & G. Linnebank (2011). Public Support for the Media: A Six-Country Overview of Direct and Indirect Subsidies. University of
Oxford: Reuters Institute for the Study of Journalism (RISJ). https://reutersinstitute.politics.ox.ac.uk/sites/default/files/2017-11/Public%20support%20for%20Media.pdf[51]

See, for example, the work of UCL’s Institute for Innovation and Public Purpose (IIPP) and its Mission-Oriented Innovation Network(MOIN): https://www.ucl.ac.uk/bartlett/public-purpose/about-moin[52]See, for example, McCleary, W. (1991). The Earmarking of Government Revenue: A Review of Some World Bank Experience. The WorldBank Research Observer, 6(1), 81–104. https://doi.org/10/c2tzvx[53]

OECD (2020). Tax Challenges Arising from Digitalisation – Report on Pillar One Blueprint: Inclusive Framework on BEPS. OECD/G20
Base Erosion and Profit Shifting Project. Paris: OECD Publishing. , https://doi.org/10.1787/beba0634-en.

[54]

International Centre for Tax and Development (2021). Taxing the Digitalising Economy. https://www.ictd.ac/theme/taxing-the-digitalising-economy/[55]

Statistics Denmark. (2021). Budgets of General Government. https://www.dst.dk/en/Statistik/emner/nationalregnskab-og-offentlige-finanser/offentlige-finanser/offentlig-forvaltnings-budgetter-finanslov; Schrøder, K. C. & M. Ørsten, (2019). Digital News Report:
Denmark. University of Oxford: Reuters Institute for the Study of Journalism (RISJ). https://www.digitalnewsreport.org/survey/2019/denmark-2019/[56]

Kultur Ministeriet. (2021). Tilskudsmodtagere af redaktionel produktionsstøtte. https://slks.dk/omraader/medier/skrevne-medier-trykteweb/redaktionel-produktionsstoette/tilskudsmodtagere/.

[57]

Dyremose, H. (2011). Demokratistøtte: Fremtidens Offentlige Mediestøtte. Copenhagen, Denmark: Styrelsen for Bibliotek Og Medier.
https://slks.dk/fileadmin/publikationer/Rapporter/Demokratistoette.pdf[58]

Schrøder & Ørsten, op. cit.

[59]

Bastin, Gilles, (2019). Les aides à la presse peuvent-elles contribuer à promouvoir le journalisme d’intérêt public? The Conversation.
https://theconversation.com/les-aides-a-la-presse-peuvent-elles-contribuer-a-promouvoir-le-journalisme-dinteret-public-115510[60]

France24 (2021). Aides à la presse: le gouvernement annonce une concertation en vue d’une réforme.
https://www.france24.com/fr/info-en-continu/20210420-aides-%C3%A0-la-presse-le-gouvernement-annonce-une-concertation-envue-d-une-r%C3%A9forme[61]

Government of Canada. (2019). The Government of Canada Supports Canadian Journalism to Ensure the Vitality of Democracy.
https://www.canada.ca/en/canadian-heritage/news/2019/05/the-government-of-canada-supports-canadian-journalism-to-ensure-the-vitality-of-democracy.html[62]

The Canadian government’s explanation of what kinds of organizations qualify for their various tiers of support is set out here, forexample.

[63]

Kaufholz, H. (2020). Denmark provides a survival kit for media outlets. European Centre for Press and Media Freedom. Retrieved fromhttps://www.ecpmf.eu/covid19-and-world-press-freedom-day-denmark-provides-a-survival-kit-for-media-outlets/[64]

In the wake of the unlawful killing of George Floyd in the USA in 2020, and the subsequent #BlackLivesMatter and associated protests
across many parts of the world, one particular call for direct funding as a form of historic reparations was made in the USA: https://
mediareparations.org/[65]

See, for example, the Dutch Stimuleringsfonds voor de Journalistiek, or Dutch Journalism Fund: www.svdj.nl[66]

UCL Institute for Innovation and Public Purpose (IIPP). (n.d.). Patient finance and public banks. https://www.ucl.ac.uk/bartlett/public-purpose/research/patient-finance-and-public-banking[67]

New Jersey Civic Information Consortium (n.d.). https://njcivicinfo.org/[68]

Civitates (n.d.). Independent Public Interest Journalism. https://civitates-eu.org/independent-public-interest-journalism/; Padania,
S. (2019). How to fund investigative Journalism: Insights from the field and its key donors. Deutsche Welle Akademie. https://p.
dw.com/p/3iwD2[69]

Myers, M. & L. A. Juma, (2018). Defending Independent Media: A Comprehensive Analysis of Aid Flows. Center for International Media
Assistance (CIMA). https://www.cima.ned.org/publication/comprehensive-analysis-media-aid-flows/[70]

Council of Europe. (2019). Public Service Media: Public service media are ‘an important public source of unbiased information anddiverse political opinions [and] can contribute greatly to the promotion of social cohesion, cultural diversity and pluralist communication accessible to everyone’. https://rm.coe.int/leaflet-public-service-media-en/1680735c27

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[71]

Research and policy work is underway to try to formulate new arrangements of how universality might work in the contemporary
media environment, with some focus falling on the concept of ‘due prominence.’ See, for example, Mazzoli, E. M. & D. Tambini, (2019)
Prioritisation Uncovered: The Discoverability of Public Interest Content Online. Council of Europe. https://rm.coe.int/publication-content-prioritisation-report/1680a07a57[72]

Parliamentary Assembly of the Council of Europe, Resolution 2255 (2019). Public service media in the context of disinformation andpropaganda. http://assembly.coe.int/nw/xml/XRef/Xref-XML2HTML-EN.asp?fileid=25406[73]

Media Freedom Rapid Response. (2021). European Union Must Act on Media Freedom in Poland, Hungary and Slovenia. https://www.
mfrr.eu/european-union-must-act-on-media-freedom-in-poland-hungary-and-slovenia/ .

[74]

Lestón-Huerta, T., M. Goyanes & B. Mazza, (2021). ¿Qué Hemos Aprendido sobre la Radiodifusión de Servicio Público en el Mundo?
Una Revisión Sistemática de la Literatura y Sugerencias para Investigaciones Futuras. Revista Latina de Comunicación Social, 79, pp.
65–88. https://doi.org/10.4185/rlcs-2020-1489[75]

Sehl, A., R. Fletcher & R. G. Picard, (2020). Crowding out: Is there evidence that public service media harm markets? A cross-national comparative analysis of commercial television and online news providers. European Journal of Communication, (4), pp. 389–409.
https://doi-org/10.1177/0267323120903688[76]

Donders, K., H. Van den Bulck & T. Raats (2019). The politics of pleasing: a critical analysis of multistakeholderism in Public Service
Media policies in Flanders. Media, Culture & Society, 41(3), pp. 347–366. https://doi.org/10.1177/0163443718782004[77]

Hansen, E. & E. Roseman, (2021). The Public Media Mergers Playbook. Harvard Kennedy School: Shorenstein Center for Media, Politics
and Public Policy . Retrieved from https://shorensteincenter.org/wp-content/uploads/2021/01/PMMP-Playbook-jan-21.pdf[78]

Deane, 2021. Independent media, op. cit.; Horowitz, M. & A. D’Arma. (2021). Dynamic Public Value. Lessons from the InnoPSM Research Network on Innovation in Public Service Media Policies. Unpublished Working Paper for the International Association for Mediaand Communication Research Conference.

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Mazzucato, M. et al. (2020). Re-Imagining Public Value with the BBC. UCL Institute for Innovation and Public Purpose (IIPP). https://www.ucl.ac.uk/bartlett/public-purpose/research/projects/re-imagining-public-value-bbc.

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Dragomir, M. & M. Horowitz. (2021). Media Capture and Its Contexts: Developing a Comparative Framework for Public Service Media;
Tunez-Lopez, Miguel, Francesco Campos-Freire &Marta Rodriguez-Castro (eds.). (2021). The Values of Public Service Media in an InternetSociety. London: Palgrave Macmillan.

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UK Parliament (2021). The Future of Public Service Broadcasting. UK House of Commons DCMS Select Committee Report. https://publications.parliament.uk/pa/cm5801/cmselect/cmcumeds/156/15602.htm.

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Myers, M. & L. A. Juma (2018). Defending Independent Media: A Comprehensive Analysis of Aid Flows. CIMA.https://www.cima.ned.
org/publication/comprehensive-analysis-media-aid-flows/[84]

The EC’s Technical Advisory Facility Media4Democracy provides advice and technical support to EU Delegations. https://media4democracy.eu/about-us/[85]

The COE has a number of Expert Committees, supported by its Information Society Unit: https://www.coe.int/en/web/freedom-expression/committees[86]

The Global Forum for Media Development has recently established IMPACT, a collective learning resource for the media development
sector and its donors: https://impact.gfmd.info/ and is also involved in the Dynamic Coalition on the Sustainability of Journalism andNews Media at the Internet Governance Forum: https://www.intgovforum.org/multilingual/content/dynamic-coalition-on-the-sustainability-of-journalism-and-news-media-dc-sustainability[87]

Deane, J. (2020). Enabling Media Markets to Work for Democracy. International Fund for Public Interest Media. https://ifpim.org/resources/feasibility-study/[88]

UNESCO (2020). Global Media Defence Fund. https://en.unesco.org/global-media-defence-fund[89]

Omer, Reema. (2020). GSP-Plus and Media Freedom. DAWN. https://www.dawn.com/news/1548553/gsp-plus-media-freedom[90]

Brown, Frances Z., Thomas Carrothers & Alex Pascal, (2021). America needs a Democracy Summit more than ever. Foreign Affairs.
https://www.foreignaffairs.com/articles/world/2021-01-15/america-needs-democracy-summit-more-ever[91]OECD (2018). The role of media and investigative journalism in combating corruption. https://www.oecd.org/corruption/
the-role-of-media-and-investigative-journalism-in-combating-corruption.htm[92]

Nielsen & Linnebank, (2011). op. cit.

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Government of Canada. (2021). Canadian Journalism Labour Tax Credit. https://www.canada.ca/en/revenue-agency/services/tax/businesses/topics/corporations/business-tax-credits/canadian-journalism-labour-tax-credit/guidance.html#h_3.

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Public Interest Journalism Initiative (PIJI) (2019-20). Research program into taxation.https://piji.com.au/research-and-inquiries/our-research/taxation-reform-for-public-interest-journalism/public-interest-journalism-tax-rebate/[95]

See, for example, Marín-Sanchiz, C-R., Miguel Carvajal & José-Luis González-Esteban, (2021). Survival Strategies in Freelance Journalism: An Empowering Toolkit to Improve Professionals’ Working Conditions, JournalismPractice. https://www.tandfonline.com/doi/abs/
10.1080/17512786.2021.1929414[96]

Government of Australia. (2020). Media Reform Green Paper 27 November 2020 https:// minister.infrastructure.gov.au/fletcher/media-release/mediareform-green-paper?web=1&wdLOR=c29BA68E6-6C08-0343- B7DE-1A91A6B5A9A7 (Cited in Deane, 2021, op. cit.)[97]

Government of Canada. (2021). Canada Revenue Agency. https://www.canada.ca/en/revenue-agency/services/tax/businesses/topics/
corporations/business-tax-credits/canadian-journalism-labour-tax-credit/guidance.html#h_4[98]

On potential misuses of this allowance, see, for example, Center for Media, Data and Society (CMDS) (n.d.). The Business of Misinfor-73

mation. https://cmds.ceu.edu/business-misinformation-final-report-how-misinformation-became-profitable-business-eastern-europe[99]

George J. Stigler Center for the Study of the Economy and the State, Committee for the Study of Digital Platforms, Media Subcommittee, (2019). Protecting Journalism in the Age of Digital Platforms, p.34. https://research.chicagobooth.edu/-/media/research/stigler/pdfs/
media---report.pdf[100]Such as provided by the Korea Press Foundation, for example: https://www.kpf.or.kr/eng/intropage/intropageShow.do?page_id=5ebf13c69783428e987e0ac1d2da8df3[101]

Bátorfy, A. & Á. Urbán, (2020). State advertising as an instrument of transformation of the media market in Hungary, East European
Politics, 36:1, pp. 44-65 10.1080/21599165.2019.1662398[102]

Thompson, Mark & Marius Dragomir, (2014). Lapdogs vs. Watchdogs: State Advertising and Media. Open Society Foundations. https://www.opensocietyfoundations.org/voices/lapdogs-vs-watchdogs-state-advertising-and-media[103]

Inter-American Commission on Human Rights. Office of the Special Rapporteur for Freedom of Expression (2011). Principios sobre
regulación de la publicidad oficial y libertad de expresión/Principles on the regulation of government advertising and freedom of expression. https://www.oas.org/en/iachr/expression/docs/publications/ADVERTISING%20PRINCIPLES%202012%2005%2007%20reduce.
pdf [link doesn’t work][104]

Gaur, A. et al. (2020). The Future of News in India. Vidhi Centre for Legal Policy. https://vidhilegalpolicy.in/research/the-future-of-newsin-india/ See pp. 53-55.

[105]

InvestEU. European Union. https://europa.eu/investeu/home_en.

[106]See, for example, the Zebra network: https://zebrasunite.coop/our-vision[107]

See: https://thegiin.org/research/publication/impinv-survey-2020[108]

See, for example, UNECA (2020). Increasing women’s access to capital critical in Africa’s fight against poverty. https://www.un.org/africarenewal/news/increasing-women%E2%80%99s-access-capital-critical-africa%E2%80%99s-fight-against-poverty, Fackelmann, S. &A. De Concini (2020). Funding Women Entrepreneurs. European Investment Bank. https://www.eib.org/attachments/thematic/why_are_women_entrepreneurs_missing_out_on_funding_en.pdf[109]

Armeni, A. & W. Negrón (2020). Investing in Equitable News and Media Projects. Ford Foundation. https://www.fordfoundation.org/media/5494/transform-finance-investing-in-equitable-news-and-media-projects-76.pdf[110]

Hansen Shapiro, Elizabeth. (2021). A new form of community-focused capital for local news. The National Trust for Local News.
https://medium.com/national-trust-for-local-news/the-national-trust-for-local-news-a-new-form-of-community-focused-capital-for-local-news-b7590407e428[111]

MediaPowerMonitor (2021). Private Investors in Talks to Fund European Journalism. https://mpmonitor.org/2021/03/private-investors-in-talks-to-fund-european-journalism/[112]

Padania, S. (2018). An Introduction to Funding Journalism and Media. Ariadne Network & Transparency and Accountability Initiative.
https://www.ariadne-network.eu/introduction-funding-journalism-media/[113]

Schiffrin, op. cit.; Dragomir, op. cit.

[114]

360Giving. https://www.threesixtygiving.org/; Candid. https://candid.org/.

[115]

Media Impact Funders (2021). Mapping the Field of Media and Philanthropy. https://mediaimpactfunders.org/the-field/[116]

Karstens, E. (2017). The Media Philanthropy Space in 2017. Alliance Magazine. https://www.alliancemagazine.org/feature/media-philanthropy-space-2017/.

[117]

The grantmaking Civitates is a pooled philanthropic fund involving 17 philanthropies from across Europe, and in 2020 it provided 10
investigative journalism centers and networks with core funding for three years: https://civitates-eu.org/independent-public-interest-journalism/. The Journalism Funders Forum is a pan-European network for philanthropies giving to or interested in independentjournalism: https://www.journalismfundersforum.com.

[118]

The Expertisekreis Qualitätsjournalismus und Stiftungen, or Expertise Circle for Quality Journalism and Foundations is part of theGerman Association of Foundations (Bundesverband Deutscher Stiftungen) and convenes over 100 foundations with an interestor expertise in funding journalism within or outside Germany. https://www.stiftungen.org/arbeitskreise-expertisekreise/expertisekreis-qualitaetsjournalismus-und-stiftungen.html[119]Calouste Gulbenkian Foundation (2021). European Media and Information Fund. https://gulbenkian.pt/en/european-media-and-information-fund/

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Picard, R. G., V. Belair-Gagnon & S. Ranchordás, (2016). The Impact of Charity and Tax Law/Regulation on Not-for-Profit News Organizations. University of Oxford: Reuters Institute for the Study of Journalism. https://reutersinstitute.politics.ox.ac.uk/sites/default/
files/2017-11/The%20impact%20of%20charity%20and%20tax%20law%20regulation%20on%20not%20for%20profit%20news%20organisations.pdf.

[121]

Such as Lawyers for Reporters in the USA: https://lawyers4reporters.org/, or the International Lawyers Project: https://www.internationallawyersproject.org/media-freedom[122]

Bill Birnbauer (2019). The biggest nonprofit media outlets are thriving but smaller ones may not survive. The Conversation. https://theconversation.com/the-biggest-nonprofit-media-outlets-are-thriving-but-smaller-ones-may-not-survive-109369

74[123]

Muttart Foundation. (2018). Consultation on non-profit journalism. https://www.muttart.org/wp-content/uploads/2019/03/Consultation-on-Non-Profit-Journalism-Feb-2019.pdf[124]

The 2019 Cairncross Report recommended a review from the UK charities regulator of the charitable status of journalism;Thakor, A.
(2020). Read All about It: When Can Journalism Be Charitable? Charity Commission. https://charitycommission.blog.gov.uk/2020/01/27/
read-all-about-it-when-can-journalism-be-charitable/; see also Brock, G. (2020). Coronavirus Is Killing Quality Journalism – Here’s
One Possible Lifeline. The Conversation. http://theconversation.com/coronavirus-is-killing-quality-journalism-heres-one-possible-lifeline-138627.

[125]

The Forum Gemeinnütziger Journalismus is a coalition of journalists, civil society, and funders advocating for the establishment ofsuch privileges for non-profit journalism at both the Land and Federal level in Germany.

[126]

Dickson, G. (2021). A review of proposals to provide news organisations with access to tax deductible gifts in Australia. Public Interest
Journalism Initiative (PIJI). https://piji.com.au/research-and-inquiries/our-research/taxation-reform-for-public-interest-journalism/philanthropic-giving-for-journalism/[127]

Professor Julia Cagé and Benoit Huet argue in their 2020 book L’Information est un bien public (Seuil, 2020), for the creation in France ofa new hybrid class of public purpose media organization that is able both to receive funding of this kind, and to make profits. To qualify for this status, outlets would need to invest a certain proportion of their budget in original news production, to include journalists
and editors in governance bodies, and to guarantee the governance body a veto over ownership changes.
https://www.seuil.com/ouvrage/l-information-est-un-bien-public-julia-cage/9782021483154[128]

J’aime l’info. https://www.jaimelinfo.fr/; Presse & Pluralisme. https://www.donspep.caissedesdepots.fr/.

[129]

Gov.uk (2019). The Cairncross Review; a sustainable future for journalism. https://www.gov.uk/government/publications/the-cairncross-review-a-sustainable-future-for-journalism ; Furman, J. (2019). Unlocking Digital Competition. Report of the Digital Competition
Expert Panel. Gov.uk. https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/785547/unlocking_digital_competition_furman_review_web.pdf; Gov.uk (2020). Press Release: New Competition Regime for Tech Giants to Give
Consumers More Choice and Control over Their Data, and Ensure Businesses Are Fairly Treated. https://www.gov.uk/government/
news/new-competition-regime-for-tech-giants-to-give-consumers-more-choice-and-control-over-their-data-and-ensure-businessesare-fairly-treated.

[130]

Crémer, J., Y. de Montjoye & H. Schweitzer, (2019). Competition Policy for the Digital Era. Publication Office of the European Union.
https://op.europa.eu/en/publication-detail/-/publication/21dc175c-7b76-11e9-9f05-01aa75ed71a1/language-en; European Commission (n.d.). Shaping Europe’s Digital Future: The Digital Services Act Package. https://digital-strategy.ec.europa.eu/en/policies/digital-services-act-package.

[131]

University of Baltimore (2020). The economic cost of keyword blacklists for online publishers. https://info.cheq.ai/hubfs/Research/
The%20Economic%20Costs%20of%20Keyword%20Blacklists%20covid%2019%20update.pdf[132]

Sweney, M., (2020). Newspapers to lose £50m in online ads as firms use coronavirus ‘blacklist’. The Guardian. https://www.theguardian.com/media/2020/apr/01/newspapers-to-lose-50m-in-online-ads-as-firms-use-coronavirus-blacklist[133]

In addition to the work of organizations like First Draft, there are numerous networks including the Credibility Coalition, Trust Project,
News Integrity Initiative, Content Authenticity Initiative, Coalition for Content Provenance and Authenticity, among others.

[134]

See: https://www.journalismtrustinitiative.org/about[135]

Japan Fair Trade Commission (2021). Approaches in the Digital Market. https://www.jftc.go.jp/en/policy_enforcement/digital/index.
html; Craig, E. (2021). Turkey Launches Online Advertising Market Study. Global Competition Review (GCR). https://globalcompetitionreview.com/digital-markets/turkey-launches-online-advertising-market-study; Global Competition Review (GCR) (2021). Data
Overload: The Asia-Pacific Tipline for 19 February 2021. https://globalcompetitionreview.com/gcr-asia/data-overload-the-asia-pacific-tipline-19-february-2021; Makunga, S. (2021). Press Release: Commission to Initiate a Market Inquiry on Digital Markets. The Competition Commission South Africa. http://www.compcom.co.za/wp-content/uploads/2021/02/COMMISSION-TO-INITIATE-A-MARKET-INQUIRY-ON-DIGITAL-MARKETS.pdf; Masson, J. (2020). Korea Set to Regulate Online Platforms. Global Competition Review (GCR). https://globalcompetitionreview.com/gcr-asia/digital-markets/korea-set-regulate-online-platforms[136]

Germany’s Bundeskartellamt and the French Autorité de la Concurrence worked together on a series of papers in 2016, for example,
Bundeskartellamt (2021). Digital Economy. https://www.bundeskartellamt.de/EN/Economicsectors/Digital_economy/digital_economy_
node.html).

[137]

OECD (2020). Digital Economy, Innovation and Competition. http://www.oecd.org/daf/competition/digital-economy-innovation-and-competition.htm; United Nations Conference on Trade and Development (2019). Intergovernmental Group of Experts
on Competition Law and Policy, Eighteenth Session. https://unctad.org/meeting/intergovernmental-group-experts-competition-law-and-policy-eighteenth-session[138]

Khan, L. (2017). Amazon’s Antitrust Paradox. The Yale Law Journal 126 (3): pp. 564-907: https://www.yalelawjournal.org/note/amazons-antitrust-paradox; Srinivasan, D. (2019). The Antitrust Case Against Facebook: A Monopolist’s Journey Towards Pervasive
Surveillance in Spite of Consumers’ Preference for Privacy. Berkeley Business Law Journal 16 (1): pp. 39. https://lawcat.berkeley.edu/record/1128876; Srinivasan, D. (2020). Why Google Dominates Advertising Markets. Stanford Technology Law Review 24 (1). https://wwwcdn.law.stanford.edu/wp-content/uploads/2020/12/Srinivasan-FINAL-Why-Google-Dominates-Advertising-Markets.pdf; Nadler, J. & D.
Cicilline (2020). Investigation of Competition in Digital Markets. United States House of Representatives, Sub-Committee on Antitrust,Commercial and Administrative Law of the Committee on the Judiciary. https://judiciary.house.gov/uploadedfiles/competition_in_digital_markets.pdf[139]

Ofcom (2021). A joined-up approach to digital regulation. https://www.ofcom.org.uk/about-ofcom/latest/media/media-releases/2021/a-joined-up-approach-to-digital-regulation[140]

European Commission (2021). The Digital Services Act Package. https://digital-strategy.ec.europa.eu/en/policies/digital-services-act-package[141]

See, for example, World Economic Forum (n.d.) Agile Regulation for the Fourth Industrial Revolution. https://www.weforum.org/projects/agile-regulation-for-the-fourth-industrial-revolution[142]

See, for example, Srinivasan, D. 2020, op. cit., and 2019, op. cit.

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McLaughlin, D. & S. Forden, (2021). Tech War With News Media Flares in U.S. With New Congress Push. Bloomberg.com. https://www.
bloomberg.com/news/articles/2021-03-10/tech-s-war-with-news-outlets-flares-as-u-s-lawmakers-ready-bill75

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McGoey, S. (2021). Panama Papers revenue recovery reaches $1.36 billion as investigations continue. International Consortium of
Investigative Journalism. https://www.icij.org/investigations/panama-papers/panama-papers-revenue-recovery-reaches-1-36-billion-as-investigations-continue/[145]

Graves, L. & N. Shabbir, (2019). Gauging the Global Impacts of the ‘Panama Papers’ Three Years Later. University of Oxford: Reuters
Institute for the Study of Journalism.https://reutersinstitute.politics.ox.ac.uk/risj-review/resignations-reforms-and-backlash-impacts-panama-papers[146]

Kaplan, D. & D. Sullivan (2016). Investigative Journalism & Foreign Aid: A Huge Return on Investment. Global Investigative Journalism
Network. https://gijn.org/2016/03/17/investigative-journalism-and-foreign-aid-a-huge-return-on-investment/[147]

See Recommendation 7A, Financial Accountability, Transparency and Integrity (FACTI) (2021). Financial Integrity For Sustainable Development. https://www.factipanel.org/explore-the-report[148]

See Commitment 4, Addis Taxation Initiative (2021). Declaration 2025. https://www.addistaxinitiative.net/sites/default/files/resources/
ATI Declaration 2025.pdf[149]

Center for the Study of Democracy (CSD). (2021). Capture Proofing Media in Southeast Europe. Policy Brief No. 98. https://csd.bg/publications/publication/capture-proofing-media-in-southeast-europe/; Filipova, R. (2021). Tackling Kremlin’s Media Capture in Southeast
Europe: Shared Patterns, Specific Vulnerabilities and Responses to Russian Disinformation. Center for the Study of Democracy (CSD).
https://csd.bg/publications/publication/tackling-kremlins-media-capture-in-southeast-europe/[150]

Mascagni, J., M. Moore & W. Prichard, (2021). Open Societies, Tax, and the British Aid Programme. The International Centre for Tax
and Development (ICTD). https://www.ictd.ac/blog/open-societies-tax-british-aid-programme/.

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Cicatiello, L., E. De Simone, S. Ercolano & G. L. Gaeta, (2021). Assessing the impact of fiscal transparency on FDI inflows. Socio-Economic Planning Sciences, Volume 73. https://doi.org/10.1016/j.seps.2020.100892.

[152]

See for example the resources gathered at the International Centre for Tax and Development (ICTD) website on Taxing the Digitalising
Economy: https://www.ictd.ac/theme/taxing-the-digitalising-economy/; Rukundo, S. (2020). Addressing the Challenges of Taxationof the Digital Economy: Lessons for African Countries, ICTD Working Paper 105. The International Centre for Tax and Development(ICTD). https://www.ictd.ac/publication/addressing-challenges-taxation-digital-economy-lessons-african-countries-rib/ ; and Center for
New Economy and Society, World Economic Forum. (2021) Building Back Broader: Policy Pathways for an Economic Transformation.
http://www3.weforum.org/docs/WEF_GFC_NES_Policy_Pathways_for_an_Economic_Transformation_2021.pdf[153]

FACTI Panel, op.cit.; The General Assembly of the United Nations, (2021). Report of the High-Level Panel on International Financial
Accountability, Transparency and Integrity for Achieving the 2030 Agenda (FACTI Panel). https://www.un.org/pga/75/2021/02/26/
report-of-the-high-level-panel-on-international-financial-accountability-transparency-and-integrity-for-achieving-the-2030-agenda-facti-panel/.

[154]

Addis, op. cit.

[155]

Charalambous, S. (2021). The Ailing News Media Industry Needs to Do More than Just Survive (Part 2). Medium. https://styli.medium.
com/the-ailing-news-media-industry-needs-to-do-more-than-just-survive-part-2-c1f9a7f88aa9.

[156]

Kaplan & Sullivan, op. cit.

[157]

Tripathi, A. & S. Mehta (2020). Equalisation Levy 2020: The need to revisit India’s new digital tax. The Dialogue. https://thedialogue.co/
wp-content/uploads/2020/12/Equalisation-Levy-2020-The-Dialogue.pdf[158]

Karr, T. (2021). Journalism won’t be saved one link at a time. Free Press. https://www.freepress.net/our-response/expert-analysis/insights-opinions/journalism-wont-be-saved-link-time[159]

Cabinet Office, Government of Japan (2019). International Symposium on Utilizing Dormant Assets for Social Issues, Information on
Utilization of Funds Related to Dormant Deposits. https://www5.cao.go.jp/kyumin_yokin/english/symposium_index-en.html.

[160]‘Global Right to Information Rating’. https://www.rti-rating.org/.

[161]

Fitzgerald, M. & P. Geoghegan, (2021). Fleet Street Editors Unite to Demand “Urgent” Action on Freedom of Information. openDemocracy. https://www.opendemocracy.net/en/freedom-of-information/fleet-street-editors-demand-urgent-action-to-protect-freedom-of-information/ .

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Deshmukh, V. & P. Keskar (2021). Life and Death in the Time of RTI: Case Studies from Maharashtra. Commonwealth Human Rights Initiative. https://www.humanrightsinitiative.org/download/1585041950Life%20And%20Death%20In%20The%20Time%20Of%20RTI%20
2020.pdf[163]

bellingcat. https://www.bellingcat.com/about/; Forensic Architecture. https://forensic-architecture.org/about/agency.

[164]

Open Contracting Partnership. https://www.open-contracting.org/; World Legal Information Institute (WorldLII). http://www.worldlii.
org/.

[165]

Publish What You Fund. https://www.publishwhatyoufund.org/.

[166]

IndiaSpend: Data Journalism, Analysis on Indian Economy, Education, Healthcare, Agriculture, Politics’. https://www.indiaspend.com/;
Open Government Partnership. https://www.opengovpartnership.org/.

[167]

Global Data Barometer. https://globaldatabarometer.org; Open Data Barometer. https://opendatabarometer.org/?_year=2017&indicator=ODB.

[168]

See, for example: https://mediaengagement.org/[169]

See, for example, the LSE’s JournalismAI collaboration project: https://blogs.lse.ac.uk/polis/category/journalism-ai/[170]

See, for example, The UK AI Council, (2021). AI Roadmap. https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/949539/AI_Council_AI_Roadmap.pdf[171]

AfriLabs. The Largest Network of African Technology Hubs. https://www.afrilabs.com/ .

76

[172]

Baraza Media Lab. About Us. https://barazalab.com/about/.

[173]

Welcome to Clwstwr. Clwstwr. https://clwstwr.org.uk/.

[174]

Digital Media Viability Lab. Mission and Vision. https://digitalmediaviability.com/about-us/mission-and-vision/.

[175]

Media City Bergen. (2015). https://mediacitybergen.no/about/.

[176]

Dulgheru, A.F. (2017). Media Lab Bayern. Global Alliance for Media Innovation (GAMI). https://media-innovation.news/media-lab/media-lab-bayern-an-incubation-unit-for-digital-media-development-and-innovation/.

[177]

Global Alliance for Media Innovation (GAMI). https://media-innovation.news/.

[178]

Stonbely, 2021, op. cit.

[179]

See, for example, the Atlas da Notícia in Brazil (https://www.atlas.jor.br/), Cartografías de la Información in Colombia (https://flip.org.
co/images/Documentos/Results_presentation_Cartografas_FLIP.pdf), research into local Czech news deserts (https://www.irozhlas.cz/
zpravy-domov/regionalni-lokalni-noviny-media-denik-lenka-cisarova_2002030630_jab), and recent coverage in the Philippines (https://adnchronicles.org/2020/11/01/news-deserts-emerge-in-pandemic-hit-philippines/)[180]

Hansen Shapiro, (2021). op.cit.

CHAPTER 4[181]

Schulte, A. & R. Bonilla (2021) Burn the Ships: A Guide to Igniting Cultural Change for News Media Companies. World Association of News
Publishers (WAN-IFRA)/Facebook Journalism Project. https://wan-ifra.org/2021/04/new-guide-to-help-activate-cultural-change-fornews-publishers-launched/[182]

See the News Product Alliance: https://newsproduct.org/about-us[183]

Kueng, Lucy (2020). Hearts and Minds: Harnessing Leadership, Culture & Talent to Really Go Digital. University of Oxford: Reuters Institutefor the Study of Journalism. https://reutersinstitute.politics.ox.ac.uk/sites/default/files/2020-11/Kueng%20-%20Hearts%20and%20
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Roper, Dean, (2019). World Press Trends 2019: The balancing act of publishers. World Association of News Publishers (WAN-IFRA).
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Newman, N. et al. (2020). Reuters Institute Digital News Report 2020. University of Oxford: Reuters Institute for the Study of Journalism .
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Newman, N. et al. (2018). Reuters Institute Digital News Report 2018. University of Oxford: Reuters Institute for the Study of Journalism. https://www.digitalnewsreport.org/survey/2018/overview-key-findings-2018/: ‘Those that were aware that digital newspapers aremaking a loss (10% of our sample) are more likely to pay for a news subscription or give a donation. More widely, this year we haveidentified different levels of news literacy within our online sample — and the next chart shows a clear link between knowledge about
how the news industry works and likelihood to pay in the future.’[195]

Turvill, Wiliam. (2021). 100k Club: Digital subscriptions top 23m, Press Gazette research finds. Press Gazette: https://pressgazette.co.uk/
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Flueckinger, Simone. (2021). How Poland’s Gazeta Wyborcza tackled a tough media environment. World Association of News Publishers (WAN-IFRA). https://wan-ifra.org/2021/01/how-polands-gazeta-wyborcza-tackled-a-tough-media-environment/77

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Schütz, Elna. (2020). Nigeria’s Stears is making data and media business work together. Jamlab. https://medium.com/jamlab/stears-ismaking-data-and-media-business-work-together-162103c3448[199]

Chowdhury, Miraj. (2021). Lessons in Transitioning from Legacy Media to Digital: Expert Tips from Asia. Global Investigative Journalism
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Scire, Sarah. (2021). Daily Nation, the largest newspaper in Kenya, adopts a paywall – and predicts more African-owned publications
will too. Nieman Lab. https://www.niemanlab.org/2021/01/daily-nation-the-largest-newspaper-in-kenya-adopts-a-paywall-and-predicts-more-african-owned-publications-will-too/[201]

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Ziegler, T. (2020). The Global Alternative Finance Market Benchmarking Report. Cambridge Centre for Alternative Finance, University ofCambridge. https://www.jbs.cam.ac.uk/faculty-research/centres/alternative-finance/publications/the-global-alternative-finance-market-benchmarking-report/[203]

Turvill, op. cit.

[204]

Nguyen, Terry. (2021). Virtual tips are helping content creators actually make money. Vox. https://www.vox.com/the-goods/22301751/
digital-tipping-creators-platforms[205]

Media Development Investment Fund (2021). Malaysiakini has successfully crowdfunded legal costs a number of times, most recently
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Aldenrath, P. et al. (2021). Safe. Strong. Viable – The Symbiosis between Media Viability & Media Safety. Deutsche Welle Akademie.
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Cohen, N. S. & G. De Peuter, (2020). New Media Unions: Organizing Digital Journalists. Routledge & CRC Press. Retrieved from https://www.routledge.com/New-Media-Unions-Organizing-Digital-Journalists/Cohen-Peuter/p/book/9781138327115 Fischer, Sara. (2021).
Record numbers of journalists unionize during COVID pandemic. Axios. https://www.axios.com/journalists-unionize-digital-media5f38770c-e398-4a18-8e6a-7f8374caaa80.html ;[208]

Kueng, op. cit.

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Oliinyk, E., E. Zaslavsky & J. Parusinski (2018). Independent Regional Media: A Fragile Existence . Media Development Foundation.
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Jurrat, Nadine & Attila Mong, (2020). Taking a 360° view of your media outlet’s viability! Deutsche Welle Akademie. https://www.
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Fabius, V., S. Kohli, & S. Moulvad Veranen, (2020). Meet the Next-Normal Consumer. McKinsey & Company. http://ceros.mckinsey.
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See, for example, the negotiated discounts offered by India digital news publication Scroll: https://scroll.in/theplus/[213]

See: https://www.mdif.org/mdif-is-purchasing-a-34-stake-in-leading-slovak-publisher-petit-press/[214]

Venema, Nienke. (2017). Underwriting Independent Media. Alliance Magazine. https://www.alliancemagazine.org/feature/underwriting-independent-media/[215]

UK Journal of Co-operative Studies. (2021). Special Issue on Journalism and the Co-operative Movement. https://www.ukscs.coop/pages/32-si-journalism-and-the-co-operative-movement [same as note 188]

[216]

See, for example, Equileap Gender Equality Global Report and Ranking 2021: https://equileap.com/wp-content/uploads/2021/03/Global-Report-2021.pdf[217]

Murray, S. (2017). Center for Cooperative Media Identifies 6 Models of Collaborative Journalism, a “revolution” in Media. Center for
Cooperative Media, Montclair State University. https://centerforcooperativemedia.org/center-cooperative-media-identifies-6-models-collaborative-journalism-revolution-media/.

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Montclair State University (n.d.). Collaborative Journalism Database. https://collaborativejournalism.org/database-search-sort-learn-collaborative-projects-around-world/.

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