Chapter 7

Soaring media ownership concentration
Comparing the effects of digitalisation
on media pluralism and diversity
Josef Trappel & Werner A. Meier

Abstract
This chapter addresses the evolution of media and communication concentration, its
causes, and its consequences. The political relevance of this perennial problem has
amplified over the past decade, but it is still largely ignored by politics. The scholarly social science discourse has determined time and again how media ownershipconcentration controls editorial boards and newsrooms, curtails content diversity,
marginalises less popular and consequently expensive content, and commodifies
cultural industries altogether. Despite this, the concentration of media ownership
remains one of the least-regulated media policy issues of the last three decades.
Metrics undeniably demonstrate continuous growth of ownership concentration at
the global, national, and local level. Digitalisation has not counterbalanced power
relations in society at large; rather, digital communication platforms reflect andreplicate dominant media structures. Lately, however, policy initiatives have emerged
to address the negative effects of ownership concentration in the media sector.
Keywords: media ownership concentration, oligopolistic media structures, media
pluralism, commercial imperative, public interest

Introduction
In 2022, the European Commission could celebrate the thirtieth anniversaryof its “Green Paper on Pluralism and Media Concentration in the InternalMarket” (European Commission, 1992). It is common knowledge that Internal Market regulations take time in Brussels, and controversial issues takeeven more time, but 30+ years is unusual, if not spectacular. But there is notreally a reason to celebrate. Media ownership concentration remains a largely
unregulated, although pressing, issue. In the literature, scholars seem to belosing hope that European policy will ever be able to harmonise adequate
ownership rules and go beyond only discussing the problem (Iosifidis, 2007;
Papathanassopoulos, 2018).
Trappel, J., & Meier, W. A. (2022).Soaring media ownership concentration: Comparing the effects of digitalisation on
media pluralism and diversity. In J. Trappel, & T. Tomaz (Eds.), Success and failure in news media performance: Comparative analysis in the Media for Democracy Monitor 2021 (pp. 147–164). Nordicom, University of Gothenburg. https://doi.
org/10.48335/9789188855589-7

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The latest wake-up call originates from the US. Over the last two decades,
ownership concentration in the field of media and communication accelerated
at an unprecedented speed, as digital platform companies conquered global
communication networks, first and foremost the Internet. The “big five” –labelled GAFAM (Google, Apple, Facebook, Amazon, and Microsoft) – alloriginate from the US. This ownership concentration in the digital sphere did
not replace the old structures of “big media” (a term borrowed from McChesney, 1999), but rather constitutes a parallel power structure.
Scholars have frequently, and meticulously, addressed the troubled relationship between media ownership concentration and democracy (Baker, 2007; McChesney, 2008; Meier & Trappel, 1998, to name just a few). Subsequently, theMedia for Democracy Monitor (MDM) research project (Trappel et al., 2011;
Trappel & Tomaz, 2021b, 2021c) dedicates two analytic indicators to media
concentration (at the national and the regional or local level), thus granting
prominence to this problem.
MDM Indicators and related research questions addressed in this chapter:(E1) Media ownership concentration national level

What is the degree of ownership concentration at the national level?
(Trappel & Tomaz, 2021a: 32)(E2) Media ownership concentration regional (local) level

What is the degree of ownership concentration at the regional (local) level?
(Trappel & Tomaz, 2021a: 33)

In this chapter, we discuss the continuities and discontinuities of media ownership concentration against the background of dominant digital platforms and in
the light of the contemporary scientific debate, the findings of the 2021 MDM,
as well as other relevant sources. We are interested in the evolution of ownership concentration in the decade of communication digitalisation (2010–2020),
its causes, and its consequences. In the second part of the chapter, we turn topossible reactive media and communication policy measures and regulatory
options available to policy-makers.

Media concentration in 2021: Little has changed in ten years
The MDM press release of 15 April 2021 on the status and impact of current
legacy media ownership concentration reports troubling conclusions regarding
the future of democracy in the 18 participating countries:

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The high level of media concentration, both at the national and the regional
and local level, is critically challenging news diversity. At the national level,
not a single country reports concentration levels below 0.40 (concentration
ratio), and in about one-third of the countries, competition appears weak, withvery few media conglomerates controlling the news media markets. Despite
earlier hopes and the vested optimism by some media companies, digitalisation has not delivered much to balancing media ownership concentration at
the regional and local level. (EMRG, 2021)

This conclusion does not come as a surprise, as media concentration findings
were similar in the 2011 MDM. At that time, commercial logic and pressures
were identified as main problems for contemporary news media and a threat tothe news media’s democratic functions (Trappel et al., 2011). In many countries,
globalisation of the media business together with deregulated media policies
exacerbated this development. New commercially oriented providers were successfully challenging national legacy media companies. The constant battle forreach and advertising revenues stimulated cheap journalism at the expense ofquality journalism. As a result, fact-based news journalism was superseded byattention-oriented journalism.
In addition, in 2011, there were signs that the balance of power within
media organisations was shifting, with business and market divisions gaining
influence on strategic decision-making processes. Media mergers and various
modes of cooperation between media companies reduced news diversity, andmedia power accumulated in the hands of a few business groups, especially at
the regional and local level. Structural changes in media markets were driven
by economic imperatives, and media policy-makers were either indifferent or
unsuccessful in their attempts to reduce undesired consequences for democracy.
In short, the 2011 MDM results can be summarised as follows:• strong commercial pressure on legacy media from within and from outside• high levels of media ownership concentration as a structural feature innational media landscape• media policy willingly and unwillingly endorsed high ownership concentration levels of national legacy media
Ten years later, in 2021, 18 countries participated in the MDM project, nine ofwhich were also part of the 2011 sample, allowing for longitudinal comparison(Trappel & Tomaz, 2021b). The other half of the sample participated for the
first time in 2021(Trappel & Tomaz, 2021c), and hence no comparison overtime is possible.
Before we discuss the MDM findings in detail, we account for the scholarly
debate on media ownership concentration in contemporary social sciences.

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JOSEF TRAPPEL & WERNER A. MEIERMedia ownership concentrationin contemporary social sciences
Parallel to the above-mentioned policy proceedings at the European Union level,
the issue of media ownership concentration turns out to be a lasting theme insocial science literature as well. Nonetheless, one would expect variations in thescientific debate, caused by media digitalisation on the one hand, and recurrent
crises affecting the media (from the financial crises in 2008, and again in 2018,
to the 2020–2021 Covid-19 pandemic), on the other.
Concentrated ownership characterises the media industries in many countries (Doyle, 2015), and the history of ownership concentration is long andcontentious. According to Noam (2016), concentrated media ownership is
one of those fundamental issues of power and wealth distribution that every
generation must resolve with its own means. Van den Bulck and colleagues(2016: 100) conclude the following:
In recent decades, the media sector […] has witnessed recurring waves ofcross-media concentration, and the consolidation of corporate power. […]Media mergers and acquisitions always ignite critical discussions by opinion
makers and academics, creating challenges for media-policy makers, regulators and competition authorities.

Private owners are primarily economic actors, pursuing economic profit, which
in turn governs day-to-day editorial work and marginalises less popular andconsequently expensive content (Korbiel & Sarikakis, 2017). Underproduction of content relevant to democracy can lead to market failure (Sjøvaag &Ohlsson, 2019). According to Doyle (2015), economies of scale is a prevalentcharacteristic of media industries, as are economies of scope. Furthermore,“enlarged, diversified and vertically integrated groups appear well suited to
exploit technological [innovation]” in media and communications (Doyle, 2015:299). Thus, a multiplatform distribution strategy that uses various formats andplatforms to share content allows further economies of scale and scope to bereaped (Doyle, 2015).
According to Doyle, highly concentrated firms that can take advantage ofwider product and geographic markets to spread out production costs standto benefit from natural economies of scale. Combined with high fixed costs
and low marginal costs, these economic characteristics naturally gravitate in
the direction of oligopoly and monopoly in the media industry (Doyle, 2015).
Market forces are unlikely to cope with this harmful dynamic.
Media ownership concentration “has been both a market reality and a publicconcern” (Iosifidis, 2014: 461). Therefore, as digitalisation enables a global
media market, questions about the consequences of media concentration forpluralism and diversity are being raised (Iosifidis, 2014). There are few industries

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whose ownership and control are more important than those of media, given
their central role in social, cultural, economic, and political life (Noam, 2016).
In the literature (among others, Meier, 2007), media ownership concentration threatens national democracy for the following reasons:• Media concentration is likely to diminish voices and to eliminate journalistic
and opinion diversity.
• Fewer corporate and public media limit competition in the field of investigative journalism.
• Corporate control commands editors to follow the media owner’s agenda,
rather than the public interest.
• Strong (conglomerate) media companies become powerful political actors
beyond democratic control.
• If economically or politically beneficial, concentrated media might decide toprovide one-sided political support, thereby influencing or even distorting
election results.
• “Concentrated media ownership creates the possibility of an individual
decision maker exercising enormous, unequal and hence undemocratic,largely unchecked, potentially irresponsive power” (Baker, 2007:16).
• Strong media ownership power increases the risk of corrupting politics
for mutual benefit.
• Strong (conglomerate) media companies manage to influence or evendetermine their own regulatory framework by influencing politicaldecision-making through editorial bias in their own corporate interest.
• Editorial and economic power of strong (conglomerate) media might
convert into political power (e.g., Silvio Berlusconi in Italy, Andrej Babišin Czechia).
• In case of conglomerate ownership, topics and issues affecting the strategicinterests of the owners are excluded from journalistic observation andscrutiny.
There are a few arguments in favour of media concentration as well:• Strong (conglomerate) media can raise and make available sufficient funds
for effective investigative journalism about political powerholders.
• Strong (conglomerate) media can withstand economic and political pressure and shield their newsrooms from undue interventions from outside.
Given this list of potentially harmful effects, media ownership concentration isconsidered to be antidemocratic: “It restricts [political and] cultural diversity[and] it undermines the ability of citizens to acquire and exchange the information and ideas necessary to take informed decisions about public life” (Freedman, 2014: 170). Moreover, “it further commodifies the cultural industries

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themselves, transforming them from vehicles of symbolic interaction to enginesof capital accumulation that foster the exploitation of creative labour” (Freedman, 2014: 170). Media pluralism is, in contrast, one of the pillars of a healthy
media environment and contributes to a well-functioning democratic system.
The new millennium has modified the rules of the “media monopoly”
game considerably. On the one hand, the digitalisation of the entire media
and communication environment – from news production along the value
chain to distribution and consumption of news – has not only transformed theincumbent media industry, but also enabled digital platforms to emerge on a
global scale. On the other hand, severe and frequent crises have disrupted thenews industry (Trappel et al., 2015). From bursting dot-com bubbles in 2001,
to the financial market crises in 2008 and 2018, to the Covid-19 pandemic in
2020–2021. Sjøvaag and Ohlsson (2019) point out that most of the critical
media concentration research occurred during the profitable years of media
business; thus, a revision under these new and precarious conditions of themedia and communication industry is required.

Digital platform concentration and democracy
Initially, the Internet provided high hopes for media pluralism, with the potential to create new players in the media and communication markets thatwould challenge powerful legacy media and create media freedom and diversityof opinion around the world, despite efforts by governments and global techplatforms to control the Internet. However, the Internet has proven to be partof the problem – a force for concentration – rather than part of the solution(Noam, 2014, 2016). Never has there been so much wealth created throughthe ownership of media. This wealth leads to various manoeuvres to perpetuate control, with such firms seeking market power through concentration or
regulatory protection (Noam 2016).
There are similarities and differences between legacy mass media and digitalcommunication platforms. Like legacy media institutions, digital platforms enable public communication, give voice to citizens, allow for the establishmentof many public spheres, and provide means for citizens to network on a large
variety of causes, but digital platforms usually do not produce news content
themselves. Rather, they exercise their extremely large influence to disseminate
all kinds of content (including, at times, mis- and disinformation). Under theshield of freedom of speech, digital platforms developed their dominant business model without much regulatory intervention: “The proliferation of dis/misinformation is symptomatic of an unregulated media monopoly governedsolely by profit imperatives” (Pickard, 2020: 126). While it took establishment
media decades to build up national oligopolies, digital platforms have operated

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as global oligopolies almost since their inception. They constitute global oligopolistic and anti-competitive monoliths, unprecedented in economic history.
With regard to the role that global digital communication platforms playfor democratic societies, digital platforms may do the following:• give and amplify voice indiscriminately to all kinds of groups, among
them undemocratic groups;• enable and amplify undesired and illegal content such as misogynistic andracist hate speech;• decide to take down content, thereby accepting the risk of over-blocking
legitimate content;• determine communication flows by non-transparent (confidential) algorithmic selection;• define communication rules on their platforms centrally and without
democratic control;• follow the platform owner’s agenda, not the public interest (see Kergueno,2021);• and transcend nationstates and operate globally, thereby exploiting andprofiting from weaknesses of democratic control and jurisdiction.
Furthermore, continuities from the mass media era to digital platforms become
visible with regard to the possibility of exercising enormous media and platform
power, the risk of corrupting politics, influencing political decision-making
through algorithmic selection, and algorithmic selection manipulating communication content in the owner’s strategic interests.
There are arguments in democratic favour of conglomerate digital platforms,
as they may give voice to people regardless of their status and power, and enable indiscriminate social networking among citizens regardless of time andspace. Thus, digital communication platforms largely reflect and replicate legacy
media power structures. In this respect, they are not fundamentally different,
but they represent additional and modified challenges to democracy comparedwith prevailing threats by legacy news media.

Trends in global media ownership concentration
To quantify the degree of ownership concentration, two measurements arecommonly used. First, the concentration ratio (CR) sums up the market shareof companies; thus, CR4 indicates the concentration ratio of the four largest
companies in the industry, with 0–40 per cent representing low concentration,
40–70 per cent representing medium concentration, and anything above 70
per cent representing high concentration. This method does not show the dif-

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ferences in market structure due to variations in company size that affect thelevel of competition. Second, the Herfindahl-Hirschman Index (HHI) provides
a more complete picture of concentration because it looks at the entire market
by summing the squares of the market shares of all players (Naldi & Flamini,2014). The concentration level based on the HHI is divided into three groups: An
index value of 0–1,500 represents an unconcentrated market; a value between
1,500–2,500 represents a moderately concentrated market; and a value above
2,500 is considered evidence of a highly concentrated market. Thus, the higher
the value of the HHI, the higher the owner concentration. Of course, even thislimited informative value is dependent upon comprehensive and precise industry
data. Methodological problems associated with the indices used in this chapter
are discussed in detail elsewhere (e.g., Pavic et al., 2016).
Based on country case studies and world statistics, Eli Noam (2016) analysed media ownership concentration around the world. Expressed in termsof the HHI, he found that the weighted world average for the overall media
sector has increased from 3,125 in 2004–2005 to a very high 3,253 in 2012.
For content media, the world average weighted HHI is lower at 2,219 (1,999
without Internet search engines and online news). The search engine industry
is the most concentrated among the media industries.
When it comes to news media, Noam found that concentration is very highin most countries, with a world average of 5,194 when measured by attention
time. Even without China, the HHI concentration scores at 3,089. On average,
the national pooled CR4 for the world is almost 60 per cent; thus, on average,
four companies control over half of national media industries combined, astrikingly high percentage largely based on the large size of platform media andtheir high concentration. According to Noam (2014, 2016), such high figurescharacterise oligopolistic markets.

Trends in national media ownership concentration
All nine countries participating in both the 2011 and 2021 MDM projects hadhigh ownership concentration rates in the traditional sectors of newspapers,
radio, and television in 2011 and 2021. In addition, all of the experts involved
reported growing ownership concentrations in the emerging online sector. Thereis no mention of a decline in any of the countries studied.
All 18 participating countries of the 2021 MDM project are in a similar
situation, with thirteen countries scoring 2 points and five countries only 1
point for indicator E1, regarding ownership concentration at the national level(Trappel & Tomaz, 2021c). In this respect, there are no differences between
larger countries (with more than 20 million inhabitants) and smaller ones (lessthan 20 million inhabitants).

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Against the backdrop of the previous scholarly debate on the ownershipconcentration of leading news media, a comparison of the 2011 and 2021 data
reveals a number of peculiarities, which are nonetheless discussed in the relevant
literature (see Trappel et al., 2011: 354–355; Trappel & Tomaz 2021c: 452–453).
In all nine countries, oligopolies still prevail in various legacy media, regardlessof the quantitative assessment made in the country reports. According to the
Dutch experts, the situation has clearly worsened: “Ownership concentration ona national level is remarkably high, with only five large media companies sharing
the market among them” (Vandenberghe & d’Haenens, 2021: 277).
In order to provide additional information to the assessments of the MDM
scholars, we compare the MDM findings with the study on the implementationof the revised Audiovisual Media Services Directive (AVMSD) by the European
Commission, carried out by Deloitte and SMIT (2021) on a set of 29 countries.
For our comparison, we chose a list of eleven countries covered by both the
MDM and the AVMSD studies (see Table 7.1). The comparison is limited to
television markets, as this has been the sole object of the AVMSD study.
Table 7.1 CR4 and HHI in the selected eleven countries

Country

CR4 2014(%)

CR4 2018(%)

HHI 2014

HHI 2018

Number of
regulations

Austria

78

74

2,183

2,009

5

Belgium

83

80

2,776

2,561

2

Denmark

89

94

2,631

3,061

0

Finland

88

86

3,066

2,049

1

Germany

87

86

2,035

1,978

7

Greece

62

57

1,405

1,390

8

Italy

81

78

2,717

2,375

5

Netherlands

76

72

2,163

2,004

1

Portugal

74

66

1,751

1,528

4

Sweden

92

94

2,461

2,659

0

UK

79

78

2,226

2,104

5

Source: Deloitte and SMIT, 2021

The AVMDS study investigated whether there is a correlation between the
degree of regulation and the degree of concentration. The researchers divided
the member states into four groups, based on the number of media ownership rules identified: 0 rules corresponds to a completely deregulated market;
between 1 and 3 rules represents a low level of regulation; between 4 and 6
rules is considered a medium level of regulation; and between 7 and 11 rules
is considered a high level of regulation.

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In a next step, the audience market shares for 2014 and 2018 have beenmatched with the degree of concentration of the television market for eachcountry, calculated as the concentration ratio for the four largest televisiongroups (CR4 and HHI).
Based on these indices, it can be seen that, with the exception of Denmarkand Sweden, all countries show slightly declining concentration values for thenational television market. Measured by CR4, all countries covered – except
Greece – have highly concentrated markets. According to the HHI in 2018,
only the television markets in Belgium, Denmark, and Sweden are highly concentrated, and only the television market in Greece is low. In contrast – but
including the print media market – the Greek MDM authors state that “thelevel of ownership concentration is dangerously high. The main reason for thisis the vulnerable media legislation, whose limitation on horizontal concentration in broadcast media and newspapers permits a specific modus operandi of
the market” (Papathanassopoulos et al., 2021: 199).
The AVMSD report focused empirically on the density of regulation and foundthat, from the selected eleven countries, Denmark and Sweden have no regulation
with regard to mergers and acquisitions in place, while Belgium, Finland, and theNetherlands have light regulation of the television market. Austria, Italia, Portugal, and the United Kingdom have a medium level of regulation. In the selected
eleven countries, only Germany and Greece appear to be highly regulated, withseven and eight different regulations, respectively. Of course, neither the existence nor the effectiveness of regulations is decisive for the extent of the measured
concentration. However, based on their full country selection, the authors of
the AVMSD study conclude they “can confirm that from a quantitative point ofview, there is a strong correlation between the two variables, so that the higher
the number of media ownership rules, the lower the market concentration levelbased on the HHI index score is” (Deloitte and SMIT, 2021: 181). Thus, using
the example of the Netherlands, it can be shown that deregulation – in 2011 allmedia and cross-media ownership restrictions were abolished – has not reduced
concentration, but rather promoted it (Papathanassopoulos et al., 2019).
Regulation or non-regulation of excessive ownership concentration is only
one of many factors that may influence the market result; country size, location, languages, GDP per capita, extent of public and government subsidies
for various media genres, and the business potential of the leading news media
may or may not play a role. After all, it is not enough to consider the number,but also the diversity of participants in the markets. In addition, the diversity ofreporting in the broadest sense is of central importance for democratic politicaldecision-making processes. The MDM research project seems to confirm that
democratic political quality cannot be maintained solely by imposing competition policy, but it must be approached more holistically, taking into accountrecent developments in platform media.

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The television markets of the Nordic countries are among the most concentrated in Europe, as the figures based on the HHI index and CR4 showedin Table 7.1. On the one hand, the Nordic countries have a liberal economic
orientation and show deregulated markets, while at the same time, they try tostabilise public broadcasting – which has long been institutionalised – and toanchor it in society. For example, public broadcasters are the largest playerswith the highest audience market shares: Swedish SVT has a 35 per cent market
share; Finnish Yle has 44 per cent; and Danish TV2 and DR have a combined
76 per cent (Deloitte and SMIT, 2021).
The situation is somewhat different in the smaller countries and markets incontinental Europe. In the Netherlands, for example, public and commercial
broadcasting coexist, as the state and the media authority play an active policy
role. The CR4 is high, with an audience market share of 72 per cent and amedian HHI of 2,004. Here, too, the public broadcaster NPO has the highest
national audience market share (32%), followed by the German Bertelsmann
Group (RTL station) (21%), and media groups from the US (12%). In contrast
to the Nordics, foreign television groups have a strong presence in terms ofaudience reach.
In 2007, the existing Dutch rules were relaxed and the maximum concentration was set at very high levels, primarily to allow domestic media companies
to grow and operate in foreign markets. As of 2011, rules were completely
abolished and regulation was left to the leading corporations themselves. Instead, the competent authority started its annual monitoring (see van Dreunen,2016). However, systematic monitoring could not prevent the newspaper market
from being controlled by two foreign corporations as a result of the removalof ownership limits. The radio market suffered a similar fate.
In 2017, the Dutch media company Talpa Media acquired three major television stations, while also owning four major radio stations and the nation’slargest press agency, ANP. In competition with large international corporations,the domestic media industry has grown in the Netherlands, but the market ishighly concentrated, and liberalisation has led to ownership concentrations
across media. The extent to which this leads to a journalistic and democratic
deficit in terms of diversity and pluralism is likely to be far more difficult tomonitor than the few media owners.
Not only in the Netherlands, but also in other states or regions with largeneighbours speaking the same language, such as Austria, Ireland, Luxembourg,
Switzerland, or Wallonia, foreign media groups play a major role. These smaller
countries generally only have a few domestic broadcasters and publishers, however, with high reach and audience shares for their products and programmes.
The sectoral concentration figures are correspondingly high. At the same time,
linguistic proximity leads to widespread overspill, and the presence of foreign
stations is not only competition, but also part of a welcome quality offer. For

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example, the German-speaking populations in Austria, Belgium, and Switzerland
benefit from public and commercial broadcasting services from Germany, andthe French-speaking populations in Belgium, Switzerland, and Italy from those in
France. At the same time, the authorities in these regions are motivated to keep
the local media industry alive (e.g., with public and state support measures) inorder to ensure a minimum of local diversity. This balancing act is necessary,
because commercial as well as public broadcasters from France and Germany areneither mandated, nor interested in, nor willing to provide journalistic services
for the benefit of the democratic political decision-making processes in theirneighbouring countries. In any case, the data show that foreign groups havelarger shares in smaller television markets than in larger markets. This can be
exemplified by the case of Austria (Grünangerl et al., 2021).
Austria has a high concentration: 74 per cent in CR4 and an HHI of 2,009
in 2018. Austria does have restrictions to prevent horizontal and cross-media
concentration, but the merger of the two largest private television stations, ATV
and PULS 4, nevertheless took place and increased ownership concentration.
In terms of audience share, this group is the second-largest broadcaster after
the dominant public broadcaster ORF (see Seethaler & Beaufort, 2020). The
antitrust law regarding media diversity and media pluralism did not prohibit
the merger. Thus, the four largest players in the German market are also among
the five largest broadcasters in Austria, with an audience market share of 47
per cent.
Greece has a comparatively highly regulated media market with clearly
defined thresholds to prevent horizontal and cross-media concentration. The
Greek state owns and covertly regulates the media to a large extent. As a covert
regulator, it seeks to control and limit the power and influence of the media inpolitics (Deloitte and SMIT, 2021). From this perspective, it is hardly surprisingthat the public (state) broadcaster ERT has a market share of only 9 per cent.
The four leading groups are domestic private-commercial television groups,
which claim an audience share of 57 per cent, a medium level of concentration.
The HHI of 1,390, on the other hand, indicates a low level of concentration(see also Papathanassopoulos et al., 2021).
The large European countries of Germany, Italy, and the United Kingdom
have high CR4 figures for television broadcasters. In these countries, too,governments promote their leading domestic companies so they can position
themselves nationally and globally.
The United Kingdom corresponds to the liberal model, which is characterised by the dominance of largely unregulated commercial media – some withperformance mandates. The British market is dominated by nationally based
operators, with the three largest players accounting for 69 per cent of total audience market share, followed by US-based groups Comcast, Viacom, Discovery,
Walt Disney Company, and Warner Media (AT&T), which together account for158

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20 per cent of the audience market share (Deloitte and SMIT, 2021). Despite all
media-specific rules and bodies, the United Kingdom shows a concentration of
78 per cent among the four largest companies and an HHI of 2,104 (see also
Moore & Ramsay, 2021).
In Germany, 86 per cent of the audience share is concentrated among the fourlargest companies, and the HHI is just under 2,000 (a medium concentration).
Also in Germany, the public broadcasters achieve the highest audience market
share of 48 per cent, making the German public broadcasters the second-largest
in terms of audience market share after Denmark. The private-commercial
company Bertelsmann, which is active in ten European Union member states,
and ranks second in Germany (RTL Group) with an audience share of 21 percent on the domestic market, is the only European company to achieve a higher
audience market share abroad than at home (Horz-Ishak & Thomass, 2021).
Finally, Italy has a law to limit cross-media sector ownership. Nevertheless,according to the CR4, the Italian television market is highly concentrated (78per cent). The public broadcaster RAI and the commercial Mediaset group forma strong duopoly with an audience reach of 66 per cent (Padovani et al., 2021).
Over and above this number-crunching of market shares, CR4, and HHI
measures, structural reasons for why ownership concentration is prevalent inthese countries should not be ignored or forgotten. Differences in the measurement of ownership concentration also arise due to the choice of methodology,
and because of multilayered factors that come into play to a greater or lesser
extent in individual countries. It is, however, clear that whatever measurement
is used, media ownership concentration has undesired effects for the economy,
journalism, competition, and democracy. Both media policy and communication studies are all too often content with quantitative measurement, insteadof asking about the current forms, reasons, and consequences of ownershipconcentration. Thus, we should not stop at describing the indices, but should
contextualise the quantitative results.

Media ownership regulation
There are no European-wide ownership rules in place to counter harmful media
ownership concentration: “Each member state has treated the issue separately,
mostly with a deregulatory trend” (Iosifidis, 2014: 468). The reasons for
dismantling or abolishing ownership regulations include concerns about thecompetitiveness of domestic media providers. The deregulation trend in Europe
favours the mitigation or reduction of existing regulations (Arnold, 2014).
This regulatory absence “has left a few large communications conglomerates
unhindered to expand their activities across the Continent” (Iosifidis, 2014:468). According to Doyle (2015), an economic “crisis” in newspaper publishing

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has resulted in many publishers calling for the deregulation of cross-ownership
restrictions, claiming that they impede the sector’s ability to adapt to changing
market conditions.
However, multiplatform expansion is no guarantee of greater diversity ofcontent or editorial pluralism, and increasing Internet use poses complex challenges for policy-makers (Doyle, 2015). According to Doyle (2015: 304), “therise of search and intermediation have introduced powerful new players”. Because of economic characteristics, such as economies of scale, high fixed costs
and low marginal costs, and customer lock-in and switching costs, network
effects are widespread in search engines; thus, the “industry is highly prone tomonopolization” (Doyle, 2015: 304).
The business design of search engines to use algorithms to direct alreadypopular content to audiences is obviously a threat to diversity. And for smaller
countries and minority languages, this information selection practice is potentially more harmful than for larger states: “Google’s dominance across theglobe creates many possibilities for abuses of gateway monopoly power andof market power” (Doyle, 2015: 304).
In addition, “the question of how to regulate ownership of media is always
a site for controversy” (Doyle, 2015: 297). Despite consistent support from theEuropean Parliament for legislative intervention to protect media pluralism,
the member states’ diverse approaches to protecting media pluralism, and theireconomic and cultural differences, will likely prevent the EU from harmonising
media ownership rules in the foreseeable future (Craufurd Smith, 2013).
So far, however, the European Union’s media policy can be regarded as a“lever to promote market liberalization that would nurture European champions” (Iosifidis, 2014: 463). In Europe, technological advances have allowed aproliferation of communication channels and modes of content delivery, whichchallenge the rationale for strict regulation. The European Commission, withthe goal of competing globally, has allowed the formation of large European
corporations (Iosifidis, 2014).
Observers point out that the European Commission has been neither willing nor able to achieve pan-European solutions, and there has been no interest
among European decision-makers to raise the issue. A clear policy is lacking,and the European Union has been unsuccessful in implementing a harmonised
framework of media ownership to guarantee the public’s right to know who
owns the media (Korbiel & Sarikakis, 2017).
Lately, however, there are indications that the European Union is seeking toplay an enhanced monitoring role in the future (Craufurd Smith et al., 2021).
While the European Commission’s Action Plan, “Europe’s Media in the Digital
Decade” (2020a), does not mention media ownership concentration as an issue, the Action Plan “On the European Democracy”, released on the same day,stipulates that “transparency of media ownership is essential for assessing the160

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plurality of media markets” (European Commission, 2020b: 16). Furthermore,
the European Commission announced the effort to improve the public availability of media ownership information by co-financing a pilot project to establish
a media ownership monitor, prone to be expanded to cover all member states(European Commission 2020b).
In addition to monitoring ownership, governments might consider enacting policy tools in order to ensure pluralism of ownership and content beyond
simply curbing clear misuses, for instance, by encouraging alternative media,
protecting access, and promoting interconnection. Not only governments,
but also academics, public-policy analysts, NGOs, and media and platform
companies must be creative when determining new approaches to these issues,balancing the public interest, technological innovation, and financial investment(Noam, 2014, 2016). According to Iosifidis (2014: 472), “the role of content
regulation remains crucial in the converged media age. […] Such rules should
aim increasingly at ensuring that public interest content reaches users in themultichannel era”. In addition, “a more mixed media system with different
mandates as well as different modes of ownership and financing is necessary”(Picard & Dal Zotto, 2015: 63; see also Picard & Pickard, 2017).

Conclusions
The emergence and dominance of highly concentrated platform companies has
pushed the problems stemming from ownership concentration in the legacy
media sector into the background. Over the past 30 years, despite all economic
and political ownership regulations and transparency demands, media policies
in the European Union and in individual European countries have not succeeded
in dismantling oligopolistic media structures that are harmful to democracy.
On the contrary, challenged by digital platforms, national governments seek toprotect and promote their legacy media without obliging them to refrain frompotentially undemocratic business models and practices.
This structure-preserving media policy ties up many public resources andaverts the sustainable transformation of legacy media and enlightened journalism
into a platform-dominant environment (see KEA, 2021). In an attempt to replicate the practices of the “big five” global communication companies (GAFAM),
successful legacy media companies appear to prefer investing in profitable digitale-ventures rather than loss-making journalism. Such a digital strategy may besuccessful from an entrepreneurial point of view, but democratic, diverse, andpower-critical information for the public is lost along the way. Politically andeconomically captured that way, media companies are at risk of losing theirautonomy and being used by vested interests (see Schiffrin, 2017).

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