Monitoring media pluralism in Europe : application of the media pluralism monitor 2016 in the European Union, Montenegro and Turkey.
Date: 2017-12-18
Institutions: Robert Schuman Centre for Advanced Studies
Subjects: European Union, Türkiye, United Kingdom, access to information, communications policy, communications profession, freedom of communication, freedom of the press, legislation, mass media, pluralism in the media, press, report, right to information

Monitoring Media 
Pluralism in Europe: 
Application of the 
Media Pluralism Monitor 2016 in 
the European Union, Montenegro 
and Turkey

2017 Policy Report 

Centre for Media Pluralism and Media Freedom

 
© 2017, European University Institute

Authors: Elda Brogi, Konstantina Bania, Iva Nenadic, Alina Ostling, Pier Luigi Parcu. The Authors thank Lorenzo 
Giuntini for creating the online platform for data collection, Giorgio Giamberini for the info-graphics, Maria Karidi 
and Mario Viola de Azevedo Cunha for the support in the final revision of the report, Gianni Betti for advice on the 
methodology, Peggy Valcke and Beata Klimkiewicz for the peer-review. The Authors wish to thank also the Country 
Teams who carried out the data collection for each country. As in past years, their work and passion were essential 
for the success of the project.

This text may be downloaded only for personal research purposes. Any additional reproduction for other purposes, 
whether in hard copies or electronically, requires the consent of the European University Institute. If cited or quoted, 
reference should be made to the full name of the author(s), editor(s), the title, the year and the publisher.

Views expressed in this publication reflect the opinion of individual authors and not those of the European University 
Institute or the European Commission

 
TABLE OF CONTENTS

Executive Summary  

Introduction 

1.Results 

1.1 Analysis of Basic Protection 

Protection of freedom of expression 

Protection of the right to information 

Journalistic profession, standards and protection 

Independence and effectiveness of the media authority 

Universal reach of traditional media and access  
to the Internet 

1.2 Analysis of Market Plurality 

Transparency of media ownership 

Horizontal concentration of media ownership 

Cross-media concentration of ownership and competition  
enforcement 

Commercial and owner influence over editorial content 

Media viability 

1.3 Analysis of Political Independence 

Political control over media outlets 

Editorial autonomy 

Media and democratic electoral process 

State regulation of resources and support to media sector 

Independence of PSM governance and funding 

1.4 Analysis of Social Inclusiveness 

Access to media for minorities 

Access to media for local/regional communities and  
community media 

1

5

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25

27

29

32

34

36

38

40

43

45

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51

52

55

Access to media for people with disabilities 

Access to media for women 

Media literacy 

1.5 Conclusions 

2. Methodology. The research design 

2.1 MPM2016 structure and calibration 

MPM2016 aggregation method 

2.2 Data collection 

The questionnaire 

Group of experts’ procedure 

2.3 Improvements from MPM2015 

Digital indicators 

Update of the user guide and enhancement of the 
 online platform 

2.4 Changes introduced per area 

Basic Protection area 

Market Plurality area 

Political Independence area 

Social Inclusiveness area 

References 

Annexe I. Minority definition used by the MPM2016 

Annexe II.  Conclusions from the workshop with  
media literacy experts in Florence 

Annex III Notes on the feasibility of the Media  
Pluralism Monitor 

Annex IV MPM2016 User guide 

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EXECUTIVE SUMMARY

This report presents the results and the methodology of the 2016 implementation of the Media Pluralism Monitor 
(MPM) in EU-28 countries and in Montenegro and Turkey (MPM2016).

The MPM is a tool that has been developed by the Centre for Media Pluralism and Media Freedom (CMPF) at the 
European University Institute to assess the risks to media pluralism in a given country. The MPM project is co-funded 
by the European Union. Prior to the 2016 implementation, the tool was tested under two pilot-projects that were co-
funded by the European Union in 2014 and 2015 (CMPF 2015; CMPF 2016). These two pilot-test implementations 
built on the prototype of the MPM that was designed in the 2009 Independent Study on Indicators for Media Pluralism 
in the Member States – Towards a Risk-Based Approach carried out by KU Leuven, JIBS, CEU, Ernst&Young, and a 
team of national experts (KU Leuven, 2009).

The Monitor assesses the risks to media pluralism based on a set of twenty indicators covering a broad notion of media 
pluralism that encompasses political, cultural, geographical, structural and content related dimensions1. All types of 
media are covered: public service, commercial, community media, new media and online platforms. The risks for 
media pluralism are measured in four different areas: Basic Protection, Market Plurality, Political Independence and 
Social Inclusiveness. The indicators cover legal, economic and socio-political questions. National experts, composing 
the MPM network of local teams, provided the data to assess the levels of risk at country level, drafted the country 
reports, while the CMPF supervised and guaranteed quality and consistency of the data collection and assessed the 
levels of risk. CMPF also directly implemented the MPM in Italy and Malta.

The  assessment  of  the  risk  to  media  pluralism  in  a  given  country  by  the  MPM  does  not  necessarily  represent  an 
effective lack of pluralism in a given context. The results, the data collected and the analysis provide useful information 
for policymakers, researchers, and civil society so as to better understand the threats to media pluralism in different 
media contexts and to plan relevant media policy or advocacy measures, where needed.

The results of the MPM implementation are presented according to three categories of risk: low, medium or high. The 
subsequent paragraphs provide a short description and the main results per area.

1 
publications.europa.eu/en/publication-detail/-/publication/4c7c6eb5-fb51-40f4-9125-33ef824e685b/language-en 

 Commission staff working document - Media pluralism in the Member States of the European Union /* SEC/2007/0032 */ , https://

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CENTRE FOR MEDIA PLURALISM AND MEDIA FREEDOM - Executive Summary

SUMMARY RESULTS

Figure 1- Basic Protection area

The  area  of  Basic  Protection  includes  the  assessment  of  the  fundamental  elements  of  any  plural  and  democratic 
society,  namely  the  existence  and  effectiveness  of  the  implementation  of  regulatory  safeguards  for  the  freedom  of 
expression and the right to information; the status of journalists in each country; the independence and effectiveness 
of the media authority; the universal reach of traditional media and access to the Internet.

The  results  for  the  Basic  Protection  area  show  that  18  countries  score  a  low  risk  (Denmark,  Germany,  Sweden, 
Netherlands,  Belgium,  Portugal,  the  United  Kingdom,  Finland,  the  Czech  Republic,  Lithuania,  Estonia,  France, 
Slovakia, Malta, Cyprus, Ireland, Italy, Slovenia), 11 countries score a medium risk (Romania, Greece, Croatia, Spain, 
Bulgaria, Luxembourg, Montenegro, Austria, Poland, Latvia, Hungary) and one country (Turkey) scores a high risk.

Most of the countries considered by the MPM2016 fulfil the basic protection conditions for a plural and democratic 
media  environment.  Nonetheless,  the  analysis  confirms  that  most  of  the  countries  under  scrutiny  present  some 
shortcomings in the area of Basic Protection. Being Basic Protection the area that comprises the main foundations 
for freedom of expression and media pluralism   any problems in this area affect the analysis and the levels of media 
freedom and media pluralism in other risk areas in different country contexts.

The data collection shows surprising deficits in core elements of democratic media systems, beginning from the very 
fundamental Protection of freedom of expression. Within the EU member states, 25 countries score low risk, while 
Hungary, Latvia, Poland, and Romania score a medium risk in the assessment of the key indicator on Protection of 
freedom of expression, reporting poor implementation of international standards in that regard. The indicator on 
the Journalistic profession, standards and protection confirms the trend from MPM2015 (CMPF, 2016), scoring an 
average low risk across the countries that is very close to the medium risk threshold. The trends are slightly more 
positive as regards the Protection of right to information.  Media authorities, in general, are assessed positively, even 
if their appointment procedures and composition are commonly influenced by politics. The highest risk in the area 
comes from the indicator on Universal reach of traditional media and access to the Internet: the level of risk is due to 
the high standards required in these indicators.

Turkey is the only country that scores overall a high risk for the area of Basic Protection, being the country that, 
in comparison with the other countries, shows the highest risks in three out of five indicators of the area, namely 
Protection  of  freedom  of  expression,  Journalistic  profession,  standards  and  protection  and  Independence  and 
effectiveness of the media authority.

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CENTRE FOR MEDIA PLURALISM AND MEDIA FREEDOM - Executive Summary

Figure 2 - Market Plurality area

The  Market  Plurality  area  assesses  the  risks  to  media  pluralism  that  arise  from  the  level  of  transparency  and 
concentration of media ownership, commercial and owner influence over editorial content, and from the economic 
conditions in which the media operate. 

Based on the data collection conducted by the country teams, the vast majority of the countries under consideration 
score a medium risk (25). Two countries, namely Bulgaria and Luxembourg, score a high risk and only three countries, 
Germany, France and Portugal, score a low risk. In general, Market Plurality indicators show the highest levels of risks 
amongst all the four areas of the Monitor. Media ownership concentration (horizontal) is the only indicator of the 
MPM2016 that performs overall in a high risk band, with no country scoring a low risk in this regard. Commercial 
and owner influence over editorial content is also a matter of concern for many EU countries and for the two EU 
candidates  under  consideration.  It  is  one  of  the  highest  percentage  scoring  indicator  in  the  entire  Monitor  (58%) 
remaining however still in a medium risk band.

Figure 3 - Political Independence area

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CENTRE FOR MEDIA PLURALISM AND MEDIA FREEDOM - Executive Summary

The Political Independence area is assessed using indicators that evaluate the extent of the politicisation of the media 
system, media organizations, newsrooms, media reporting and the public service media. The comparative analysis 
of the risks reveals that a vast majority of the countries examined scored a medium risk (18), eight are at low risk 
(Sweden, France, Germany, Portugal, Belgium, Denmark, the Netherlands, and the United Kingdom), and four are at 
high risk when it comes to political influences over different dimensions of their media operations - two of which are 
EU member states (Hungary and Slovenia), and two candidate countries (Montenegro and Turkey).

Hungary is the only EU country that scores high risks for all five indicators in this area, with most concerns being 
related to the allocation of state subsidies and advertising, and independence of PSM governance and funding. For 
the two candidate countries, Montenegro and Turkey, the political capture of the media represents a strong burden 
on their way to ensure more independence and media freedom as an essential precondition of a healthy democracy. 
Particularly at risk are media and journalists in Turkey as regards editorial autonomy vis à vis political power. The 
government there already had a record of censoring, embittered after the attempted military coup in July 2016 when 
the state of emergency was declared. In general, for most countries, the lack of editorial autonomy and political control 
over media outlets are of most concern. These two indicators result in one of the highest risk percentages (57%) of the 
entire 2016 Monitor. 

Figure 4 - Social Inclusiveness area 

The Social Inclusiveness area examines access to media by various social and cultural groups, such as minorities, 
local/regional communities, people with disabilities and women. Access of different groups to media is a key aspect of 
a participatory media system and a core element of media pluralism. In addition, the Monitor considers media literacy 
to be a precondition for using media effectively, and examines media literacy contexts across countries, as well as the 
digital skills of the overall population. 

In the area of Social Inclusiveness, two thirds of the countries (21) are in the medium risk band. Three countries 
score a high risk (Greece, Latvia and Turkey) and six countries a low risk (Belgium, Denmark, France, Netherlands, 
Sweden and the United Kingdom). The indicator on access to media for people with disabilities shows the lowest risk 
(37%) but it still ranks as a medium risk since support services for people with hearing and visual impairments are 
either non-existent or limited in the majority of countries. The highest risk scores are related to access to media for 
minorities and for women (54% respectively). None of the countries scored low risk on the representation of women 
as subjects and sources in news (both on- and offline), which indicates that women might be heavily underrepresented 
in the media across Europe. 

The  results  of  the  MPM2016  implementation  confirm  again,  as  a  general  trend  and  in  line  with  MPM2015  and 
MPM2014, that no EU country is immune from risks that are related to media freedom and pluralism.

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INTRODUCTION

Freedom  of  expression  and  freedom  and  pluralism  of  the  media  are  fundamental  rights  and  principles  that  are 
enshrined in the Charter of Fundamental Rights of the European Union.2 The protection and promotion of pluralism 
and the freedom of the media are essential to guarantee a democratic environment for all EU citizens, and for the 
legitimacy of the Union as a whole. Free media and the plurality of voices constitute the foundations of any healthy 
democratic society: they are indispensable conditions with which to guarantee that individuals have access to a variety 
of information and may form their opinions by taking into account different perspectives and views. The growing 
role of the Internet and in particular of the social media in disseminating content of public interest allows for broader 
participation in the communication and information exchange.

In Europe, democratic discourse is challenged by populism and radicalisation of public communication that has been 
fuelled by the migrant crisis and economic hardship. In the June 2016 referendum, the United Kingdom voted to leave 
the European Union. This has prompted a public discussion on the role of media in fostering a well-informed debate 
and a decision making process through the provision of full, high-quality and impartial information for the benefit 
of citizens and the democratic system. The international scenario offers even darker perspectives, as propaganda and 
misinformation are heavily impacting upon the public debate and political decisions. 

Whereas  new  technologies  have  dramatically  contributed  to  the  easy  and  effective  spreading  of  content  and 
information to wider audiences, the way information is distributed online by internet content intermediaries may 
accentuate polarisation (the ‘filter bubble’) in which a person is exposed to news, sources and ideas that adhere to 
his/her  expressed  preferences.  This  can  significantly  undermine  the  potential  to  encounter  and  debate  opposing 
viewpoints, and, as such, may pose a risk to media pluralism and to democracy itself. 

The European Commission’s Annual Colloquium on Fundamental Rights, held in November 2016, set a focus on 
“Media Pluralism and Democracy”. One of the key actions, drawn from the discussions that involved policy makers, 
regulators, media actors, journalists, academics and civil society organisations, is to promote a healthy political debate 
and engagement through media literacy, media ethics and media pluralism. The colloquium was informed by the 
results of a special Eurobarometer survey on media pluralism and democracy (Special Eurobarometer 452, 2016). 
Albeit that there are variations among the countries, overall, only a minority of respondents to the survey state that 
their national media provide information that is free from political or commercial pressure; the vast majority is not 
aware of the body that oversees audiovisual media in their country; radio is perceived as being the most reliable media 
(for 66% of respondents); and three quarters of social media users have experienced abuse, hate speech or threats, 
which then makes them hesitant to further engage in online debates.

The  Centre  for  Media  Pluralism  and  Media  Freedom  (CMPF)  at  the  European  University  Institute  is  regularly 
monitoring the state of play of media freedom and media pluralism since 2013, when  the European Union assigned to 
the Centre itself a grant to update, simplify and implement the Media Pluralism Monitor (MPM), initially developed 
in 2009 by an international consortium, at the request of the European Commission (KU Leuven, 2009). The CMPF 
updated the indicators proposed in 2009 in the light of the growing importance of the Internet. Furthermore, the 
scope  and  definition  of  media  pluralism  was  revised,  and  the  indicators  were  improved  in  terms  of  feasibility  by 
refining the methodology and the data collection approach. The number of indicators was radically reduced. In 2014, 

2 

 Please note that the Charter applies to Member States only when they are implementing EU law.

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CENTRE FOR MEDIA PLURALISM AND MEDIA FREEDOM - Introduction

the CMPF conducted a first pilot implementation of the Monitor in a sample of nine EU countries3. In 2015, the 
Monitor was further refined and the second pilot was carried out in 19 countries4. 

In 2016 the Media Pluralism Monitor was implemented for the first time in all 28 EU member states and in two candidate 
countries,  namely  Montenegro  and  Turkey.  The  Monitor  is  now  a  comprehensive  and  balanced  tool  for  assessing 
risks for media pluralism, composed of 200 variables organized within 20 main indicators and, finally, structured in 
four thematic areas, encompassing pertinent legal, economic, political and socio-cultural considerations, being so a 
“holistic” tool. In order to be more reliable and have high level of validity, the MPM relies on both quantitative and 
qualitative indicators.

The research design of the Monitor is based on a sophisticated questionnaire that was completed following a common 
and rigorous methodology by national country teams that were made up of experts in media pluralism and media 
freedom. A second group of experts, including national stakeholders and experts in the area, conducted a review of 
the answers that required a qualitative type of measurement and/or that lacked measurable and easily verifiable data. 

In order to ensure the comparability of the answers and the consistency of their quality, the CMPF centrally monitored 
the  data  collection  and  raised  questions  in  cases  where  inconsistent  or  incomplete  answers  were  provided  by  the 
country teams. This proved to be essential in a cross-national study of this size and type.

As mentioned above, the MPM 2016 assessed the risks to media pluralism by considering four areas of risk:

•  Basic Protection

•  Market Plurality

•  Political Independence

• 

Social Inclusiveness

and by taking into account 20 indicators.

Figure 5. List of indicators per area

BASIC PROTECTION

MARKET PLURALITY

Protection of freedom of 
expression

Transparency of media 
ownership

Protection of right to  
information

Media ownership  
concentration (horizontal)

POLITICAL  
INDEPENDENCE

Political control over  
media outlets

Editorial autonomy

SOCIAL  
INCLUSIVENESS

Access to media for  
minorities

Access to media for local/
regional communities and 
for community media

Journalistic profession, 
standards and protection

Independence and 
effectiveness of the media 
authority

Universal reach of tradition-
al media and access to the 
Internet

Cross-media concentration of 
ownership and  
competition enforcement

Commercial & owner  
influence over editorial 
content

Media viability

Media and democratic 
electoral process

Access to media for  
people with disabilities

State regulation of  
resources and support to 
media sector

Independence of PSM gov-
ernance and funding

Access to media for women

Media literacy

The implementation of the MPM in the European Union and Montenegro and Turkey confirms the provisional trends 
of  the  pilot  implementations  in  2014  and  2015,  showing  that  no  country  (EU  member  states  and  two  candidate 
countries), is free from risks to media pluralism.

This policy report analyses the results of the 2016 implementation from a comparative perspective (see part 1), and 
it describes in detail the methodology employed (see part 2). The risks to media pluralism are examined, taking into 
account the four areas that capture the main dimensions of risk for media pluralism and media freedom. Each area 
consists of five indicators which are the result of an articulated construction and combination of sub-indicators and 
elementary variables. 

3 
4 
Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden

 Belgium, Bulgaria, Denmark, Estonia, France, Greece, Hungary, Italy and the UK
 Austria, Croatia, Cyprus, the Czech Republic, Finland, Germany, Ireland, Latvia, Lithuania, Luxembourg, Malta, the Netherlands, 

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CENTRE FOR MEDIA PLURALISM AND MEDIA FREEDOM - Introduction

1. RESULTS 

1.1 ANALYSIS OF BASIC  
PROTECTION

The indicators that fall under the area of Basic Protection are designed to describe and measure the elements that 
are essential conditions for a pluralistic and democratic society. The first and fundamental component of the area is 
the level of Protection of freedom of expression, a very basic prerequisite for a functioning democracy. Freedom of 
expression is necessary for individual dignity and fulfilment and “constitutes [an] essential foundation for democracy, 
rule of law, peace, stability, sustainable inclusive development and participation in public affairs”5. 

Along with freedom of expression, and stemming from it, the right to access information is another fundamental 
ingredient  of  democracy.  It  is  of  the  utmost  importance  that  effective  transparency  of  public  administrations  is 
guaranteed and information in the public interest is circulated to feed the political debate and, in the end, democracy. 
Whether it is important that freedom of expression and freedom of information are effectively safeguarded, a free and 
plural media environment must rely on free journalism. This means that access to the journalistic profession should 
be open, that journalists should be able to rely on decent working conditions and should be able to work without 
constraints.  An  “enabling  environment”6  allowing  journalists  and  other  media  actors  to  freely  express  themselves 
without fear, even when their opinions are contrary to those held by the authorities or by a significant section of public 
opinion, should be guaranteed by member states. The MPM therefore considers safety of journalists, both physical 
and digital, as a parameter to assess whether the basic conditions for a plural media environment are fulfilled.

Impartiality of the institutions that oversee the media market is another basic element for a plural media environment. 
Therefore,  independence  of  media  authorities  is  of  paramount  importance  when  implementing  media  specific 
regulation and media policy, as the shape of the market has a direct impact on market plurality.

Finally, the Basic Protection area includes an assessment of universal reach of traditional media and access to the 
Internet. These are conditions that contribute to assessing whether citizens have, or at least potentially have, access to 
a wide variety of content.

The indicators and sub-indicators under Basic Protection are assessed by combining both legal and socio-economic 
variables. In particular, the indicators aim to capture risks in relation to specific legal standards, by measuring both 
the existence of legislation in a given area and its implementation. In addition to this, the Monitor assesses what the 
effective socio-political conditions that practically affect the specific area of investigation are.

Summarising, the five indicators under Basic Protection are:

•  Protection of freedom of expression

•  Protection of right to information

• 

• 

Journalistic profession, standards and protection

Independence and effectiveness of the media authority

•  Universal reach of traditional media and access to the Internet

 Council EU, EU Human Rights Guidelines on Freedom of Expression Online and Offline, 12 May 2014, http://www.consilium.euro-

5 
pa.eu/uedocs/cms_data/docs/pressdata/EN/foraff/142549.pdf. 
6 
 ECtHR, case Dink v. Turkey, 2668/07, 6102/08, 30079/08, 7072/09 et 7124/09, Judgment on September 14, 2010. See also Council 
of Europe, Committee of Ministers, Recommendation CM/Rec(2016)4 of the Committee of Ministers to member States on the protection of 
journalism and safety of journalists and other media actors,  https://search.coe.int/cm/Pages/result_details.aspx?ObjectId=09000016806415d9 

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CENTRE FOR MEDIA PLURALISM AND MEDIA FREEDOM - Results

Figure 1.1.1. Basic Protection area - Map of risks per country

The results for the Basic Protection area show that eighteen countries score a low risk (Denmark, Germany, Sweden, 
Netherlands,  Belgium,  Portugal,  the  United  Kingdom,  Finland,  the  Czech  Republic,  Lithuania,  Estonia,  France, 
Slovakia, Malta, Cyprus, Ireland, Italy, Slovenia), eleven countries score a medium risk (Romania, Greece, Croatia, 
Spain, Bulgaria, Luxembourg, Montenegro, Austria, Poland, Latvia, Hungary) and one country (Turkey) scores a high 
risk. 

Most  of  the  countries  considered  by  the  MPM2016  fulfil  the  basic  conditions  for  a  plural  and  democratic  media 
environment. Nonetheless, it must be noted that some countries, in comparison with previous rounds of the (pilot) 
implementation of the Media Pluralism Monitor (CMPF, 2016) score higher risks in this very fundamental area. In 
particular, Croatia, Latvia, Luxembourg, Poland and Spain, at low risk in 2015, receive a medium score in 2016. While 
this is partially due to the different combination of indicators from the previous MPMs, it must be noted that, in 
some countries, the data collection clearly confirms or shows a trend towards a deterioration in the core elements of 
democratic media systems, starting from the very fundamental Protection of freedom of expression and the respect 
of the rule of law. For instance, within the EU countries, Hungary, Latvia, Poland, and Romania score a medium risk 
in the indicator on Protection of freedom of expression, indicating poor implementation of international standards 
in that regard, in particular when it comes to proportionate balance between protection of freedom of expression and 
dignity and, in some cases, respect of rule of law as regards freedom of expression online. Even countries that score a 
high percentage within the low risk band can be seen as being somehow at risk, considering that the Basic Protection 
area deals with fundamental elements of a sound democratic media system. Such is the case, for instance, with Italy, 
which scores 32%, which lies at the upper limit of the low risk band.

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Figure 1.1.2. Basic Protection area - Averages per indicator 

As general remarks, from the data analysis of the MPM2016 it is possible to assess a positive trend in relation to the 
indicator on Protection of right to information, which scores low risk in 25 countries out of 30 (with the exception of 
Bulgaria, Hungary, Turkey (medium), Austria and Luxembourg (high)) and as regards the indicator on Independence 
and effectiveness of the media authority that scores low risk in 24 countries (five countries score medium risk, namely 
Latvia, Spain, Hungary, Slovenia and one high, Turkey).

The  indicators  that  are  most  problematic  in  the  Basic  Protection  area  are  Journalistic  profession,  standards  and 
protection,  and  Universal  reach  of  traditional  media  and  access  to  the  Internet.  The  average  medium  risk  of  the 
indicator on Universal reach can be explained to some extent with the high parameters used by the MPM in order to 
assess acceptable levels of access to the Net, based on EU existing standards.

Even  if  the  general  average  is  within  the  low  risk  band  (30%),  the  indicator  on  Journalistic  profession  produces 
alarming results, as one third of the countries analysed under the MPM2016 (Croatia, Ireland, Italy, Romania, Latvia, 
Bulgaria, Greece, Montenegro, Hungary, Turkey) fall within the medium risk band . The detailed data analysis of this 
indicator shows that in many countries journalists face censorship, intimidation, job insecurity, physical attacks, and 
digital threats.

Turkey (a country that was not assessed by previous MPMs) undoubtedly presents the highest risks in relation to 
the Basic Protection area and is, in general, an outlier in the assessment of the risks to media pluralism under the 
MPM2016. The country is facing a dramatic crackdown on fundamental rights and rule of law, worsened since the 
attempted coup of July 2016. The scores for Turkey in the Basic Protection area vary between medium and high risk, 
with an alarming percentage of risk for Protection of freedom of expression (81%), due to a lack of respect for the rule 
of law and due to the highest risk amongst the 30 MPM2016 countries in terms of Journalistic profession, standards 

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CENTRE FOR MEDIA PLURALISM AND MEDIA FREEDOM - Results

and protection. In Turkey, the legal framework on freedom of expression and its implementation are not in line with 
common European and international standards: for instance blasphemy, insulting religion insulting the President not 
only are criminal offences, but are widely applied and often turn in prison sentences. Grounds of limitation of freedom 
of expression are often interpreted in an arbitrary way: criminal law, defamation legislation and the anti-terrorism 
law  are  used  to  punish  critical  reporting  including  numerous  cases  of  arbitrary  pre-trial  detention  of  journalists7. 
Concerns over the respect of freedom of expression standards arise as a result of general monitoring and blocking 
policies implemented by state bodies: “tens of thousands of websites, most of them independent and/or Kurdish online 
news sites have been blocked by Telecommunications Communication Presidency (TİB)”(Inceoglu et al, 2017).

PROTECTION OF FREEDOM OF EXPRESSION

Freedom of expression is considered to be the cornerstone of democracy. Freedom of the press, freedom of the media, 
right to access information - being essential conditions for a public sphere in which public opinion is based upon 
the free exchange of information and opinions - stem from freedom of expression. In addition to that, freedom of 
expression also ‘enables’ other rights, like the right of assembly, the right to join a political party, the right to vote.8 Its 
protection is thus at the very core of any democratic society. EU member states share and are bound to the respect of 
freedom of expression as it is enshrined in Art 11 of the EU Charter of Fundamental Rights and as it is at the core of 
their common constitutional traditions. It is also a right that has been effectively promoted under the Enlargement 
and Accession process (Brogi, Dobreva and Parcu, 2014) and by the Council of Europe framework of protection of 
human rights (Voorhoof, 2014).

The indicator on Protection of freedom of expression under the MPM2016 aims to assess the existence and effective 
implementation of regulatory safeguards for freedom of expression in a given country. A country may have good laws 
protecting freedom of expression, but they may not be implemented or enforced effectively. Sometimes constitutional 
guarantees may be eroded by exceptions and derogations from international treaty obligations or by other laws that 
may limit freedom of expression in an arbitrary way. In order to assess the levels of protection of freedom of expression, 
the MPM uses the standards developed by the European Court of Human Rights (ECtHR) under the interpretation of 
Art. 10 of the European Convention of Human Rights (ECHR). According to these parameters, freedom of expression 
must be protected under the rule of law: restrictive measures should have a legal basis in domestic law, should be 
accessible  to  the  person  concerned  and  foreseeable  to  its  effects;  limitations  must  have  a  “legitimate  aim”  and  be 
“necessary in a democratic society”. The ECtHR has interpreted broadly the scope of freedom of expression, as it is 
considered essential for the functioning of a democratic society: “the dynamic interpretation by the Court of what 
is to be considered ‘necessary in a democratic society’ together with the limitation of the ‘margin of appreciation’ by 
the member states has been crucial for the impact of Article 10 of the Convention on the protection of freedom of 
expression in Europe” (Voorhoof, 2014).

The indicator includes also a sub-indicator that is specific on defamation. While defamation is an important tool to 
protect  people  from  false  statements  that  damage  their  reputation,  defamation  laws  can  “easily  be  misused”9  and 
criminalization of defamation may pose risks for freedom of expression, producing a chilling effect on journalistic 
freedom. Journalists, instead, should enjoy a position to exercise their job without fear. 

Online violations of freedom of expression are growing in frequency and importance. Another element that is therefore 
taken into account in the indicator is whether freedom of expression online is limited on the same grounds as freedom 
of expression offline.10 In this regard, the indicator takes into account whether Art 10 of the ECHR is respected, and, in 
particular, whether restrictive measures resulting in blocking, removing and filtering online content comply with Art 
10.2 ECHR (i.e.  limitations on freedom of expression are prescribed by law, pursue a legitimate aim, and are necessary 
in a democratic society).

The indicator also takes into consideration whether filtering and blocking practices by Internet service and content 
providers and by a given state are arbitrarily limiting freedom of expression online.

 See also Council of the European Union, EU Human Rights Guidelines on Freedom of Expression Online and Offline, 12 May 2014 

7 
  Council  of  Europe,  Platform  to  promote  the  protection  of  journalism  and  safety  of  journalists,  http://www.coe.int/en/web/me-
dia-freedom/all-alerts?p_p_id=sojdashboard_WAR_coesojportlet&p_p_lifecycle=0&p_p_state=normal&p_p_mode=view&p_p_col_id=col-
umn-1&p_p_col_pos=2&p_p_col_count=4&_sojdashboard_WAR_coesojportlet_mvcPath=%2Fhtml%2Fdashboard%2Fsearch_results.jsp&_
sojdashboard_WAR_coesojportlet_selectedCategories=11709592&_sojdashboard_WAR_coesojportlet_fulltext=1 (7/04/2017)
8 
http://www.consilium.europa.eu/uedocs/cms_data/docs/pressdata/EN/foraff/142549.pdf
9 
tion_society/newsroom/image/document/2016-50/2016-fundamental-colloquium-conclusions_40602.pdf
10 
 Recommendation CM/Rec(2016)5[1] of the Committee of Ministers to member States on Internet freedom, (Adopted by the Comm-
mittee of Ministers on 13 April 2016 at the 1253rd meeting of the Ministers’ Deputies) https://search.coe.int/cm/Pages/result_details.aspx?Ob-
jectId=09000016806415fa

 Media pluralism and democracy: outcomes of the 2016 Annual Colloquium on Fundamental Rights http://ec.europa.eu/informa-

10

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Figure 1.1.3. Protection of freedom of expression - Map of risks per country

The results for the first indicator on Protection of freedom of expression show 25 countries at low risk (note that 
Bulgaria and France score a 33% risk, so are very close to the medium risk band), four countries at medium risk 
(namely Latvia, Hungary, Romania, Poland), while Turkey scores a high risk.

Legal protection for freedom of expression is formally guaranteed in all the countries considered under the MPM2016. 
It is enshrined in all the constitutions and/or in the national laws. As a general trend, relevant international conventions 
on human rights, that are particularly relevant for freedom of expression standard setting, the International Covenant 
on Civil and Political Rights (ICCPR, art 19) and the European Convention on Human Rights (ECHR, Art 10) have 
been ratified with no particular exemption. According to the collected data (Nenadic, 2017), only Malta has made two 
peculiar and significant reservations to Article 19 of the ICCPR that may affect the assessment of the risks for freedom 
of expression in the country, declaring that Art 19 ICCPR does not affect the Constitutional provision that allows for 
restrictions on the freedom of expression for public officials, as long as such restrictions are “reasonably justifiable in a 
democratic society”. According to the Code of Conduct of Public Officers in Malta, public officers are precluded from 
taking an active part in political discussions or other political activity during working hours or on the premises. Malta 
also reserved the right not to apply article 19 to the extent that non-application is fully compatible with domestic 
legislation that regulates “the limitations on the political activities of aliens”, and in accordance with Article 16 of the 
ECHR (Restrictions on political activity of aliens).

It must be noted, that France, since the terrorist attacks in 2015 and Turkey, after the failed coup in 2016 have asked 
for derogation from certain rights that are guaranteed by the European Convention on Human Rights, due to the state 
of emergency (Art 15 ECHR). In both cases and to different extents, this can be seen as being a risk to Protection of 
freedom of expression (see below).

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While  freedom  of  expression  is  formally  protected  in  all  the  countries  considered,  the  data  collection  shows  that 
the main differences amongst the legal systems lie in the grounds of limitation of freedom of expression and in the 
proportionality of this limitation -- in the end, on the respect of the rule of law. Art. 10 ECHR states that freedom of 
expression can be limited “in the interests of national security, territorial integrity or public safety, for the prevention 
of disorder or crime, for the protection of health or morals, for the protection of the reputation or rights of others, for 
preventing the disclosure of information received in confidence, or for maintaining the authority and impartiality of 
the judiciary”. Overall, legal orders of the countries covered under the MPM2016 implementation comply with the 
standards that are provided by the ECHR and the interpretation of the ECtHR, with some noticeable exceptions. 

Figure 1.1.4. Protection of freedom of expression - Risk average scoring  
for sub-indicator

For instance, the protection of the reputation of others is one of the most common grounds for limiting freedom of 
expression. The  score of  the sub-indicator  on Proportionate balance between protection of freedom of expression 
and  dignity  (35%)  under  Protection  of  freedom  of  expression  shows  a  medium  risk  on  average  in  MPM2016 
countries as regards existence and implementation of proportionate laws on defamation. Many countries score high 
(Hungary, Latvia, Poland, Portugal, Turkey) or medium risk (Austria, Croatia, Slovenia, United Kingdom, Finland, 
Italy, Luxembourg) for the sub-indicator on Proportionate balance between protection of freedom of expression and 
dignity.  All  countries  have  legislation  on  defamation,  but  the  scope  of  it  varies  from  country  to  country  and  the 
limitations on the ground of honour and reputation are shaped in laws that are not fully homogeneous or comparable 
and may be not consistent with international standards on freedom of expression. For instance, most of the countries 
analysed under the MPM guarantee special protection to public officials and to heads of state against defamation. 
In many countries criminal defamation laws are still upheld, while for just a few, defamation cases are dealt with via 
civil proceedings. Imprisonment for defamation (libel) is possible in most EU member states, along with pecuniary 
sanctions;  high  damages  are  very  common  remedies  to  libel  when  it  comes  to  civil  defamation.  According  to  the 
MPM2016 data, blasphemy is foreseen as a crime in many EU countries (for instance in Finland, Greece, Italy, Ireland, 
Denmark,  Turkey).  This  is  due  to  “…[t]he  absence  of  a  uniform  European  conception  of  the  requirements  of  the 
protection of the rights of others in relation to attacks on their religious convictions”. This widens the countries’ “… 
margin of appreciation when regulating freedom of expression in relation to matters liable to offend intimate personal 
convictions within the sphere of morals or religion”.11

11 

 ECtHR cases Giniewski v. France 64016/00, Otto-Preminger-Institut v Austria13470/87; Wingrove v United Kingdom 17419/90; and 

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The scope of the restrictions, interpretation of the law and effective implementation of it by judges make the difference 
in assessing risks for media pluralism when comparing countries where defamation is a criminal offence. Just as an 
example, in Poland (high risk in the sub-indicator) defamation, insult and offence are punishable by imprisonment: 
“although most of the punishments result in fine, or community service, there have been also cases in which the courts 
decided about suspended sentence of deprivation of liberty. An unnecessarily restrictive and formalistic treatment of 
some defamation cases by the domestic courts leads repeatedly to applications submitted to the ECHR” (Klimkiewicz, 
2017). In Finland, a country that is usually at the top of the international rankings on freedom of expression, defamation 
carries fines while (just) aggravated defamation,12 as reported by the country team, can result in a prison sentence of 
up to two years, which cannot be considered proportional.  Nonetheless, as further noted by the country team, no 
Supreme Court or Appeal Court ruling in the past two years has upheld a fine (no appeals involving prison sentences 
were processed). 

Countries where defamation is not criminalised and imprisonment is not a sanction score lower risks, but may still 
face problems when it comes to proportionate responses to defamation. The MPM2016 data collection reports cases of 
the awarding of disproportionate damages (e.g. Montenegro, Romania). While disproportionate remedies can have a 
chilling effect on journalists as having the effect of limiting their watchdog role, it must be noted that MPM teams have 
also reported cases in which defamation is used by newspapers as a “political weapon” to feed in an unfair manner 
the political debate. This is the case in Bulgaria where “the majority of the media involved in libel and defamation are 
deliberate, and the fines are either never paid or are not enough to discourage further publication”13. 

Within Protection of freedom of expression, the MPM2016 analyses also whether freedom of expression online is 
guaranteed and respected in practice. This specific focus is interesting as it gives an overview of how different countries 
interpret and apply the rule of law for freedom of expression online. In general, the laws are not specifically drafted 
to protect freedom of expression online: online expression should be limited to the same grounds and extent like 
offline expression. Nonetheless, this may lead to an incoherent enforcement of the provisions regarding restrictions 
online,  as  well  as  to  a  lack  of  predictability  and  foreseeable  consequences  of  expression  online.  The  sub-indicator 
on guarantees of freedom of expression online seeks to analyse whether restrictive measures of blocking, filtering 
and removing online content comply with the three conditions set by Article 10(2) ECHR, namely that limitations 
on freedom of expression are prescribed by law, pursue a legitimate aim foreseen in Article 10(2) ECHR, and are 
necessary in a democratic society. Again, the standards for this evaluation are set by the most recent case-law of the 
ECtHR (Barata and Bassini, 2016). Another aim of the sub-indicator is to collect information on and assess risks 
stemming from blocking and filtering practices of governments and online intermediaries. Turkey scores high risk for 
this sub-indicator, with very high risks reported for all the variables that compose the sub-indicator, what confirms its 
outlier position in comparison with the other assessed countries. The Turkish Ministry of Transportation, Maritime 
Affairs and Communications and the Telecommunication authority (TIB) could ban access to any website without 
a court order. Private intermediaries are bound to orders and are compelled to execute the court and TIB blocking 
decisions  they  receive  subject  to  the  law.  No  instances  of  Internet  service  providers  (ISPs)  challenging  any  of  the 
thousands of blocking decisions they receive on a yearly basis have been reported by the country team (Inceoglu et 
al., 2017, for more details).

Six  other  countries  score  a  medium  risk  for  this  sub-indicator  (Cyprus,  France,  Romania,  Ireland,  Poland,  the 
United  Kingdom).  In  particular,  after  terrorist  attacks  in  the  country,  as  state  of  emergency  was  declared,  France 
has adopted laws that extend the possibility of blocking websites by order of the State and that allow authorities to 
monitor international communications without judicial review. The law on surveillance of international electronic 
communications expands the powers of the executive over the collection, analysis and storage of communications 
content or metadata, without requiring prior authorization or judicial review. As noted by the country team, this has 
raised some concern as regards the respect of the rule of law and international standards on freedom of expression.

Similarly, the recent “Investigatory Powers Bill” proposed in 2015 by the UK government has been heavily criticized as 
an infringement of civil liberties and an unprecedented expansion of state surveillance powers on privacy on one side, 
and journalistic freedom and protection of sources on the other, as it deals with encryption, bulk data and hacking. 
The text, as partially amended to include more safeguards and approved by the House of Lords in November 2016, 
grants  police,  tax  inspectors  and  other  public  officers  the  power  to  access  data  related  to  communications’  traffic 
(including internet communications) without prior judicial review.14

Murphy v. Ireland, no. 44179/98,
12 
 According to Section 10 of Chapter 24 of the Finnish Criminal Code :Section 10 - Aggravated defamation (879/2013) If, in the deff-
amation referred to in section 9(1), considerable suffering or particularly significant damage is caused and the defamation is aggravated also 
when assessed as a whole, the offender shall be sentenced for aggravated defamation to a fine or to imprisonment for at most two years.
 Bulgaria Media Sustainability Index (MSI)2015  
13 
  Council  of  Europe,  Platform  to  promote  the  protection  of  journalism  and  safety  of  journalists,  https://www.coe.int/en/web/me-
14 
dia-freedom/all-alerts?p_p_id=sojdashboard_WAR_coesojportlet&p_p_lifecycle=0&p_p_state=normal&p_p_mode=view&p_p_col_id=col-

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PROTECTION OF THE RIGHT TO INFORMATION

The  indicator  on  the  Protection  of  the  right  to  information  is  designed  to  assess  the  existence  and  effective 
implementation  of  regulatory  safeguards  in  relation  to  access  to  information.  Hence,  it  aims  to  assess  one  of  the 
building blocks of media freedom and investigative journalism. The indicator is very simple and structured in a way 
that allows comparisons with the MPM2015 indicator on the same topic. As in MPM2015, the indicator focuses on 
the right of access to information that is held by public authorities and the state, the lawfulness of its limitations, as 
well as the existence and effectiveness of appeal mechanisms in cases where there is denial of access to information. 
The indicator is based on the notion that “all information in the possession of the State belongs to the public, with 
limited and qualified exceptions that must be justified by State authorities”.15 The indicator has no sub-indicators, but 
consists of five variables.

Figure 1.1.5. Protection of the right to information - Map of risks per country

According to MPM2016 data collection, Protection to the right of information scores low risk in most of the countries 
considered. Only a very small portion of states scored a medium risk (3 countries, namely Bulgaria, Hungary and 
Turkey) and only 2 countries showed a high risk (Austria and Luxembourg). The average risk under this indicator 
(24%) falls within the low band.

Luxembourg and Austria confirmed the negative scores of MPM2015, as they both fall within the high risk band. The 
reason why these countries score such high risks is the same as in 2015. In Austria, art. 20 of the Federal Constitution 
enshrines a right to information in its paragraph 4; however, the same article in its paragraph 3 states that the organs 
charged with federal, provincial and municipal administration, as well as other public bodies, are sworn to secrecy 
concerning all facts that come to their knowledge during their official duty and this has precedence over freedom of 

umn-1&p_p_col_pos=2&p_p_col_count=4&_sojdashboard_WAR_coesojportlet_mvcPath=%2Fhtml%2Fdashboard%2Fsearch_results.jsp&_
sojdashboard_WAR_coesojportlet_selectedCategories=13050458&_sojdashboard_WAR_coesojportlet_fulltext=1
15 
2013. Available at http://undocs.org/A/68/362.Para 50.

 Report of the Special Rapporteur on the promotion and protection of the right to freedom of opinion and expression. 4 September 

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CENTRE FOR MEDIA PLURALISM AND MEDIA FREEDOM - Results

information (CMPF, 2016 and Seethaler et al., 2017). The Constitution in Luxembourg does not mention or protect the 
right to information; in addition there is also a lack of general law on freedom of information (CMPF, 2016 and Kies et 
al., 2017). On 15 February 2013, a draft law concerning the access of citizens to documents held by the administration 
was presented to the Parliament of Luxembourg but it is still in the process of being adopted. The bill has been widely 
criticised by civil society organisations as “it seems not to bring any fundamental change compared to the previous 
draft bill on the access of citizens to documents held by the administration. It contains numerous exceptions and the 
administration keeps important powers in terms of deciding when to issue the information” (Kies et al., 2017). 

Bulgaria and Hungary (38%) confirm the medium risk assessments of MPM2014. In Bulgaria, laws on freedom of 
information are not effective: the access to public information has been systematically violated in the last two years. 
According to the data provided by the Bulgarian country team (Spassov et al., 2017) public institutions “are becoming 
more and more creative in denying information to the media and to investigative journalists in particular”. In Hungary, 
while a regulatory framework is in place, and courts have generally ruled on the side of disclosure of public data, 
lack of information on cases of rejection of access to information and delays coming from court appeals may affect 
effectiveness of the law and have a high cost to the public’s right to know (Brouillette et al., 2017). 

In Italy, instead, the low risk for this indicator is an improvement compared to the assessment on the same indicator 
under MPM2014 (medium risk - CMPF, 2015). The decreased risk is due to the positive regulatory trends and legislative 
steps towards an effective right to information, in line with international standards. The Italian government approved 
in 2016 a legislative decree that details and puts in practice the “transparency” reform already started in 2013.

Turkey scores a very high percentage (63%) within the medium risk band. This is due to the fact that, although the 
right to information is enshrined in relevant legislation, the grounds of limitation to access to public information are 
wide (state secrets, the economic interests of the state, the state intelligence, the administrative investigations, and 
judicial  investigations  and  prosecutions)  (Inceoglu  et  al,  2017),  what  makes  them  [the  grounds  of  limitation]  not 
oriented to guarantee transparency and the public interest.

JOURNALISTIC PROFESSION, STANDARDS AND PROTECTION

Journalists (and other media actors) are those that, in a functioning democratic society, feed the public debate and 
ensure the public is informed on all matters of public interest. Contributing to the public debate, journalists influence 
public opinion and, in the end, electoral choices of voters and accountability of politicians. It is therefore important 
that, in a democratic society, access to the profession of journalist is not limited (e.g. subject to licensing schemes);16 
and  that  journalists  can  act  independently  from  political  and  commercial  interests  and  may  rely  on  an  “enabling 
environment” to carry out their job. In this regard, the standards are provided by the ECtHR: the Court has stressed 
in its case-law that countries have positive obligations to “create a favourable environment for participation in public 
debate by all persons concerned, enabling them to express their opinions and ideas without fear”.17 This means also 
that the countries are under a duty to guarantee a safe environment where journalists and other media actors can 
exercise their watchdog function.18

The indicator on Journalistic profession, standards and protection, as in MPM2015, deals with a range of different 
aspects concerning the journalists and journalism. The indicator is composed of four sub-indicators, that describe 
risks  resulting  from  conditions  to  access  the  profession;  from  the  level  of  representation  of  the  interests  of  media 
professionals and media employers in labour relations and the effectiveness of professional organisations to guarantee 
professional  standards;  from  safety  conditions,  both  physical  and  “digital”,  and  working  conditions;  and  from  the 
existence and levels of implementation of rules on protection of journalistic sources.

 Cf. Art. 19, Licensing of media workers, https://www.article19.org/pages/en/licensing-of-media-workers.html. 
16 
17 
 ECtHR, case Dink v. Turkey, 2668/07, 6102/08, 30079/08, 7072/09 et 7124/09, Judgment on September 14, 2010. See also Council 
of Europe, Committee of Ministers, Recommendation CM/Rec(2016)4 of the Committee of Ministers to member States on the protection of 
journalism and safety of journalists and other media actors,  https://search.coe.int/cm/Pages/result_details.aspx?ObjectId=09000016806415d9 
 This obligation was stressed also during the 2016 Colloquium on Fundamental Rights, see Media pluralism and democracy: outt-
18 
comes of the 2016 Annual Colloquium on Fundamental Rights, id.

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Figure 1.1.6. Journalistic profession, standards and protection - Map of risks per 
country

As already mentioned, this is an indicator that shows many risks in the MPM2016 countries. A considerable number 
of countries scored a medium risk (ten countries, namely Croatia, Ireland, Italy, Romania, Latvia, Bulgaria, Greece, 
Montenegro, Hungary, Turkey), with one country reaching a low level score close to the borderline of medium risk 
(Netherlands) and four countries (Malta, Cyprus, France and Slovakia) in the low band scoring around 30% of risk, 
which is still quite high for an indicator under Basic Protection. Turkey is the country that shows the highest risk 
amongst the thirty counties (63%, medium, but close to the high risk band).

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Figure 1.1.7. Journalistic profession, standards and protection - Risk average scoring 
for sub-indicator

The analysis of the sub-indicator on access to the journalistic profession does not show particular risks (average of 
the  indicator  9%).  Most  of  the  countries  either  have  self-regulatory  instruments  that  prescribe  who  may  practice 
journalism or that require the licensing or registration of journalists on the basis of transparent, objective, proportionate 
and non-discriminatory requirements, or they do not have any rule on that, enabling open access to the profession. 
Italy scores a high risk under this sub-indicator, as access to the journalistic profession faces a sort of “filter” by law: 
a  professional  journalist  must  be  enrolled  in  the  Albo  dei  Giornalisti (Register  of  Journalists),  kept  by  the Ordine 
dei Giornalisti (Order of Journalists). In some countries, access to journalism is restrained de facto by poor working 
conditions associated with the profession itself (Austria, Hungary) and by political pressures (Hungary). Although 
there are no legal barriers, access to the profession in Ireland is influenced by education (and level of education by 
income). According to the MPM2016 for Ireland (see Flynn, 2017) there is ample evidence that social class is a real 
determinant of who can access the profession. In Bulgaria, instead, free and unlimited access to journalistic profession 
is  sometimes  criticized  as  leading  to  many  cases  of  low  quality  journalism,  disregard  for  the  basic  professional 
standards, and propaganda assignments (Spassov et al., 2017).

The assessment of the effectiveness of professional associations and unions in supporting better working conditions, 
including independence, for member journalists shows an overall medium risk (46%) across the 30 countries. This 
somehow confirms the results of MPM2015, as most of the analysed countries score high or medium risk under the 
relevant variables. Only Austria, France and Germany report a low risk. Progressively fewer journalists are represented 
by professional associations or other journalists’ organisations: this is due to the deep changes in the media job market, 
the disruption of the information system coming from the web, the fact that journalism is increasingly practiced by 
freelancers and very often outside traditional media organizations.

The  sub-indicator  on  Protection  of  journalists  scores  an  alarming  average  of  52%:  most  of  the  countries  report  a 
medium or high risk regarding the risks for the safety of journalists. This includes physical safety (attacks and threats 
to physical integrity) and threats coming from online surveillance, seizure of computers, and disclosure of sources 
online. States are, therefore, failing to a large extent in fulfilling their positive duty to create that favourable environment 
for participation in public debate by journalists and other media actors that the ECtHR and Council of Europe have 
repeatedly advocated for. Turkey, Bulgaria, Croatia, Greece, Montenegro, Italy, Romania, Sweden, Latvia, Germany, 
Hungary, report high risks. Cyprus, France, Ireland, Poland, Slovakia report medium risks. Finland, United Kingdom, 
Belgium, Malta, the Netherlands and Spain are scoring 33%, still a high percentage within the low risk band. 

17

CENTRE FOR MEDIA PLURALISM AND MEDIA FREEDOM - Results

On a methodological note, although Turkey scores the highest risk percentage (100%) under the sub-indicator on 
safety of journalists, the sub-indicator itself does not weigh enough the extent of the effective crackdown on journalists 
the country is facing, in comparison with other countries that score a high risk under the same sub-indicator19. The 
score for Turkey in this case reflects more an assessment of the effective situation of violation of human rights in the 
country than an assessment of risks to media pluralism.

The last component of the indicator is protection of sources. According to the data provided by MPM country teams, 
The Netherlands seem to be the only country where protection of sources is not established in any law or in case-law 
which represents a risk in this country. The Dutch government has been repeatedly criticized by the European Court 
of  Human  Rights  for  not  having  legislation  in  place  that  legally  guarantees  the  protection  of  journalistic  sources 
(Paapst and Mulder, 2017). In Greece, the country team reports that there are some rules  regarding the protection of 
sources to radio and television news and current affairs programmes. The courts recognise that protection of sources 
constitutes  an  intrinsic  part  of  free  speech  (Kandyla  and  Psychogiopoulou,  2017)  and  self-regulation  provides  for 
the protection of journalistic sources. In Bulgaria, a legislation on journalistic sources is in place, but many cases of 
pressure  on  journalists  are  reported:  in  January  2015  the  Financial  Supervision  Commission  (FSC)  imposed  high 
fines  on  Capital  Daily  and  Dnevnik  Online,  and  on  zovnews.com,  claiming  that  the  publications  of  these  media 
aimed to destabilize the banking sector and insisting the sources of information to be revealed (see Spassov et al., 
2017).  In France, after the Intelligence Bill was passed, emails and messages exchanged by journalists and sources are 
susceptible of being intercepted if the latter are targetedin the fight against terrorism (Vedel et al., 2017). As mentioned 
in the MPM2016 data collection for France, intelligence services can obtain and preserve for five years the browsing 
history of any journalist. A serious case of violation of protection of sources is reported in Latvia: a 2016 case of police 
investigation on the team of the programme “Aizliegtais paņēmiens” and on journalist Sanita Miķelsone (Rozukalne, 
2017).

INDEPENDENCE AND EFFECTIVENESS OF THE MEDIA AUTHORITY

The recent 2016 Colloquium on Fundamental Rights on Media Pluralism and Democracy has affirmed the importance 
of independence of media authorities for media pluralism, also in the light of the on-going revision of the Audiovisual 
media service directive.20 Building on the MPM2015 pilot-test implementation, the indicator on independence and 
effectiveness of the media authority has been revised in MPM2016 and focussed only on the main media authority 
(see definition below). The indicator is designed to capture a number of different characteristics of media authorities in 
the thirty countries: whether the appointment procedures guarantee their independence and whether the authorities 
are independent in practice; whether the allocation of budgetary resources protects them from coercive budgetary 
pressures and ensures the possibility of performing their functions; the type of powers and appeal mechanisms which 
are in place in regard to the authorities’ decisions; transparency and accountability of their actions.

 The MPM was originally not designed to measure the type of situation currently existing in Turkey, as, for example, no indicator refers 

19 
to the number of journalists in prison.
 “The European Parliament and the Council should swiftly adopt the revision of the Audiovisual Media Services Directive proposed 
20 
by  the  European  Commission  in  May  2016.  It  requires  regulatory  authorities  in  the  field  of  audiovisual  media  services  to  be  independent 
and sets out the requirements on independence they have to comply with”. http://ec.europa.eu/information_society/newsroom/image/docu-
ment/2016-50/2016-fundamental-colloquium-conclusions_40602.pdf

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Figure 1.1.8. Independence and effectiveness of the media authority - Map of risks 
per country

On a methodological note, the MPM2016 considers a media authority to be a public body which upholds the rules 
that are formulated in media acts and laws and which oversees the media market. For those countries that do not 
have an authority devoted to media regulation, the MPM2016 asks to consider and assess the authority that is part of 
the European Regulators Group for Audiovisual Media Services (ERGA) or of the European Platform of Regulatory 
Authorities (EPRA). In Estonia, for instance, the Technical Regulation Authority is considered, while for Spain the 
competition authority.

For this indicator, just a small percentage of the countries reached a medium (five countries) or high level risk (only 
Turkey). The medium risk for five countries (Latvia, Greece, Spain, Hungary and Slovenia) is due to the fact that, 
despite the fact that most of these countries have laws in place to ensure more transparency and independence for the 
media authorities, the appointment procedures are not always effective in safeguarding political and/or commercial 
independence of the members. These countries report also that, in practice, media authorities are subject to some kind 
of political interference in their activities.

According  to  the  MPM2016  data  collection,  the  Turkish  situation  of  high  risk  is  due  to  different  factors.  Firstly, 
the selection and appointment procedures of the members of the Radio and Television Supreme Council (RTÜK) 
defined by the law is not transparent and cannot exclude political interference. There is no independent representative 
of  media  associations,  trade  unions,  academia  or  audience  to  strengthen  the  independence  and  professionalism 
of  the  regulatory  body.  In  practice,  the  Authority  does  not  act  independently  from  political  influence.  The  Radio 
and Television Supreme Council publishes annual reports on its activities including its budget, revenues, statistics, 
employment etc.; however, the country team notes that there are no details about its decisions, information on the 
media market, market shares or audience shares and media ownership.

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Figure 1.1.9. Independence and effectiveness of the media authority - Risk average 
scoring for sub-indicator

A common feature in many countries observed under the MPM2016 is the weak effectiveness of mechanisms that 
exclude political or commercial influences and ensure independence of the authorities in the appointment procedures 
for the members of the authorities. In addition to countries that scored medium or high risk under this indicator (see 
above), Greece, Ireland, Italy, Slovenia are at high risk for the relevant sub-indicator on Appointment procedures. 
Political influences on appointments do not automatically mean that the authority will act in line with political inputs, 
but it poses a risk of further interference.

The assessment of the competencies of the authorities scores an overall 9% of risk. Within this sub-indicator the main 
problem comes from few cases in which the government overruled decisions of the media authority.

Recent  cases  in  Europe  have  put  the  spotlight  on  the  important  role  of  media  authorities  in  the  governance  of 
national media sectors and media pluralism and posed some questions regarding the level of independence (or better 
“resilience”) of these authorities, vis à vis political power. Media authorities can be exposed, for instance, to political 
turnover.  For  instance,  in  Croatia,  there  has  been  an  escalation  in  political  pressure  towards  the  media  authority, 
the Council of Electronic Media. The Council issued a ban on the television broadcaster Z1 (regional license) for 
repeated  incitement  to  hatred  in  its  programs.  The  (then)  newly  appointed  Minister  of  Culture  and  the  Croatian 
Government rejected the 2014 annual report by the Council and proposed to the Croatian Parliament for the Council 
to be removed and replaced. Due to increasing pressure the president of the Council for Electronic Media eventually 
resigned from her position21. 

In Poland,  2015 Small Media Act, and the 2016 Act on National Media Council, modified for the first time since 
1993 the competences of the Broadcasting Authority (KRRiT) in the area of appointing PSM boards and supervising 
PSM. The ‘Small Media Act’ introduced PSM boards’ appointment directly by the Minister of the Treasury, while the 
2016 Act on National Media Council, created later a new body responsible for PSM appointments (National Media 
Council), weakening the competences of KRRiT in this regard. This is a case of “legislative drain” of competencies from 
an independent authority  (KRRiT) to a body that is under governmental control. The composition of the national 
Media Council, in fact, “strongly reflects influence of political parties and does not limit a possible membership by 
active politicians and the Members of Parliament” (Klimkiewicz, 2017).

21 
the Council.

 Although the president resigned, her resignation has not been accepted (end of 2016), so she remains in office as well as the rest of 

20

CENTRE FOR MEDIA PLURALISM AND MEDIA FREEDOM - Results

In  Greece,  due  to  the  ability  of  political  parties  to  veto  candidates,  there  have  been  considerable  delays  in  the 
appointment of new members of the broadcasting authority. This was done with the purpose to hinder the auction 
procedure to assign licences for digital terrestrial TV transmission, as the Authority should have been involved in it 
(see Kandyla and Psychogiopoulou, 2017, for more details).

Budgetary  independence  of  the  media  authority  is  an  issue  in  at  least  one  third  of  the  countries:  Spain,  Turkey, 
Estonia, Greece and Montenegro score high risk for the relevant sub-indicator, while Finland, Latvia, Luxembourg, 
Slovakia and Slovenia show a medium risk. According to the standards of the Council of Europe22, arrangements for 
the funding of the media authority should be specified in law, with reference to the estimated cost of its activities, so 
as to allow the authority to carry out its functions fully and independently. Public authorities should not use their 
financial decision-making power to interfere with the independence of the media authority.

UNIVERSAL REACH OF TRADITIONAL MEDIA AND ACCESS TO THE INTERNET

The aim of the indicator on Universal reach of traditional media and access to the Internet is to describe risks to 
pluralism coming from an insufficient level of access to platforms of content distribution. The indicator on universal 
reach  of  traditional  media  and  access  to  the  Internet  is  an  improvement  of  the  MPM2015  indicator  on  Universal 
coverage of PSM and the Internet. The indicator consists also of variables on net neutrality, contained in MPM2015 
under the indicator on horizontal ownership concentration and on access to the Internet.

Figure 1.1.10. Universal reach of traditional media and access to the Internet - Map 
of risks per country

 Declaration of the Committee of Ministers  on the independence and functions of regulatory authorities for the broadcasting secc-
(2008)  https://wcd.coe.int/ViewDoc.jsp?p=&Ref=Decl(26.03.2008)&Language=lanEnglish&Ver=original&BackColorInternet=9999C-

22 
tor 
C&BackColorIntranet=FFBB55&BackColorLogged=FFAC75&direct=true

21

CENTRE FOR MEDIA PLURALISM AND MEDIA FREEDOM - Results

The majority of the countries scored a medium risk for this indicator (18 out of 30), with eleven countries reaching a 
low risk and just one country (Hungary) showing a high risk (81%). This high risk score for Hungary is mostly due to 
the fact that universal access for broadband (fixed line and mobile) has not been achieved in Hungary, with 87,20% 
of broadband coverage, which is low if compared with the countries that obtained the best score for this indicator, i.e. 
Denmark, Finland, Sweden and the Netherlands, where broadband coverage reaches almost 100% (Sweden 99.8%, 
Netherlands 99.9%, Finland 99.8% and Denmark 99.7%). It is important to highlight, however, that the thresholds 
for the broadband coverage are quite high (99-100 low risk, 98-97 medium risk and 96 or less high risk, calculated by 
taking into account the existing levels of broadband in EU countries).

As for the Internet Access, 23 countries scored a medium or high risk, with just seven countries reaching a low risk 
level. We have to bear in mind that MPM2016 again has a very high threshold for assessing this risk (low risk 81-100%, 
medium risk 71-80% and high risk 0-70%, calculated by taking into account the existing levels of access to internet in 
EU countries). 

Regarding the percentage of the population covered by signal of all public TV channels and radio stations, the majority 
of countries scored a low risk level (20 countries for TV channels and 18 for radio, with only few countries with a high 
risk level (5 for TV channels and 4 for radio stations), with an even higher threshold for assessing the risk levels (Low: 
99% or more; Medium: >98% and <99%; High: <98%).

This  indicator  also  showed  a  high  concentration  of  the  market  shares  in  the  hands  of  the  TOP  4  Internet  Service 
providers (ISPs) in the large majority of countries analysed (22 out 30). Two countries were found to have no available 
data. Harmonised rules on net neutrality apply throughout the EU as of 30 April 2016, following the adoption of 
Regulation (EU) 2015/2120 on 25 November 2015 (which is directly binding). So the principle of net neutrality is 
introduced directly in all 28 EU member states. It is, therefore, not surprising that Montenegro and Turkey score high 
risk under this sub-indicator, as they do not have any principle on net neutrality in their legislation.

Figure 1.1.11. Universal reach of traditional media and access to the Internet - Risk 
average scoring for sub-indicator

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CENTRE FOR MEDIA PLURALISM AND MEDIA FREEDOM - Results

1.2 ANALYSIS OF MARKET PLURALITY 

The Market Plurality area aims to assess risks to media pluralism that arise from the legal and economic context in 
which market players, most notably content providers, operate. For example, it seeks to establish whether regulation 
that restricts concentration of ownership has been enacted and, if so, whether it is effectively implemented. This area 
further attempts to unfold the economic conditions of the market in which these providers offer their services. For 
instance, it attempts to depict the levels of ownership concentration with reference to the market and audience shares 
that media firms hold.  

The Market Plurality area comprises the following five indicators:

•  Transparency of media ownership                            

•  Horizontal concentration of ownership

•  Cross-media concentration of ownership and competition enforcement

•  Commercial influence over editorial content

•  Media viability

As with all other areas of the Monitor, the above five indicators consist of sub-indicators. In turn, these sub-indicators 
encompass variables that evaluate risks that are pertinent to the issue under examination. For example, the indicator 
assessing commercial influence over editorial content contains a sub-indicator on editorial decision-making, which 
includes variables relating to regulation that prohibits advertorials.23 Compared to MPM2015, the most significant 
novelty  in  the  Market  Plurality  area  is  the  introduction  of  the  indicators  on  Commercial  influence  over  editorial 
content and Media viability. Though slightly amended, the remaining three indicators24 are based on the same rationale 
as their ‘predecessors’.

In the Market Plurality area, the vast majority of the countries under consideration scores medium risk. Two countries, 
namely Bulgaria and Luxembourg, score high risk, and three countries, that is, Germany, France and Portugal, score 
low risk.

 As per the Unfair Commercial Practices Directive, advertorials consist of “[u]sing editorial content in the media to promote a product 
23 
where a trader has paid for the promotion without making that clear in the content or by images or sounds clearly identifiable by the consumer”. 
See Directive 2005/29/EC of the European Parliament and of the Council of 11 May 2005 concerning unfair business-to-consumer commercial 
practices in the internal market and amending Council Directive 84/450/EEC, Directives 97/7/EC, 98/27/EC and 2002/65/EC of the European 
Parliament and of the Council and Regulation (EC) No 2006/2004 of the European Parliament and of the Council [2005] OJ L 149/22, Annex I, 
(11)
24 

 A description of the amendments introduced to the indicators used in the MPM2015 implementation will be provided   below

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CENTRE FOR MEDIA PLURALISM AND MEDIA FREEDOM - Results

Figure 1.2.1. Market Plurality area - Map of risks per country

At  one  end  of  the  spectrum,  Bulgaria  scored  71%.  Media  ownership  concentration  (horizontal)  and  Commercial 
influence over editorial content are the indicators that reflect the highest level of risk. This score is largely explained by 
the fact that, in Bulgaria, rules restricting concentration of ownership do not apply. Given sector-specific economics, 
which encourage consolidation, lack of regulatory safeguards setting ownership caps translates into high concentration 
ratios in several domains. For example, based on the data submitted by the country team, the CR4 concentration ratio25 
in the audiovisual and radio sectors is 82% and 81% respectively. In addition, there are currently no mechanisms 
that protect journalists in cases of changes of ownership and/or editorial direction. There also appears to be well-
documented influence of commercial interests over editorial decisions.26

At the other end of the spectrum, France scored the lowest risk in the Market Plurality area. This outcome is based 
on a number of parameters, including the existence of regulatory safeguards that limit (horizontal and cross-media) 
concentration and rules that establish transparency obligations vis-à-vis the public authorities and the public at large. 
Moreover, in order to shield editorial content from commercial influence, the French Code du Travail includes a clause 
de conscience; based on the provision in question, journalists are entitled to compensation in cases where they decide 
to  terminate  their  employment  contract  on  the  grounds  that  changes  in  the  editorial  direction  of  the  publication 
have taken place that are likely to affect their honour, reputation, or moral interests.27 However, it must be noted that, 
while performing better than the other countries examined by MPM2016, even the French situation is not ideal. For 
example, the fact that the national legislator has enacted certain rules in order to mitigate risks to media pluralism that 

 The CR4 (or Top4) concentration ratio is an indicator of the size of the four largest firms within an industry, compared to the output 

25 
of the entire industry. In this example, we refer to market share, which refers to the share of total revenues generated in the sector concerned
26 
 Assessment made by the Bulgarian team for Variable 101, referring to, inter alia, Freedom House (2016). Freedom of the Press 2015 
– Bulgaria. Available at: https://freedomhouse.org/report/freedom-press/2015/bulgaria; Blagov, K. and Orlin Spassov (2014). Influence on the 
Media: Owners, Politicians and Advertisers. Available at: http://www.kas.de/wf/doc/kas_39402-1522-2-30.pdf?141117155526; and IREX (2016). 
2016  Media  Sustainability  Index:  Bulgaria.  Available  at:  https://www.irex.org/sites/default/files/pdf/media-sustainability-index-europe-eur-
asia-2016-bulgaria.pdf.pdf
27 
 Article L7112-5 reads: ‘Si la rupture du contrat de travail survient à l’initiative du journaliste professionnel, les dispositions des articles L. 
7112-3 et L. 7112-4 sont applicables, lorsque cette rupture est motivée par l’une des circonstances suivantes: 1° Cession du journal ou du périodique; 
2° Cessation de la publication du journal ou périodique pour quelque cause que ce soit; 3° Changement notable dans le caractère ou l’orientation 
du journal ou périodique si ce changement crée, pour le salarié, une situation de nature à porter atteinte à son honneur, à sa réputation ou, d’une 
manière générale, à ses intérêts moraux. Dans ces cas, le salarié qui rompt le contrat n’est pas tenu d’observer la durée du préavis prévue à l’article L. 
7112-2’

24

CENTRE FOR MEDIA PLURALISM AND MEDIA FREEDOM - Results

arise from ownership concentration does not necessarily mean that the rules in question are adequate to achieve that 
objective. This may be inferred, inter alia, from the data gathered by the country team concerning the radio sector; 
safeguards to limit concentration in radio markets exist, but the audience concentration ratio is 72%.28 This result is 
explained by the fact that the Monitor aims to assess whether safeguards are in place without restricting the regulatory 
options States have at their disposal; it is up to the States under examination to decide which type of measure best 
addresses the risk concerned on the basis of the specificities of national media markets. 

One final remark needs to be made on the overall results of the Market Plurality area: the common assumption that 
small markets are more vulnerable to consolidation does not seem to hold. That is to say, one cannot establish a direct 
and causal relationship between the risk levels and the size of the market. It is worth noting that the assumption that 
small markets are systematically more susceptible to concentration than larger markets was also contradicted by the 
MPM2015 results (CMPF, 2016).

TRANSPARENCY OF MEDIA OWNERSHIP 

Media is a key component of democracy, for it plays an important role in holding power to account.29 However, in 
order to achieve that objective, it is essential that the ownership structures of media organisations be transparent. 
Public  authorities  need  to  know  who  controls  the  media  outlets  they  are  entrusted  with  monitoring  in  order  to 
effectively tackle undue concentration. Citizens need to know who controls media organisations, the content of which 
they consume in order to make informed decisions about matters of common concern. Based on the above rationale, 
the Monitor seeks to assess whether regulation establishing the obligation of media organizations to disclose their 
ownership structures has been enacted and, if so, whether it is effectively implemented.

Compared to previous implementations of the Monitor, the main novelty introduced by MPM2016 consists in that, 
instead of using one indicator to assess the extent of transparency obligations vis-à-vis the public, and/or the public 
authorities, this indicator now contains two sub-indicators that distinguish between the two issues. The reason for 
introducing this change to the Monitor is two-fold:  first, rules ensuring transparency vis-à-vis the public authorities 
and  the  rules  ensuring  transparency  vis-à-vis  the  public  at  large  serve  different  purposes.  The  former  enable  the 
competent authorities to effectively apply sector-specific regulation, including regulation restricting ownership and 
regulation that prevents interference with editorial independence.30 The latter enable citizens “to form an opinion on 
the value to be given to […] ideas and opinions disseminated by the media”,31 thereby contributing to building a more 
effective citizenry. Second, previous implementations of the Monitor have demonstrated that there are countries that 
have established rules covering both dimensions of transparency. The dichotomy is therefore meant to reflect this 
regulatory  reality;  in  cases  where  citizens  are  deprived  of  access  to  information  about  media  ownership,  risks  to 
media pluralism are expected to be higher than in cases where relevant rules have been enacted and are effectively 
implemented.32 

Based  on  the  information  submitted  by  the  country  teams,  in  most  countries,  risks  to  media  pluralism  arise  not 
because the legislator has not enacted the rules that seek to ensure transparency of ownership,33 but because the rules 
in question are not effectively implemented and/or only partially serve transparency. The reasons for this result vary. 
For example, in cases where the trail of proprietorship leads abroad, the regulator reportedly encounters difficulties 
in finding accurate information about the ownership structures of the media firm(s) concerned. Moreover, there are 
cases where firms operating in the media industry do not fall under the scope of sector-specific rules. 

28 
 In the case at hand, the CR4 ratio is obtained by summing the audience shares of the 4 most popular radio owners within the radio 
market. Calculation of the audience share is based on the standard or most widely accepted audience measurement system available in the 
country
29 
 Conclusions of the Council and of the Representatives of the Governments of the Member States, meeting within the Council, on 
media freedom and pluralism in the digital environment [2014] OJ C 32/4, paragraph 1. Retrieved from:  http://eur-lex.europa.eu/legal-content/
EN/TXT/PDF/?uri=CELEX:52014XG0204(02)&from=EN
30 
  See  Council  of  Europe.  Recommendation  No.  R  (94)  13  of  the  Committee  of  Ministers  to  Member  States  on  Measures  to  Promote 
Media  Transparency.  Retrieved  from:  https://wcd.coe.int/com.instranet.InstraServlet?command=com.instranet.CmdBlobGet&InstranetIm-
age=534799&SecMode=1&DocId=515710&Usage=2 (last accessed on 30/12/2016)
 Ibid.
31 
32 
 Reference is made to citizens since, if there are rules establishing the obligation of media firms to disclose their ownership structures 
to the public at large, regulatory authorities may still exercise their monitoring duties as they may thereby access this. However, if the legislator 
was limited to establishing the obligation of media firms to disclose their ownership structures to the public authorities, citizens would not 
necessarily be able to access information about who controls the sources they consult
33 
in 23 countries. Rules ensuring transparency vis-à-vis the public authorities have been adopted in 28 countries

 Based on the information submitted by the country teams, rules ensuring transparency vis-à-vis the public at large have been enacted 

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CENTRE FOR MEDIA PLURALISM AND MEDIA FREEDOM - Results

For example, in Cyprus, broadcasters are expected to publish in daily newspapers the names of the (natural or legal) 
persons who own more than 5% of the capital.34 In the Czech Republic, broadcasters may acquire a license only if they 
submit information about the identity of their shareholders and the members of their governing bodies.35 However, 
neither in Cyprus nor in the Czech Republic are firms in the press sector bound by similar duties. In all the above 
cases, knowledge about who controls the media in a given landscape is limited, or at least incomplete.36

Figure 1.2.2. Transparency of media ownership - Map of risks per country

As Figure 1.2.2 shows, three countries, namely, Greece, Luxembourg and the Czech Republic, score a high risk in this 
indicator. In Luxembourg, media firms are not bound by transparency obligations vis-à-vis the public authorities. In 
addition, while certain safeguards exist to ensure transparency vis-à-vis the public, these are not sufficiently robust, 
since media firms are merely bound by the obligation to disclose their initial ownership structures. That is to say, they 
are not obliged to inform the public about any changes in ownership that may take place after the company is formed. 
Contrary to Luxembourg, in Greece, rules to ensure transparency vis-à-vis the competent authority do exist, but they 
do not seem to achieve the objective that they were enacted to pursue. In a recent report, the Greek regulator for the 
television and radio broadcasting sector, ESR, pointed to a number of factors that adversely affect the accuracy of the 
ownership data that it holds and subsequently publishes. These factors involve hurdles of an administrative nature 
(other authorities are not bound by law to provide the ESR with relevant information), as well as budgetary constraints 
in preparing annual reports that include detailed ownership data.37

 Cyprus Radio Television Law 7(I) 1998, Article 20(1). Available (in Greek) at: http://www.cylaw.org/nomoi/enop/non-ind/1998_1_7/

 Broadcasting Act 231/2001 of May 17, 2001, on Radio and Television Broadcasting Operation and on Amendments to Other Acts, 

34 
full.html 
35 
Article 14(1)(a)-(d). Retrieved from: http://www.wipo.int/wipolex/en/text.jsp?file_id=197933 
36 
 For more information on the transparency of media ownership in Europe (or the lack thereof) see Craufurd-Smith, R. and Yolann-
da  Stolte  (2014).  The  Transparency  of  Media  Ownership  in  the  European  Union  and  Neighbouring  States:  Report  on  a  Project  by  Access  Info 
Europe and the Open Society Program on Independent Journalism. Retrieved from: http://www.research.ed.ac.uk/portal/files/18780552/Crau-
furd_Smith_Stolte_Transparency_of_Media_Ownership_in_the_EU_24sep2014.pdf (last accessed on 30/12/2016)
37 
tor.

 Based on the reply given by the Greek country team to MPM Variable 60, referring to the 2015 report produced by the Greek regulaa-

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HORIZONTAL CONCENTRATION OF MEDIA OWNERSHIP

Horizontal  (also  referred  to  as  ‘monomedia’)  concentration  of  ownership  mirrors  the  level  of  control  that  may  be 
exercised by (one or a few) media owners in a specific sector (e.g., the position held by a corporation providing retail 
broadcasting services in the audiovisual market concerned).

The indicator on Media ownership concentration (horizontal) is divided into sets of variables that seek to evaluate 
concentration of ownership in three sectors, namely audiovisual, radio, and newspaper publishing. It is worth making 
two remarks regarding the chosen sectors. First, as regards audiovisual media, the Monitor adopts the definition that 
is laid down in the Audiovisual Media Services Directive. In other words, the variables concerned cover both linear 
and non-linear audiovisual services.38 This approach is intended to reflect technological developments that have been 
dramatically altering traditional broadcasting markets (and the regulatory environment). Second, the sectors that have 
been selected represent the media in which Europeans demonstrate the most trust (European Commission, 2015a). 

Moving to a more detailed description of the Market Plurality area, six questions are posed with a view to assessing 
horizontal concentration of ownership in each sector. The first variable relates to establishing whether the country 
under examination has enacted any rules in order to prevent horizontal concentration in the sector concerned. These 
rules (where they exist) vary from country to country; for example, certain states limit the number of licenses that a 
media organization may hold, whereas other states set market (or audience) share thresholds that an individual media 
organization39  or  merged  entity  may  not  exceed.  Given  the  diversity  of  regulatory  models  across  the  EU  member 
states, this variable is drafted in broad terms in order to include all types of rules that are meant to address horizontal 
concentration.40 

The remaining five variables are concerned with evaluating the effective implementation of ownership restrictions, 
introducing two layers of assessment. The first layer comprises three variables that seek to establish whether there is a 
supervisory authority that is entrusted with monitoring compliance with the rules, whether the authority in question 
has the power to impose sanctions in cases of non-compliance, and whether the rules are effectively implemented. 
The second layer comprises two variables that attempt to establish the actual levels of concentration within the sector 
under scrutiny; these variables are based on the ‘four-firm (or Top4) Concentration Ratio’ (CR4), an index which has 
traditionally been used to measure market concentration and which is an indicator of the size of the four largest firms 
within a sector, compared with the performance of the entire sector. One variable seeks to establish the market shares 
that are held by the four largest firms, whereas the other variable seeks to establish the audience shares held by the 
four most popular firms in the sector under examination. Market shares are regularly used as an indication that allows 
competition and regulatory authorities to make preliminary evaluations of the market structure and of the relative 
importance of the various undertakings active on the market.41 Audience concentration is intended to provide a useful 
insight into how the audience is distributed across the various media outlets that are available in the market, an aspect 
which is not necessarily captured by market shares.

As Figure 1.2.3 shows, none of the countries that we examined scored a low risk in Media ownership concentration 
(horizontal).  More  particularly,  19  countries  score  a  high  risk,  and  11  a  medium  risk.  In  addition,  the  score  of 
this indicator is the highest among all other indicators that are included in the Monitor.42 It bears noting that the 
implementation of MPM2015 led to similar results (CMPF, 2016).

 Note that this is a substantial difference between media regulation and competition law. In EU and national competition law, it is not 

 See Directive 2010/13/EU of the European Parliament and of the Council of 10 March 2010 on the coordination of certain provisions 
38 
laid down by law, regulation or administrative action in Member States concerning the provision of audiovisual media services (Audiovisual 
Media Services Directive) [2010] OJ L 332/27, Recital (11) and Article 1(1).
39 
a violation to acquire and hold a dominant position, but only the abuse thereof
 For an overview of the different systems in the EU, see Valcke  P. (2009). From Ownership Regulation to Legal Indicators of Media Plu-
40 
ralism: Background, Typologies, and Methods. Journal of Media Business Studies, 6(3), 19- 42, and the National Reports on the Implementation 
of MPM2015, which are available at: http://monitor.cmpf.eui.eu/mpm2015/results/
41 
 See, e.g., European Commission, Guidance on the Commission’s enforcement priorities in applying Article 82 of the EC Treaty to abusive 
exclusionary conduct by dominant undertakings [2009] OJ C 45/2, Paragraph 13, and European Commission, Guidelines on the assessment of 
horizontal mergers under the Council Regulation on the control of concentrations between undertakings [2004] OJ C 31/3, Paragraph 14
42 

 In this round of the MPM, the implementation this indicator scored 71%

27

CENTRE FOR MEDIA PLURALISM AND MEDIA FREEDOM - Results

Figure 1.2.3. Media ownership concentration (horizontal) - Map of risks per country

These results raise concerns, but they are far from surprising. Media markets have a natural tendency to concentration, 
which is largely attributed to sector-specific economics. Characteristics that contribute to concentration include high 
entry  barriers,43  economies  of  scale,  and  the  two-sided  nature  of  advertising-based  media,  which  often  results  in 
‘winner-takes-all’ market structures. The susceptibility of media markets to consolidation is a widely studied topic 
and  an  industry  characteristic  that  has  been  confirmed  by  several  studies.44  Another  factor  which  has  driven  the 
concentration  of  media  ownership,  and  which  perhaps  deserves  more  attention  for  the  purposes  of  this  report,  is 
regulatory  leniency.  In  addition  to  a  tolerant  approach  to  mergers  and  acquisitions  in  the  media  sector,  the  trend 
towards relaxation and/or abolition of ownership restrictions that may be observed in a number of countries (e.g., the 
UK, Spain, the Netherlands, etc.) has enabled large media groups to expand throughout the EU and to thereby solidify 
their presence in a number of media markets. The argument that media policymakers are increasingly putting forward 
to justify this change is that the proliferation of sources and content that citizens can now engage with resolves some 
of the problems originating from ownership concentration that were pervasive in the traditional media landscape.45 
However, based on the data submitted by the country teams, it appears that revenues and/or audiences continue to 
concentrate around very  few providers, most notably around the long established companies which still occupy a 
central position in traditional media markets and which have successfully expanded into online markets.

Related to the above, in considering diverse regulatory and/or policy choices, potential or actual risks arising from 
ownership  concentration  should  be  considered  against  the  background  of  the  media  environment  concerned. 
For  example,  in  small  markets,  “it  is  economically  impossible  for  the  advertising  spend  to  sustain  more  than  a  few 
[providers]” (Commission Staff Working Document, 2007, p.8).  In such cases, adopting (and monitoring the effective 
implementation  of)  measures  that  seek  to  promote  content  and  exposure  diversity  and  establishing  impartiality 

 These include, for example, high sunk costs associated with the purchase of broadcasting licenses and/or the acquisition of premium 

43 
content, monetary or psychological switching costs that audiences are reluctant to bear, etc.
44 
 See, e.g., Ward D., Fueg O.C. and D’Arma A. (2010). Mapping Study of Media Concentration and Ownership in Ten European Countries. 
Retrieved from: http://77.87.161.246/wp-content/uploads/2013/08/A-Mapping-Study-of-Media-Concentration-and-Ownership-in-Ten-Euro-
pean-Countries.pdf. See also Autorità per le garanzie nelle comunicazioni, Indagine conoscitiva sul settore della raccolta pubblicitaria (Allegato 
A alla delibera 551/12/CONS). Retrieved from: http://www.agcom.it/documents/10179/1/document/bd184d98-cdcd-41e1-b141-9864dcfba8d6
45 
 See, for instance, Commissariat voor de media (2011). MEDIAMONITOR - The Dutch Media in 2010. The Dutch media regulator 
notes in this report that “a wave of deregulation in ownership rules seems to go through Europe. This also applies to the Netherlands, where 
the Temporary Act Media Concentration was repealed from the 1st January 2011. The increasing number of news sources is one of the reasons 
why concerns about media diversity gradually seem to move away from measures which aim to secure a minimal number of players in a market” 
[emphasis added]

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requirements  may  be  more  beneficial  than  stringent  ownership  restrictions  (Ibid.).  This  is  why  the  results  of  the 
Market Plurality area, in general, and the indicator for horizontal ownership, in particular, must be assessed alongside 
the  other  areas  of  the  instrument  that  introduce  variables  to  evaluate,  inter  alia,  access  to  media  by  minorities, 
policies  advancing  media  literacy,  fair  representation  of  political  viewpoints  in  news  programming  and  editorial 
independence.

CROSS-MEDIA CONCENTRATION OF OWNERSHIP AND COMPETITION ENFORCEMENT

This indicator consists of three sub-indicators. The first seeks to assess risks to media pluralism that arise from cross-
media concentration of ownership. Cross-media concentration reflects the level of control that may be exercised by 
one, or a few, media owners in a number of sectors within the industry (e.g., the position held by a media conglomerate 
in audiovisual and newspaper publishing markets). 

The Monitor distinguishes between horizontal and cross-media concentration for two main reasons: firstly, the fact 
that media content is very expensive to create but fairly cheap to deliver incentivizes media companies to expand 
into the same and/or other (succeeding and/or preceding) levels of the supply chain (Doyle, 2002), because it gives 
them the opportunity to exploit large economies of scale. Large economies of scale stimulate both horizontal and 
cross-media concentration, for they enable firms to rationalize resources and reduce transaction costs. Hence, the 
distinction is intended to mirror sector-specific economics and how the actors of the national market that is under 
examination have reacted to the pressure to consolidate. Secondly, certain countries have enacted distinct rules with 
which to address both types of concentration (e.g., Austria, Croatia, etc.), other countries have adopted regulation that 
deals exclusively with horizontal concentration (e.g., Poland), and some countries have no specific rules to prevent 
media concentration (e.g., Finland, Lithuania, etc.). In the case of countries that have enacted rules to address both 
types of concentration (and to the extent that the rules in question are well-designed and effectively implemented), the 
risks to media pluralism are expected to be lower. In addition to sector-specific economics, the distinction also seeks 
to accommodate the diversity of regulatory models across the EU. As with the indicator on horizontal concentration, 
risks originating from cross-media concentration of ownership are assessed by reference to whether specific safeguards 
apply, the existence of a supervisory authority, the effective implementation of the safeguards in question, and the 
structure of the markets involved. 

The other two sub-indicators seek to assess whether, and, if so, how, competition enforcement, that is, antitrust and 
merger control and safeguards to ensure proportionality of Public Service Media (PSM) funding, contribute to the 
enhancement  of  media  pluralism.  These  sub-indicators  form  parts  of  the  Monitor  for  the  following  two  reasons. 
Firstly, as previously mentioned, in many countries where rules to prevent horizontal concentration apply, there are 
no specific safeguards against cross-media concentration. In these regulatory environments, only general competition 
law applies. Yet, even if a (merger) transaction and/or unilateral conduct do not raise competition concerns, they may 
raise concerns over media pluralism. In certain countries these concerns are addressed by subjecting the outcome 
of  competition  enforcement  to  pluralism-related  considerations.  For  example,  in  certain  cases,  an  authority/actor 
that  is  not  structurally  linked  to  the  competition  authority  may  intervene  if  a  concentration  that  is  acceptable  on 
competition grounds is problematic for media pluralism. For instance, in Ireland, Part 4 of the 2014 Competition 
and Consumer Protection Act outlines a multi-stage process which, in addition to the Competition and Consumer 
Protection  Commission,  involves  the  Minister  for  Communications  and,  under  certain  circumstances,  the 
Broadcasting Authority of Ireland (BAI). The process in question may lead to a prohibition decision on the grounds 
that the notified transaction harms media pluralism.46 In other cases where sector-specific safeguards do not apply, 
competition authorities (e.g., Latvia, the Netherlands, Spain, etc.) reportedly take account of pluralism when adopting 
a decision that may affect media markets.

Secondly, the Political Independence area of the Monitor comprises variables that deal with Public Service Media 
(PSM). Moreover, the CR4 concentration ratio takes account of PSM organizations, which, in several cases, do not 
generate advertising revenues because they are mainly, if not exclusively, funded by public resources in order to serve 
objectives that are in the general interest. In view of the above, the inclusion into the Market Plurality area of variables 
concerning the proportionality of PSM funding sheds further light on issues that are associated with the role of PSM 
in the media system in which they operate. For example, risks arising from concentration of private media ownership 
may be mitigated if an independent and adequately funded PSM organization that is bound to provide a balanced 
and varied offer is among the most popular providers in a given media landscape. Examples of safeguards ensuring 
proportionality of PSM funding depend on the services offered by the organization(s) concerned and may include 
the development of commercial activities that are in line with market principles (e.g., keeping arm’s length relations 
with commercial subsidiaries, undertaking commercial investments that are in line with the market economy investor 

46 

 The Irish Competition and Consumer Protection Act is available at: http://www.irishstatutebook.ie/eli/2014/act/29/enacted/en/html

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principle, etc.),47 and transparency obligations (e.g., the maintenance of separate accounts for public service and non-
public service activities) in order to ensure that no cross-subsidization takes place.48

Figure 1.2.4. Cross-media concentration of ownership and competition enforcement - Map 
of risks per country

As Figure 1.2.4 shows, 11 countries, namely Belgium, the Czech Republic, Finland, Lithuania, Romania, Spain, Malta, 
Montenegro,  Bulgaria,  Luxembourg,  Poland,  scored  high  risk.  11  countries  (the  Netherlands,  Hungary,  Austria, 
Croatia,  Slovakia,  Slovenia,  Denmark,  Estonia,  Latvia,  Sweden,  Turkey  )  scored  medium  risk.  The  remaining  8 
countries under consideration, that is, Ireland, Portugal, Greece, France, Italy, the United Kingdom, Germany and 
Cyprus, scored low risk. 

Most countries that scored low risk 49 have established safeguards that seek to address concerns related to the issues 
falling  under  the  aforementioned  sub-indicators.  For  example,  the  German  legislator  has  enacted  specific  rules  to 
limit cross-media ownership concentration. More particularly, the Interstate Broadcasting Treaty Article 26(2) lays 
down that: 

“[i]f the services attributable to an undertaking reach an annual average audience share of 30 per cent of all 
viewers, dominant power of opinion shall be assumed to [have been acquired]. The same applies for an audience 
share of 25 per cent if the undertaking holds a dominant position in a media-relevant related market.”50 

For instance, in cases where a television broadcaster holds a dominant position in an upstream content production 
market, the threshold at which the firm is deemed to acquire significant opinion-forming power is lower. In such cases, 
the media organization in question may be required to divest assets as a means to reduce the influence it may exercise 
over  audiences.51  As  regards  competition  enforcement,  the  Act  on  Restraints  of  Competition  stipulates  that  firms 

 Communication on the application of State aid rules to public service broadcasting (the Broadcasting Communication) [2009] OJ C 

47 
257/1, paragraph 93
 Ibid., Paragraphs 60 et seq. 
48 
49 
 For example, in Ireland, which scored 29%, there are rules that seek to ensure that media mergers are assessed on both competition 
and pluralism grounds, as well as rules that seek to ensure the proportionality of PSM funding. However, there is no regulation restricting the 
cross-media concentration of ownership  
50 
grundlagen/Gesetze_aktuell/15_RStV_english_01-01-2013.pdf 
51 

  Interstate  Treaty  on  Broadcasting  and  Telemedia.  Available  at:  http://www.die-medienanstalten.de/fileadmin/Download/Rechts-

 Ibid., Article 26(4)

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active in newspaper and magazine publishing are subject to stricter merger notification requirements, if compared to 
firms operating in other sectors of the economy.52 Furthermore, there are safeguards to ensure proportionality of PSM 
funding. For example, while German PSM are entitled to offer commercial services (e.g., merchandising, sponsorship, 
etc.),  the  Interstate  Broadcasting  Treaty  lays  down  that  such  services  must  be  provided  by  legally  independent 
subsidiaries.53 

Countries that scored a high or medium risk have not enacted rules to address concerns pertinent to at least two of the 
three sub-indicators that are examined above. For example, based on the information provided by the country teams, 
in most of the jurisdictions that were examined, there exist safeguards to ensure proportionality of PSM funding, 
however, no rules have been established to address cross-media concentration of ownership through either a sector-
specific instrument or general competition law (e.g., Spain, Bulgaria, Romania, Finland, etc.). This regulatory reality 
may be particularly damaging to media pluralism because competition enforcement alone is usually insufficient to 
remedy concerns arising from the acquisition by a media firm of significant opinion-forming power. 

Based on the data submitted by the country teams, regulatory environments where no cross-media ownership exist 
and competition enforcement does not take sufficient account of media pluralism, is prevalent across the EU Member 
States. With respect to the two candidate countries, namely Montenegro and Turkey, we make the following remarks: 
In Montenegro, rules exist that restrict cross-media concentration of ownership, but the legal system does not envisage 
sector-specific competition enforcement that would accommodate concerns relating to media pluralism. Moreover, 
based on information submitted by the country team, safeguards to ensure proportionality of PSM funding have been 
included in the draft amendments to the law regulating public broadcasting services (e.g., keeping separate accounts 
for public and commercial services to ensure that no cross-subsidization takes place), however, at the time of writing, 
these  amendments  have  not  been  adopted  by  Parliament.  In  Turkey,  measures  to  ensure  proportionality  of  PSM 
funding do not currently apply. Moreover, rules to limit cross-media ownership have not been enacted, but related 
risks may be mitigated by sector-specific competition enforcement. It should be noted that the proportionality of PSM 
funding is strongly related to the EU acquis in the area of State aid control.54 Montenegro, which is at an advanced 
stage  of  the  accession  process,  has  introduced  the  aforementioned  amendments  as  part  of  its  efforts  to  align  aid 
schemes and measures with the State aid rules.55 With respect to Turkey, negotiations on aligning national legislation 
with EU law relating to competition have not yet started.

COMMERCIAL AND OWNER INFLUENCE OVER EDITORIAL CONTENT

Diversity of ownership is the dimension that has received the most attention (Valcke, 2011) in regulation that supports 
media pluralism across the European Union.56 Ensuring that significant opinion-forming power is not concentrated 
in the hands of a few has been (or, at least until recently, was) a priority because of the presumed negative effects of 
concentration on media pluralism. To quote the European Commission, “concentration of ownership […] may result 
in a skewed public discourse where certain viewpoints are excluded or underrepresented” (Commission Staff Working 
Document, 2007, p. 5).

Saying  that  every  media  concentration  is  always  only  harmful  to  pluralism  is  not  accurate.  Depending  on  the 
circumstances, a concentration may benefit media pluralism. For example, if a mainstream publisher acquires a niche 
publisher that is on the verge of bankruptcy, or headed for some serious financial difficulties, an outlet that offers 
alternative content survives (Bania, 2015). A merger between two local broadcasters may lead to the creation of a 
strong domestic player with a program offer that is different from the generic programming of competing multinational 
broadcasters (Bania, 2015). However, a concentration is most likely to have negative consequences for pluralism, for 
it increases the incentive to crowd out competing content suppliers. For example, a vertically integrated firm with 

 German Act against Restraints of Competition, Section 38. Another provision of the same instrument that is relevant here is Section 
52 
36, which provides that, in principle, a concentration which would significantly impede effective competition must be prohibited by the Ger-
man competition authority, the Bundeskartellamt. However, a derogation applies if, despite the fact that the dominant position of a newspaper 
or magazine publisher acquiring a small or medium-sized newspaper or magazine publisher is strengthened, it is proven that the existence of 
the publisher that is acquired would be jeopardised without the concentration. The Act is available at: http://www.gesetze-im-internet.de/en-
glisch_gwb/ 
 Interstate Treaty on Broadcasting and Telemedia, Article 16a(1)
53 
54 
 The EU acquis in this area has been mainly developed through the European Commission’s decisional practice in the field of State 
aid control. More particularly, the European Commission has imposed on State authorities across Europe in order to introduce into national 
legislation the safeguards to ensure proportionality of funding. For more information see Communication on the application of State aid rules 
to public service broadcasting (the Broadcasting Communication) [2009] OJ C 257/1. The list of the relevant decisions that the European Com-
mission has adopted in this area is available at: http://ec.europa.eu/competition/sectors/media/decisions_psb.pdf
55 
sites/near/files/pdf/key_documents/2014/20141008-montenegro-progress-report_en.pdf
56 
Background, Typologies, and Methods. Journal of Media Business Studies 6(3), 19-42

 For an overview of the different systems, see Valcke, P. (2009). From Ownership Regulation to Legal Indicators of Media Pluralism: 

 See European Commission (2014). Montenegro Progress Report. Retrieved from: https://ec.europa.eu/neighbourhood-enlargement/

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access to a valuable input is incentivized to foreclose other content providers, potentially harming supply diversity 
(Bania, 2015). An integrated media organization may also adversely affect content diversity, most notably through 
decisions relating to the use of the outlet’s resources. For example, horizontally integrated newspapers tend to use the 
same content across all titles held in common ownership in order to reduce the costs incurred in the newsgathering 
process. (Doyle, 2002).

The  above  examples  concern  the  impact  of  individual  transactions  on  media  pluralism.  As  regards  the  impact  of 
concentrated market structures, there are studies that found that the more concentrated the sector, the less pluralistic 
the media landscape (Bania, 2015).57 There are also studies that did not manage to identify a relationship between 
ownership  concentration  and  media  pluralism,  especially  content  diversity,  in  quantitative  terms  (Bania,  2015).58 
However,  even  in  the  latter  case,  there  are  qualitative  parameters,  and,  in  particular,  parameters  that  determine 
whether the power that stems from ownership is used to influence editorial content, which are key to understanding 
whether  concentration  harms  pluralism.  For  example,  do  owners  interfere  with  journalistic  autonomy  by  making 
day-to-day editorial decisions or by creating a spirit of obedience in order to advance the commercial interests of the 
organization?

In  view  of  the  above,  MPM2016  includes  an  indicator  that  seeks  to  assess  the  risks  to  media  pluralism  that  arise 
from the qualitative dimension of ownership concentration, that is, commercial influence over editorial content. To 
this end, variables have been introduced to evaluate a given media landscape in the light of a number of practices 
that may undermine editorial freedom. More particularly, the indicator includes variables that assess, inter alia, the 
mechanisms granting social protection to journalists in cases where ownership and/or the editorial line change, laws 
prohibiting advertorials, regulation59 stipulating the obligation of journalists and/or media outlets not to be influenced 
by commercial interests and, more generally, whether the media in the landscape concerned are governed by practices 
through which commercial interests dictate editorial decisions.

Based on the data submitted by the country teams, 12 countries scored a high risk (Bulgaria, the United Kingdom, 
Latvia, Slovenia, Montenegro, Malta, Romania, Turkey, Poland, the Czech Republic, Finland, Sweden), 14 a medium 
risk (Belgium, Croatia, Spain, Greece, Lithuania, Luxembourg, Hungary, Ireland, Slovakia, Estonia, Cyprus, Germany, 
Austria and Italy), and four a low risk (Denmark, France, Portugal and the Netherlands) (see Figure 1.2.5).

57 
  Referring  to  Humphreys,  P.  (1996).  Mass  media  and  media  policy  in  Western  Europe.  Manchester:  Manchester  University  Press; 
Einstein, M. (2002). Media Diversity: Economics, Ownership, and the FCC. New York: Routledge, and La Porte Alfaro, M. T. and Teresa Sabada 
(2001). Globalization of the Media Industry and Possible Threats to Cultural Diversity – A Study prepared for the European Parliament. Final Study. 
Working document for the STOA Panel
58 
 Berry, S. and Joel Waldfogel (2001). Do mergers increase product variety? Evidence from radio broadcasting. Quarterly Journal of 
Economics, 116, 1009-1025 and Ward, D. (2006). Final Report on the Study Commissioned by the MC-S-MD - The Assessment of Content 
Diversity in Newspapers and Television in the Context of Increasing Trends Towards Concentration of Media Markets, MC-S-MD (2006) 001, 
4. Strasbourg: Council of Europe
59 

 This also includes self-regulation

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Figure 1.2.5. Commercial and owner influence over editorial content - Map of risks per 
country

The reasons for which 12 countries scored a high risk are manifold, and they vary from one case study to another. For 
example, in Poland, the Press Act contains a provision that binds journalists to respect the editorial line of the title 
that employs them, and any form of action that infringes this provision may be deemed to be a violation of employee 
duties.60 Contrary to Poland, Turkey has safeguards in place to ensure social protection for journalists in cases where 
there is a risk that their editorial freedom will be undermined. For example, Law no. 5953 on the Regulation of the 
Employment Relationships in the Journalistic Profession contains a conscience clause whereby journalists who decide 
to terminate their employment contract on the grounds that changes in the editorial direction of the publication have 
taken place are entitled to compensation. However, journalists are routinely employed under the provisions of general 
Labour Law, a practice which deprives them of the special rights granted to them by Law no. 5953.61 It should also 
be noted that 40% of the countries under examination scored a high risk in the variable that assesses whether there 
is  systematic  influence  or  there  are  systematic  attempts  to  influence  editorial  decisions  and,  by  extension,  content 
output; relevant practices range from appointing like-minded editors to promoting a culture of self-censorship so that 
audiences are not exposed to diverse viewpoints or inconvenient truths that would harm the commercial interests of 
the organization.62

A  remark  that  needs  to  be  made  in  relation  to  this  indicator  concerns  the  correlation  (or  lack  thereof)  between 
commercial influence and ownership concentration. Based on the information submitted by the country teams, there 
are  countries  which  scored  a  high  risk  in  the  indicator  assessing  Media  ownership  concentration  (horizontal)  as 
well as a high risk in the indicator evaluating Commercial and owner influence over editorial content (e.g., Bulgaria 
and the UK). In such cases, it is submitted that the legislator and the industry need to consider setting standards to 

 See Article 10. 2. and 3 of the Press Act of January 26, 1984
60 
61 
 Reply provided by the Turkish team, referring to Kurban, D. and Celen Sözeri (2012). Caught in the wheels of power: The Political, 
Legal and Economic Constraints on Independent Media and Freedom of the Press in Turkey, 54. Retrieved from: http://tesev.org.tr/wp-content/
uploads/2015/11/Caught_In_The_Wheels_Of_Power_The_Political_Legal_And_Economic_Constraints_On_Independent_Media_And_
Freedom.pdf (last accessed on 29/12/2016)
62 
 The above provisions, and/or practices, must be read against principles referred to in the European Parliament Resolution of 21 May 
2013 on an EU Charter on standard settings for media freedom across the EU [2016] OJ C 55/5.  For example, the resolution lays down that 
‘journalists should be free from the pressure of owners, managers and governments, as well as from financial threats’, and underlines the impor-
tance of ensuring the independence of journalists, both from internal pressures from editors, publishers or owners, and, externally, from political 
or economic lobbies or other interest groups. Retrieved from: http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52013IP0203 
(last accessed on 29/12/2016) 

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mitigate risks to media pluralism, for the results reflect that there is no effective framework in place to address either 
the quantitative or the qualitative dimensions of ownership concentration. Other countries, such as Denmark and 
the Netherlands, scored a high risk in horizontal concentration but a low risk in commercial influence. This indicates 
that the country and/or the industry acknowledge that media markets have a tendency to concentration and, while 
ownership restrictions may not apply, they have taken action to address concerns that may arise as a consequence of 
acquiring significant opinion-forming power. 

MEDIA VIABILITY 

As previously mentioned, policy and regulation that aim to address risks to media pluralism largely depend on the 
specific characteristics of the market concerned. That is to say, one size does not fit all. In view of this particularity, 
MPM2016 has introduced an indicator which seeks to assess the viability of the media landscape being examined. 
Drawing from relevant work undertaken by UNESCO, the rationale for this indicator is that “domestic […] conditions 
must provide a supportive environment for the emergence, development, and continuance of […] media, and [that] the 
organizations themselves must act in ways that promote their survival”.63 

Assessing  media  viability  is  a  complex  endeavour  that  involves  an  analysis  of  the  broader  economic,  social  and 
political environments  in  which  media organizations operate.64 The Monitor attempts to grasp certain parameters 
that determine media sustainability, with a focus on market developments. More particularly, this indicator mainly 
assesses market revenue trends in four different sectors, namely, television, radio, newspaper publishing and online 
advertising.

Figure 1.2.6. Media viability - Map of risks per country

As shown in Figure 1.2.6, in the MPM2016 the indicator on Media viability does not score a high risk, but scores a 
medium risk in 14 countries and a low risk in 16 countries.

The  sector  that  appears  to  have  been  affected  the  most  over  the  past  two  years  is  newspaper  publishing.  More 
particularly, in the overwhelming majority of the markets examined, newspapers have been suffering a significant 
revenue decline in these past two years. This is largely attributed to advertisers preferring behavioural targeting, which 

63 
64 

http://www.unesco.org/new/fileadmin/MULTIMEDIA/HQ/CI/CI/pdf/IPDC/ipdc59_Media_viability_indicators.pdf, p. 2
 Ibid. See also http://www.dw.com/en/the-long-term-sustainable-media-viable-media/a-18670796 

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means that newspapers now have to compete with a much wider range of firms, including real estate, dating and job 
recruitment portals (Joint Research Center, 2012). Moreover, due to the vast amount of information that is currently 
available  on  the  Internet  for  free,  consumers  are  not  willing  to  pay  for  online  news  content  (ibid.).  This  revenue 
trend, which emerged in the late 1990s (ibid.), is particularly worrisome considering the important contribution that 
newspapers make to news dissemination. As Ofcom has so eloquently put it, newspapers “provide space for opinion, 
in-depth  analysis  and  a  reflection  on  recent  events  […]  helping  citizens  understand  issues”  (Ofcom,  2012,  p.14).  In 
addition to the role that newspapers play in shaping views on matters of common concern, the revenue losses that this 
sector has been experiencing must be considered against the fact that more than one third of Europeans continue to 
read the paper every day, or almost every day (European Commission, 2015a). 

Online advertising is undoubtedly the area that has been performing the best, with most markets having documented 
an increase in revenues in this sector. Unfortunately, we may not draw any safe conclusions on the amount of advertising 
revenue that migrated from newspapers to advertising-based online content providers. This is partly linked to how 
the indicator for media viability is structured65 and partly associated with the scarcity of information about the impact 
of  online  competition  on  newspaper  publishing.  Related  to  the  above,  a  difficulty  that  is  particularly  acute  in  the 
effort to evaluate revenue trends is the lack of data that indicates how the sectors we examined performed. In many 
countries, regulators and statistical authorities alike do not engage in collecting relevant information. This is especially 
problematic, because it deprives policymakers of the ability to assess the viability of a given market and to ultimately 
decide whether concrete initiatives must be taken to support the affected sector.  

The aforementioned variables sought to identify trends in the total revenues generated by companies operating in a 
given sector. By total revenues we mainly refer to revenues generated through traditional streams, including advertising 
revenues,  revenues  from  newspaper  circulation  and  revenues  from  the  sale  of  media  rights.  Yet,  the  indicator  for 
media viability also includes a variable that seeks to assess whether media companies operating in the market under 
examination are currently developing non-traditional revenue streams. The variable in question is essentially meant 
to  evaluate  whether  media  organizations  attempt  to  address  the  challenges  posed  by  digital  technologies  and  the 
financial crisis by undertaking initiatives that would allow them to access alternative financial resources. According 
to the information submitted by the country teams, several projects are currently underway. For example, in Austria, 
numerous media firms are developing applications for tablets and smartphones. Moreover, to attract or consolidate 
readership, Austrian newspapers have introduced ‘package subscriptions’ for their print and digital editions. In Belgium, 
certain outlets have used crowdfunding in order to boost revenues. For instance, a French-language magazine has 
engaged in crowdfunding in order to support investigative journalism projects. In Bulgaria, the dailies Stabdart and 24 
Chasa and Bulgaria On Air have developed event management initiatives which generate sponsorship and advertising 
revenues.  In  the  Czech  Republic,  certain  outlets  have  introduced  podcasts  of  their  news  stories.  In  Germany,  the 
television  broadcaster  ProSiebenSat.1  has  designed  a  ‘media  for  equity’  strategy  through  which  businesses  receive 
advertising space instead of cash for their stock. What the above examples illustrate is the diversity characterizing the 
initiatives that media firms across the EU have been developing in order to generate revenue through non-traditional 
streams, thereby eventually re-inventing themselves. However, we are not in the position to say with certainty whether 
the initiatives concerned have achieved their goal. This is attributed to the scarcity of information about the accrued 
benefits  and  the  fact  that  it  is  relatively  soon  to  draw  any  safe  conclusions  about  their  role  in  contributing  to  the 
creation of a viable business model. 

65 
crease in one sector was the result of a revenue increase in another

 The variables assess whether revenues in each of the four sectors examined have increased, without assessing whether a revenue dee-

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1.3 ANALYSIS OF POLITICAL INDEPENDENCE 

The area of Political Independence was designed to assess the risks of political interference on five different levels: on 
the level of media system, media organizations, newsroom, content and in particular in regard to public service media. 
Five indicators focus on examining the existence and effectiveness of regulatory safeguards against political bias and 
political control over media outlets, news agencies and distribution networks. They also concern with the existence 
and effectiveness of self-regulation in ensuring editorial independence. Moreover, they seek to evaluate the influence 
of state (and, more generally, of political power) over the functioning of the media market, and the independence of 
public service media.

Five indicators that are related to Political Independence are:

•  Political control over media outlets

•  Editorial autonomy

•  Media and democratic electoral process

• 

• 

State regulation of resources and support to media sector

Independence of PSM governance and funding

The comparative analysis of the risks for political independence reveals that a vast majority of the countries examined 
score a medium risk in the area (namely eighteen, see Figure 1.3.1). Eight are at low risk (Sweden, France, Germany, 
Portugal,  Belgium,  Denmark,  the  Netherlands,  and  United  Kingdom),  and  four  are  found  to  be  at  high  risk  from 
political influences over their media systems - two of which are EU member states (Hungary and Slovenia), and two 
are candidate countries (Montenegro and Turkey).

Figure 1.3.1. Political Independence area – Map of risks per country

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Hungary is the only EU country that scores high risks for all five indicators within the area of Political Independence, 
with most concerns being related to the indicators on State regulation of resources and support to the media sector, and 
Independence of PSM governance and funding. For the two candidate countries, Montenegro and Turkey, political 
capture over media represents a strong burden on their way to ensure more independence and media freedom as an 
essential precondition of a healthy democracy. Particularly at risk are both media and journalists in Turkey where 
government already had a record of censoring or completely denying the access to social media sites,66 but after the 
attempted military coup in July 2016, the state of emergency was declared, which then created the environment of 
oppression of media freedoms. Dozens of media outlets were shut down and, as of 21 November 2016,67 at least 125 
journalists were imprisoned with accusations of anti-state activity. 

On  the  other  side  of  the  spectrum,  there  are  four  countries  that  score  a  low  risk  across  all  indicators  of  political 
independence: Belgium, Denmark, Portugal and Sweden. According to Hallin and Mancini’s Three Models of Media 
and Politics (2004), Belgium, Denmark and Sweden belong to the Democratic Corporatist Model that is, among other 
things,  characterized  by  strong  professionalization  and  self-regulation  of  journalism.  Evidence  emerging  from  the 
Monitor confirms efficiency of self-regulation in these countries, which then serves as a shield to protect media and 
journalism from undue political influence. Similar as in the last year’s pilot Monitor (MPM2015), Portugal was again 
assessed as being at low risk from political influences. This is partly due to recent changes in media legislation (in 2014) 
that have de-politicised the appointment procedures for PSM. As indicated by the country team, this new legislation 
already shows improvements. Namely, despite a recent change of government the PSM administration appointed by 
CGI (Conselho Geral Independente - RTP’s Independent General Council), during the previous government remains 
in power.

Figure 1.3.2. Political Independence area - Averages per indicator 

As shown in Figure 1.3.2, in the area of Political Independence the highest concerns across examined countries are 
related with indicators on Political control over media outlets and Editorial autonomy, however, still in a medium risk 
band. The indicator Independence of PSM governance and funding on average also scores a medium risk, mainly 
due to the fact that many countries reported lack of safeguards to ensure autonomy and political independence in the 
appointments of managing and board functions of public service media. Another source of risk, on average medium, 
is the allocation of state subsidies and state advertising if there are no fair and transparent rules, or no rules at all. 

66 
67 

 See for example: http://www.bbc.com/news/world-europe-32204177 
 Reported by the country team. For more information, please see Inceoglu et al. (2017)

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This issue is captured within the indicator on State regulation of resources and support to media sector. And, finally, 
the only indicator that on average scores a low risk across 30 European countries is Media and democratic electoral 
process. Low risk in this case reflects the situation in which most countries have a specific regulation that imposes rules 
on fair representation of political viewpoints in news and informative programmes on PSM channels and services, in 
particular during electoral campaigns. However, one should keep in mind that the existing legislation, in most cases, 
does not regulate campaigning activities online. Considering that social media are becoming a main source of news 
(Newman et al., 2016), future implementations of the MPM should take a closer look at electoral campaign practices 
in an online (social) media environment.

POLITICAL CONTROL OVER MEDIA OUTLETS

This  indicator  assesses  the  availability  and  effective  implementation  of  regulatory  safeguards  against  control  over 
media  by  politicians,  taking  into  consideration  the  diversity  of  European  media  systems  and  cultural  differences 
among  observed  countries.  Hence,  the  composition  of  the  MPM  variables  allows  countries  that  have  long  lasting 
traditions of arm’s length principle between media and politics to score lower levels of risk, even if they do not have 
specific legislation to prevent political control over media. The indicator consists of six sub-indicators: the first relates 
to  the  general  rules  on  Conflict  of  interests,  while  the  other  five  aim  to  capture  Political  control  over  audiovisual 
media, radio, newspapers, news agencies, and distribution networks. For the purpose of the MPM and this specific 
indicator, control is understood as broader than ownership and it includes both direct ownership and indirect control. 
Indirect control implies that parties, partisan groups or politicians are not directly involved in the ownership structure 
but they exercise their power through intermediaries (e.g. family members). The conflict of interests is defined as an 
incompatibility of government office with media ownership (Djankov et al., 2003). The MPM, therefore, takes into 
consideration the existence of rules that prohibit media proprietors from holding government office, as well as the 
situation in practice. According to the public choice theory, a situation in which the media ownership is related to 
government, which manages many resources important for media, might undermine both democracy and markets 
(Dajnkov  et  al.  2003).  At  the  same  time,  public  interest  theory  sees  information  as  a  public  good  that  should  be 
available to everyone, and the government is assumed to be a neutral arbiter if private media outlets serve mainly 
commercial or political interests (Dajnkov et al., 2003). Therefore, transparency of media ownership and availability 
of information on political affiliation of media owners is a key precondition to assess the extent of politicisation of 
control over media.68 

68 
Chapter 1.2.

 The transparency of media ownership and the rationale of its measurement are observed in more detail in the area of Market Plurality, 

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Figure 1.3.3. Political control over media outlets -  Map of risks per country

Overall, six countries are assessed as being at low risk from the Political control over media outlets, namely, Portugal, 
France,  Belgium,  Sweden,  Denmark,  and  United  Kingdom.  Another  ten  are  assessed  as  being  at  medium  risk 
(Germany, Greece, Lithuania, Cyprus, Estonia, Ireland, Finland, the Netherlands, Montenegro and Spain), while the 
remaining 14 score a high risk. Very often risks emerge from the lack of transparency of media ownership.69 If the 
public is not aware of who owns the media, it is also unclear whether or not this person/organisation has a political 
affiliation  or  agenda.  Because  of  the  deficiency  of  evidence  this  indicator  relies  to  a  large  extent  on  the  Group  of 
Experts procedure.70 Namely, four variables that assess the extent of political control over media in practice, employ 
the peer review procedure to maximize the accuracy of evaluations. 

As  already  mentioned  above,  this  indicator  consists  of  six  sub-indicators,  with  the  one  on  Political  control  over 
newspapers being the most at risk (on average across countries: 65% -  medium risk). The reason for this lies primarily 
in the absence of regulation that contains limitations to direct and indirect control of newspapers by party, partisan 
group or politicians. Whether press should be regulated is a matter of long lasting debate, since, somehow, there is a 
contradiction in regulating an institution that is supposed to serve as watchdog of political powers in a democratic 
society. Data collected through the MPM show that a large majority of countries in Europe do not have legislation that 
seeks to prevent excessive control of newspapers by politicians (26 out of 30), and more than half of countries (16) 
reported the existence of some level of political control. For example, the most obvious conflict of interest in the Czech 
Republic is currently the case of the Deputy Prime Minister Andrej Babiš, whose conglomerate holding company 
Agrofert  owns  several  significant  Czech  media,  including  two  quality  newspapers  (Štětka  et  al.,  2017).  In  Latvia, 
while noting that the largest part of leading newspapers are controlled by politicians or the individuals that are linked 
with them, the country team also observed the multiplication of free newspapers issued by the local governments, 
which then attempt to represent the interests of the local politicians. Considering that Latvia is a small market, the 
interference of local governments decreases the business opportunities for the independent local media outlets and 
sets the limits of the availability of a free press for the local media audiences.

The  sub-indicator  that  scores  the  second  highest  risk  addresses  news  agencies  (on  average  across  countries:  59% 
- medium risk).  According to the MPM methodology, if at least one of the leading news agencies in a country is 
owned  and/or  funded  by  the  state,  the  risk  is  medium  or  high.  It  may  be  independent  in  practice  at  the  time  of 
assessment, but the MPM tries to capture potential threats and risks, which do exist if the agency is controlled by 

69 
70 

See Chapter 1.2 of this Report
 For more information on the Group of Experts procedure see the Methodology part.

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the state and there are no other mechanisms to mitigate that influence. Countries that score the highest risks in this 
regard are Greece, Hungary, and Turkey. Greece joined the list of highest risk countries because of the government’s 
influence over the only Greek-based national news agency: Athens-Macedonian News Agency. Organized as a public 
company, the agency is financed through the state budget and the Public Investments Programme. It is governed by 
the General Assembly composed of representatives of the two relevant Ministers and the government is also involved 
in the appointments procedures of the Management Board.

Political control over audiovisual media represents a medium or a high risk in more than two thirds of countries, 
including EU candidates Montenegro and Turkey that are in a high risk band, as well as Slovakia, Poland, Hungary, 
Croatia, Bulgaria, Austria, Slovenia, Romania, Malta, Latvia and Italy. The results mainly reflect the fact that most 
countries  do  not  have  legal  safeguards  against  extensive  direct  or  indirect  political  control  over  TV  channels  and 
services, but also the lack of regular monitoring and research on this topic. Such is the case with Austria. No TV 
or radio station is owned by a specific political group, and the share of newspapers owned by politically affiliated 
entities is below 0.5% (Seethaler et al., 2017). However, the country team noted that some owners may have political 
affiliations, but no research on this is available, and local experts have criticised the lack of clear independence of PSM 
from political entities. A specific case among the EU member states is Malta. In this Mediterranean island country 
major political parties own television and radio stations, as well as newspapers. Local experts, however, claim that this 
is more fair than the subtle political influence in other European countries and that the presence of both major parties 
contributes to external pluralism. It is believed that the audience is well aware of the bias in these media’s content.

The analysis shows that radio and distribution networks are the least susceptible to political control. 

EDITORIAL AUTONOMY

The  indicator  on  Editorial  autonomy  is  designed  to  assess  the  existence  and  effectiveness  of  regulatory  and  self-
regulatory measures that guarantee freedom from political interference in editorial decisions and content.71 In order 
to exercise their social role as watchdog of society and provider of information that serves public interest and debate, 
journalists have to be able to act independently from undue influences. In this regard, effective self-regulation in the 
form of codes of conduct, codes of ethics or editorial statutes, is of particular importance, as well as the appointments 
and  dismissal  procedures  of  editors  in  chief.  The  importance  of  co-  and  self-regulation  as  a  complement  to  the 
legislative and judicial and/or administrative mechanisms is emphasized in the Audiovisual Media Services Directive 
(2010). The pluralism of the media itself is not sufficient to ensure freedom of information if independence is not 
guaranteed. Therefore, the Council of Europe’s Recommendation on media pluralism and diversity of media content 
(CM/Rec(2007)2)  highlights  that,  while  encouraging  the  media  to  supply  the  public  with  a  diverse  and  inclusive 
media content, member states should also respect the principle of editorial independence. 

71 
cial and owner influence over editorial content

 Market Plurality area contains an indicator that aims to measure the risks of  commercial influence over editorial content - Commerr-

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Figure 1.3.4. Editorial autonomy - Map of risks per country

The results of the MPM2016 suggest that editorial autonomy is still at risk in most observed countries. This is one of the 
indicators that scores the highest risk, not only in the area of Political Independence but in the entire MPM.72 A high 
risk score is recorded for 12 countries; 11 are in the medium risk band, and for seven countries Editorial autonomy 
is  at  low  risk. The  indicator  is  composed  of  two  sub-indicators:  one  focusing  on  specific  safeguards  and  practices 
related to the appointments and dismissals of editors-in-chief; and the other one capturing existence and effectiveness 
of self-regulatory measures, such as journalistic codes and codes of ethics, that stipulate editorial independence in 
both traditional and online news media. On average, the sub-indicator on Editor-in-chief is more at risk (see Figure 
1.3.5) than the one on Self-regulatory measures. The former sub-indicator is a novelty of MPM2016, giving the special 
focus to a publication’s editorial leader, responsible for editorial policies and operations, which makes her/him the 
first line of defence against political interference with editorial autonomy. The results show that a vast majority of 
countries have no common regulatory safeguards to guarantee autonomy when appointing and dismissing editors-
in-chief. Exceptions are Portugal and Germany. Portuguese Television and On-demand Audiovisual Media Services 
Law (Law no. 27/2007, Article 35 on Editorial responsibility and autonomy 4,5,6) explicitly requires consultations 
with the editorial board prior to the appointment and dismissal of the persons responsible for the news content; and 
these posts are to be exercised with editorial autonomy. In Germany, the law (ZDF-Staatsvertrag, 2016) establishes an 
indirect control mechanism for PSM by reducing the political influence in the composition of the broadcasting boards 
and  boards  of  administration,  since  these  boards  are  taking  part  in  decisions  regarding  the  director  (Intendant), 
who decides about appointing and dismissing the chief editors. By contrast, the media laws in Slovakia do not even 
mention editors-in-chief, and the country team noted that the interference is mainly in PSM. PSM is also highly at 
risk in Croatia where almost every change of government entails editorial changes and reassignments at the PSM 
(Croatian Radiotelevision - HRT), which was recently criticised also by the European Broadcasting Union.73

72 
 Average scoring of the indicator on Editorial autonomy for all countries is 57%. The only indicator scoring higher is Media ownership 
concentration (horizontal) with 71% (Market Plurality). Commercial and owner influence over editorial content (Market Plurality) and Political 
control over media outlets (Political Independence) also score 57%.
73 

 See: https://www.ebu.ch/news/2016/08/ebu-urges-croatian-government-to-protect-the-independence-of-hrt 

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Figure 1.3.5. Editorial Autonomy - Average scorings of sub-indicators

Leading  news  media  in  most  observed  countries  have  some  form  of  self-regulation  that  emphasizes  editorial 
independence. In Cyprus, for example, editorial independence is warranted by both regulatory and self-regulatory 
provisions. The Journalists’ Code of Practice74 defines the duties and rights of journalists. It was signed in 1997 by 
all audiovisual media, including PSM, publishers and the Journalists Union, while the Association of online media 
journalists joined in May 2016. This is the primary instrument of work of the Cyprus Media Complaints Commission, 
which is a media council, responsible for the self-regulation of all news media, both print and electronic. In Germany, 
as reported by the country team, the most important catalogue of self-regulatory measures is the German Press Code, 
established by the Presserat (German Press Council). Press associations commit themselves to the code’s guidelines, 
among which editorial independence is a major obligation for all publishing platforms. Furthermore, leading media 
companies  in  the  country  have  their  own  self-regulatory  measures:  ZDF  has  Employee  code75;  Deutschlandradio 
Journalistic self-conception76; Axel Springer (newspaper Bild) Guidelines for journalistic independence.77 However, 
the  existence  of  self-regulation  does  not  guarantee  its  effective  implementation.  While  the  German  country  team 
has positively assessed effectiveness of the implementation of self-regulatory measures, the Cypriot team reported 
the lack of efficiency due to the weak sanctioning power of the Cyprus Media Complaints Commission that oversees 
compliance with the Journalists’ Code of Practice.

In some countries, such as Greece and Austria, self-regulation at the level of media companies does not exist or does 
not  encompass  leading  media  organizations.  In  Austria,  only  TV  and  radio  stations  are  obliged  to  have  editorial 
statutes  that  guarantee  editorial  independence.  All  other  media  are  allowed,  but  not  required,  to  establish  them. 
The  three  largest  newspapers  (Kronen  Zeitung,  Heute,  Österreich)  refrain  from  self-regulatory  measures,  and  are 
not  members  of  the  Austrian  Press  Council.  At  the  same  time,  these  three  newspapers  are  the  main  beneficiaries 
of state advertising spending, which, as reported by the country team, is usually considered as a means to influence 
media reporting (Seethaler et al., 2017). In Greece, broadcasters and the print media have not created their own self-
regulatory systems through the formulation of collective codes of conduct nor through editorial guidelines at the level 
of single companies. “The lack of a formalised and effective industry-level system protecting editorial independence, 
combined with the interconnections between the political elites and media owners (which the term “diaploki” has 
been  coined  to  describe)  create  space  for  potential  direct  and  indirect  political  influence  on  editorial  activity.  In 
practice, however, the extent to which such influence takes place cannot be assessed due to limited available evidence”, 
highlighted Kandyla and Psychogiopoulou (2017). 

With regard to the editorial independence in practice, most countries (23) score either medium or high risk. Political 
interference in editorial autonomy is not systematically recorded and, hence, it is particularly difficult to measure the 
extent of this complex and nuanced issue. As many country teams have reported, apart from some exposed cases, it 
is very hard to know what is happening within the newsroom considering general lack of monitoring and in depth 
studies. Therefore, in order to ensure maximum level of objectivity, assessments provided by country teams underwent 

74 
75 
76 
77 

 See: http://cmcc.org.cy/code_practice2.html 
 See: https://www.zdf.de/ZDF/zdfportal/blob/26890782/1/data.pdf 
 See: http://www.deutschlandradio.de/index.media.6d1324ff114ae9edff85a35f2a3e0cde.pdf 
 See:  http://www.axelspringer.de/artikel/Leitlinien-der-journalistischen-Unabhaengigkeit-bei-Axel-Springer_40856.html 

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peer-review of a group of multi-level stakeholders in each of the monitored countries. In general, the existing evidence 
suggests  that  the  most  vulnerable  news  media  are  public  media  organisations  that  are  still  politicised  in  many 
European countries through the financing and appointment procedures (for more information, see the indicator on 
Independence of PSM governance and funding). This, however, does not mean that the newsrooms of private media 
are resistant to political pressures. In April 2016, several news media in Poland informed about the tape-recorded talk 
(that took place in 2014) between the leading Polish businessman and a member of the former governing party (Civic 
Platform) about a possibility to influence the German owner of the daily tabloid Fakt in order to change the daily’s 
editor-in-chief, perceived as too critical of the government. Several weeks later, the Fakt’s editor-in-chief stopped to 
work for the tabloid (Blikowska, 2016). 

The lack of protection for editorial independence is particularly problematic in countries where a medium/high risk 
has  been  identified  with  regard  to  the  extent  of  the  politicisation  of  the  media.  For  example,  in  Austria,  Slovakia, 
Czech Republic, Romania, Hungary, Latvia, Malta and especially Turkey, the extent to which the media markets are 
politically affiliated has been assessed as being at medium/high risk, and the leading media do not have adequate 
self-regulatory measures to secure editorial independence. This places media in a very vulnerable position towards 
political influences.

MEDIA AND DEMOCRATIC ELECTORAL PROCESS

The indicator Media and democratic electoral process assesses existence and implementation of regulatory and self-
regulatory  framework  for  the  fair  representation  of  different  political  actors  and  viewpoints  on  PSM  and  private 
channels,  especially  during  the  electoral  campaign.  The  indicator  also  takes  into  consideration  the  regulation  of 
political advertising, and its implementation in practice. The focus is on the risks from bias in the audiovisual media, 
as  television  remains  the  main  source  of  news  for  citizens  in  the  EU  (Standard  Eurobarometer  86).  However,  the 
future editions of the MPM tool should further take into account the continuous rise of the internet and online social 
networks as a source of news (SE 86), and as a more direct and less controlled channel for political propaganda.

Figure 1.3.6. Media and democratic electoral process -  Map of risks per country

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As  regards  audiovisual  media  bias,  and  especially  during  electoral  campaign,  a  vast  majority  of  countries  score  a 
low risk (22 out of 30). Six countries are found to be at medium risk (Austria, Poland, Slovenia, the Netherlands, 
Montenegro and Latvia), and two are at high risk (Hungary and Turkey). In Hungary, the Media Act specifies that 
PSM  should  provide  fair,  balanced  and  impartial  representation  of  political  viewpoints  in  news  and  informative 
programmes. In practice, however, since the system was restructured in 2010, the content of PSM has been marked by 
a demonstrable pro-Government bias: according to monitoring data by the media regulator (NMHH), Fidesz (major 
national conservative political party in Hungary) members of the Parliament and government officials are granted a 
majority of airtime on PSM channels compared to other parties/party officials (Brouillette et al., 2017). The other high 
risk country is Turkey. In this EU candidate country the regulatory framework stipulates that in news and informative 
programmes on PSM all political viewpoints existing in society should be represented in a fair manner. However, the 
law is not implemented effectively and, as reported by the country team, Turkish Radio and Television Corporation 
(TRT) is operated as the government’s propaganda tool. This assessment was confirmed by four out of five additional 
country experts involved in the project as members of the Group of Expert procedure.78 

Despite these two examples, the indicator Media and democratic electoral process obtains on average the lowest risk 
score across 30 European countries. This is mainly because there is a long tradition of regulating and monitoring 
the activities of audiovisual media during election cycles. The MPM2016 analysis has revealed that, in all but three 
countries (Hungary, Latvia and Montenegro), the law imposes rules to ensure fair representation of political viewpoints 
in news and informative programmes on PSM channels and services. Even though the overall risk is rather low, the 
rules on PSM impartiality are not always respected in practice. In Italy, an element of risk during the observation 
period was related to the over-representation of the now former79 prime minister Matteo Renzi on PSM, but also on 
commercial channels. In the United Kingdom, overall, there is a fair representation of political actors on PSM, partly 
due to regulation that is in place. Nonetheless, there have been a few prominent issues of imbalance. For example, a 
recent study conducted by Cardiff University showed that the BBC’s coverage of general elections in 2015 - along with 
other PSMs - very much mirrored the agenda set by the print media who predominantly adopted the Conservative 
party’s agenda.80  

PSM bias, as a sub-indicator of Media and democratic electoral process, shows to be most at risk within the indicator 
on Media and democratic electoral process, however, still in a low risk band (see Figure 1.3.7). To a certain extent this is 
due to the more rigorous criteria and increased focus by both researchers and regulators on PSM, because of its special 
position in the media system. The scoring also reflects the fact that PSMs in 13 countries do not have self-regulatory 
instruments that guarantee impartiality and access for different political actors. However, this is mitigated by the fact 
that electoral campaigns on PSM are significantly   regulated. At the same time, laws and/or self-regulatory measures 
that guarantee political actors’ access to airtime on private channels and services are absent in more than a third of the 
countries (namely 11). This is reflected to a certain extent in practice: half of the countries observed score medium or 
high risk on fair representation of the different groups of political actors on private channels (which is almost twice as 
often than with PSM). As regards the sub-indicator on political advertising, most countries have regulatory safeguards 
to allow for equal opportunities and to prevent financially stronger political actors from obtaining a large amount of 
airtime for political advertising, especially during election periods. In some countries, such as, for instance, Austria, 
Finland, France, Greece and Ireland, political advertising in PSM is entirely banned during election campaigns.

78 
79 
80 

 For more information on the Group of Experts procedure please see the Methodology part of this Report.
 Matteo Renzi resigned after the outcome of a referendum aiming at modifying the Constitution (5 December 2016).
 See: http://downloads.bbc.co.uk/bbctrust/assets/files/pdf/our_work/breadth_opinion/content_analysis.pdf 

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Figure 1.3.7. Media and democratic electoral process - Average scorings of  
sub-indicators

STATE REGULATION OF RESOURCES AND SUPPORT TO MEDIA SECTOR

This indicator assesses the legal and practical situation in relation to the distribution of state managed resources to 
media. At the European Commission’s 2016 Colloquium on Fundamental Rights, which focused on media pluralism 
and democracy, the transparency of media funding, as well as media independence from any political and financial 
pressure,  was  highlighted  as  essential  to  guarantee  media  freedom  and  pluralism.81  In  a  situation  where  media 
organizations face economic difficulties caused by recent economic crisis and an ongoing technological disruption, 
financial support from the state can be crucial, especially for non-profit, community media and other less commercial 
forms of journalism. Therefore, it is of a particular importance that the fair and transparent rules on the distribution of 
state resources and support are in place, as well as that they are effectively implemented. Lack of clear and transparent 
rules might serve favouritism. Lack of available data on allocation in practice poses a risk of channelling money to 
specific media outlets in a biased/opaque manner. 

81 

 See: http://ec.europa.eu/newsroom/just/item-detail.cfm?item_id=31198 

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Figure 1.3.8. State regulation of resources and support to media sector indicator - Map 
of risks per country

As shown in the map (Figure 1.3.8), most of the countries that score medium or high risk on this indicator are the new 
democracies: Slovenia, Montenegro, Bulgaria and Hungary score a high risk, with Estonia, Latvia, Poland, Slovakia, 
Croatia, and Romania being positioned in the medium risk band. In many countries, state supports media, but in 
these countries this is an issue of a particular concern for at least two reasons. First, media capture82 is still largely 
present as a legacy of previous authoritarian rule. Second, liberalization and privatization of media in post-communist 
countries occurred, more or less recently, in parallel with democratic transition (CEDEM, 2012 and Wyka, 2010), 
which makes these young markets particularly sensitive to global technological disruption of media business model. 
In addition, in some of the countries concerned, the state still acts as one of the leading sources of financing for media. 
Therefore, the lack of fair regulation and transparency poses a risk of political influences. Other countries that score a 
medium risk in this regard are Cyprus, Spain and Malta, while Turkey is in the high risk band.

The  indicator  on  State  regulation  of  resources  and  support  to  media  sector  is  composed  of  three  sub-indicators: 
Spectrum  allocation,  Government  subsidies,  and  Rules  on  state  advertising.  Both  Spectrum  allocation  and 
Government subsidies, are a novelty of the MPM2016, introduced to capture emerging risks related with technological 
advancements and economic pressures. In the MPM2015, Rules on state advertising were assessed as an individual 
indicator. In order to achieve more equilibrium along the tool, this year’s edition of the MPM considers this source of 
financing for media within a broader picture of the distribution of state managed resources to media.

 “...a situation in which the media has not succeeded in becoming autonomous to manifest a will of its own and to exercise its main 
82 
function, notably of informing people, but has persisted in an intermediate state, whereas various groups, not just the government, use it for 
other purposes.” (Mungiu Pippidi, 2008, p. 91)

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Figure  1.3.9.  State  regulation  of  resources  and  support  to  media  sector  indicator  - 
Average scorings of sub-indicators

As shown in the Figure 1.3.9, the MPM2016 revealed that most risks within this indicator relate to state advertising, 
which, for the purpose of the MPM, is described as any advertising paid by governments (national, regional, local) 
and state-owned institutions and companies to media. Most countries (19) score a high risk because they lack the 
legislation to ensure fair and transparent rules on the distribution of state advertising to media outlets, and this is also 
reflected in practice through low transparency on the distribution criteria and beneficiaries. High risks in relation to 
state advertising are more present in new democracies than in other members of the EU. For example, in Slovenia 
there is no clear set of rules regarding the distribution of state advertising. Due to further privatisation of state owned 
companies in 2010s, the practice of non-transparent distribution of advertising has slightly decreased, as reported 
by the country team. However, the complete information on media which received state advertising is not available. 
In Bulgaria, there are also no regulatory safeguards for fair and transparent distribution of state advertising to media 
outlets. The actual practice of distribution of funds for state advertising is neither clearly motivated nor safeguarded 
against political pressure from government over the media.  The lack of regulation and transparency in the allocation 
of  state  advertising  is  also  a  pressing  issue  in  Hungary,  where,  in  the  last  few  years,  the  state  became  one  of  the 
biggest advertisers (Brouillette et al., 2017). As reported by the Hungarian country team, after the elections of 2014 
the government established a new body for the allocation of advertising budget, the National Communication Bureau, 
which holds a EUR 80 million budget for media buying annually. This, however, did not help to increase fairness and 
transparency in the distribution of budget. Instead of taking into consideration objective criteria such as audience 
numbers, the spendings are still largely guided by political preferences. There are also four EU countries (Finland, 
Ireland, Luxembourg and Spain) that do not belong to this group of post-communist new democracies but score a 
high risk on state advertising. This is mainly due to the absence of regulation and difficulties in accessing the data on 
distribution in practice.

The second sub-indicator under the State regulation of resources and support to media sector deals with Government 
subsidies. This sub-indicator assesses the general regulation and practice of both direct and indirect state subsidies 
distribution to media outlets, other than PSM. State aid to media has been observed from several perspectives and 
within three areas of risks: a set of variables in the Social Inclusiveness area aims to assess the positive dimension of state 
support to local/regional and community media;83 while in Market Plurality, concerns over effective implementation 
of regulation ensuring that State funds granted to PSM do not exceed what is necessary to provide the public service 

83 

 See indicator Access to media for local/regional and community media, Chapter 1.4

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are captured (i.e. that State funding of PSM does not cause disproportionate effects on competition).84 Finally, the area 
of Political independence aims to capture two other sources of risk: politicisation of PSM funding85, and concerns over 
the distribution of subsidies to media other than PSM.

Direct state subsidies are, for example, cash grants and interest-free loans, while indirect state subsidies include tax 
exemptions, reduced postal service and telephone rates. Again, the logic of the MPM is that, if there are subsidies, 
there should be fair and transparent rules for their distribution. Otherwise, there is a risk of favouritism. On average, 
countries score a low risk (27%) on this sub-indicator (Figure 1.3.9.). In the majority of countries observed (16) the 
state subsidies are distributed to media outlets based on fair and transparent rules. The opposite is the case in Latvia, 
Hungary, Slovenia and Montenegro, all four of which score a high risk, mainly due the fact that there are no clear 
criteria on the allocation of subsidies and/or the data on which media profit from them are hard to obtain. Poland 
and Greece are in a medium risk band. In Poland, no concerns are noted with regard to indirect subsidies (reduced 
tax) but there are some worries on the lack of transparency in distribution of direct subsidies. Apart from the support 
envisaged for minority media, relevant ministries have at their disposal funds for specific projects regarding their area 
of competence. As the country team reported, the Ministry of Foreign Affairs can, on a basis of competition, select 
projects that would support Polish foreign policy. The Ministry of Culture can support projects that would promote 
readership,  etc.  But  information  on  these  fragmented  channels  of  direct  subsidies  to  media-related  projects  and 
organizations is usually not publicly accessible. In Greece, a medium risk is noted in relation to indirect government 
subsidies  (reduced  value  added  tax  and  postal  distribution  subsidy).  As  reported  by  the  country  team,  legislation 
foresees fair rules for the distribution of indirect subsidies to print media outlets, but the lack of transparency does 
not enable an assessment of how the legislation has been implemented. The Secretariat General for Information and 
Communication used to publish information on the total amount of subsidies allocated per type of newspaper per 
year, but this information has not been updated since 2011. No direct subsidy support schemes for private media 
outlets exist in Greece. Therefore, related questions were excluded from the risk calculation. It is important to mention 
that  for  eight  countries  this  sub-indicator  was  not  counted86  since,  according  to  the  information  provided  by  the 
country teams, states in question do not provide any subsidies to media organizations (Netherlands, Estonia, Slovakia, 
Romania, Bulgaria, Malta, Cyprus and Turkey).

Finally,  variables  on  Spectrum  allocation  assess  the  existence  and  implementation  of  the  legal  framework  that 
enacts general  regulatory principles and  policy  objectives of the Radio Spectrum Policy Programme (2012). With 
the  technological  developments  there  is  a  growing  importance  of  access  to  radio  spectrum  for  various  industries 
and activities (from telephony and broadcasting, to transport, navigation and space applications). At the same time, 
spectrum is a natural, finite resource. Therefore its allocation has to take into consideration various needs and interests 
in  order  to  sustain  a  diverse  media  landscape  and  access  to  high-quality  programmes  for  European  citizens.  The 
results of the MPM2016 implementation show that, on average, countries score a low risk with regard to Spectrum 
allocation (22%), meaning that most of them have effective regulation and no disputes were recorded on this matter 
lately. However, there are a few exceptions. In Portugal, for instance, much discussion is going on in the area of digital 
terrestrial television (DTT) and the fact that the country never had a law allowing local terrestrial television. A licence is 
granted to every applicant fulfilling certain minimum requirements concerning professional and economic standards, 
but this does not secure the access to the digital terrestrial transmission network as it has to be negotiated with the 
multiplex operator (EAO, 2015). In Greece, in February 2016, the government adopted new laws which assigned the 
determination of the number of broadcasting licences to the Parliament and the licensing procedure to the Minister 
responsible for the media, bypassing the media regulatory authority (Ethniko Radiotileoptiko Symvoulio - ESR). This 
spawned criticism for potential favouritism on the part of the government and the Council of State, in October 2016, 
ruled that such procedure that excluded ESR, is unconstitutional (Kandyla and Psychogiopoulou, 2017). 

84 
85 
86 
are assessed as not applicable and excluded from the final calculation of risk.

 See indicator Cross-media concentration of ownership and competition enforcement, Chapter 1.2
 See indicator Independence of PSM governance and funding, Chapter 1.3
 If there are no subsidies the countries are not required to have a specific regulation. In these cases relevant variables in the Monitor 

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INDEPENDENCE OF PSM GOVERNANCE AND FUNDING 

The  Independence  of  PSM  governance  and  funding  indicator  is  designed  to  measure  the  risks  which  stem  from 
appointments procedures for top management positions in public service media, and the risks arising from the PSM 
funding mechanisms and procedures. The reasons behind giving a special focus to PSM are twofold, emerging from its 
perceived special role in society and its relationship with the state (CMPF, 2016). PSM systems are usually established 
by the state, which, in some cases, still has an influence over them. Given that the PSM are thought of as being media 
that are both owned by the public and responsible to it, that are characterised by nationwide access, and that produce 
content for all communities (Smith, 2012), it is feared that PSM which are under political influence will no longer 
fulfil the above-mentioned roles. Specifically, it is feared that this will produce biased content and reduce the ability 
of citizens to make informed choices. In order to secure its independence, it has frequently been suggested that the 
state  should  have  only  a  minimal  ability  to  interfere  with  the  appointment  procedures  to  its  boards  and  to  exert 
influence by funding (Bardoel and Haensen 2008; Benson and Powers 2011; Council of Europe 2012; Hanretty 2009;  
Papatheodorou and Machin 2003).

Figure 1.3.10. Independence of PSM governance and funding -  Map of risks per country

As the above map shows, in 13 countries there is a high risk to the political independence of the PSM. In six other 
countries, potentially significant vulnerabilities for the PSM system were detected, therefore placing Ireland, Czech 
Republic,  Croatia,  Latvia,  Estonia  and  Austria  in  the  medium  risk  band.  Luxembourg  scored  a  low  risk,  but  very 
close to the medium risk benchmark, while the other ten countries studied score a low risk. This indicator consists of 
three sub-indicators: one looking at the risks arising from PSM funding, and two assessing the risks stemming from 
appointments to the PSM management boards and of the Director General.

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Figure 1.3.11. Independence of PSM governance and funding - Average scorings of  
sub-indicators

On average, risks are mainly related to the appointment procedures of managing boards and general directors of PSM. 
Along the two candidate countries, Montenegro and Turkey, EU countries that are most at risk include Cyprus, Hungary 
and Romania. The generic character of the criteria used to appoint the General Manager and the Governing Board of 
the PSM in Cyprus, along with the fact that appointments and dismissals are subject to the approval and decisions of 
the Council of Ministers facilitate political influence in practice. As the country team reported, the appointment of the 
General Manager has been politically influenced for many years, which led to successive cancellation of appointments 
by the Supreme Court. In Hungary, the 2010 media legislation brought extensive restructuring of country’s PSM. Each 
of PSM outlets—three national TV, three radio stations and one national news service—are now supervised by a single 
body, the MTVA87, managed by the Media Council, whose members are appointed by the government (Brouillette et 
al., 2017). 

In Romania, the appointment procedures ensure the presence of various political groups within the overseeing boards 
of  the  PSM  and  in  the  council  of  administration  of  the  Romanian  Public  Television.  The  members  of  the  board 
of management of The Romanian Radio Broadcasting Corporation and the Romanian Television Corporation are 
appointed by the vote of the majority of Parliament members in the joint meeting of the two chambers. However, 
according to the data presented by the country team, conflicts between these groups occurred frequently in the past 
years as they act almost exclusively as representatives of narrow party interests (rather than just as party representatives 
working  as  guarantors  of  journalistic  content  in  the  public  interest).  Therefore,  any  changes  in  the  parliamentary 
majority or in the parliamentary agreements regarding the leadership of the PSM lead to a change of the PSM President 
and its board. Such change can be executed easily because the president of the PSM, together with the boards, can 
be dismissed by Parliament simply through the rejection of the annual report of activity without any evaluation of 
previously set performance targets, according to the Law of the organization and operation of the Romanian Radio 
Broadcasting Corporation and the Romanian Television Corporation. Therefore, although the mandate span of the 
Board members and President is four years, the board is actually often changed before term – only one of the presidents 
appointed since 1989 (out of a total of twelve) finished his term completely. 

There has been many changes to the broadcasting laws in Poland recently, with a particular focus on the regulation 
of public service media which have provoked broad public discussion and criticism. The Small Media Act in 2015 
introduced  appointment  of  PSM  Directors,  management  and  supervisory  boards  by  Minister  of  Treasury,  thus 
creating  a  direct  link  between  the  government  and  PSM  governance  bodies.  The  Small  Media  Act  expired  on  30 
June 2016, and the new Act establishing the National Media Council was passed by the Polish Parliament on 22 June 
2016.  According to the new Act, the National Media Council is now responsible for appointing members of PSM 
supervisory and management boards as well as Directors of the Polish Television and Polish Radio. However, this new 
body has weakened regulatory competences of the broadcasting authority KRRiT (Klimkiewicz, 2017).

Most countries that score high risks in relation to the politicisation of appointment procedures, record also medium/
high risks with regard to the sub-indicator that looks at the adequacy and transparency of PSM funding. Along the 
countries listed above, Spain and Slovenia also belong to the group of upper high risk countries.

87 

 Médiaszolgáltatás-támogató és Vagyonkezelő Alap - umbrella organization for Hungarian public service media

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1.4 ANALYSIS OF SOCIAL INCLUSIVENESS 

The Social Inclusiveness area examines access to the media by various social and cultural groups, such as minorities, 
local/regional communities, people with disabilities and women. The access of different groups to the media is a key 
aspect of a participatory media system and is a core element of media pluralism. In addition, the Monitor considers 
media literacy to be a precondition for using media effectively. The area covers the following indicators:

● 

● 

● 

● 

● 

Access to media for minorities 

Access to media for local/regional communities and community media

Access to media for people with disabilities

Access to media for women

Media literacy 

In the area of Social Inclusiveness, two thirds of the countries (21) are in the medium risk band. Three countries score 
a high risk (Greece, Latvia and Turkey) and six countries a low risk (Belgium, Denmark, France, Netherlands, Sweden 
and the United Kingdom).

Figure 1.4.1 Social Inclusiveness area – Map of risks per country

Figure 1.4.2 below illustrates that all individual indicators score in the medium risk band (on average). The indicator 
on access to media for people with disabilities shows the lowest risk (37%) but still ranks medium risk since support 
services for people with hearing and visual impairments are either non-existent or limited in the majority of countries. 
The indicators on access to media for minorities and for women score the highest risk (54% respectively). The latter 
two indicators are also among the top risk scores across all MPM areas. None of the countries scored a low risk on 
the representation of women as subjects and sources in news (on- and offline), which indicates that women might 
be heavily underrepresented in media across Europe. The other key concern in the area relates to the failing of many 
countries to provide adequate and proportional access to media (TV, radio and in newspapers) for minorities. 

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Figure 1.4.2. Social Inclusiveness area - Averages per indicator 

ACCESS TO MEDIA FOR MINORITIES

The Monitor assesses minorities’ access to airtime on PSM channels, both in terms of legal safeguards and in practice. 
It also considers whether the space dedicated to minorities on TV, radio and in the newspapers is proportional to 
the size of the minority population in the country. This indicator has been elaborated on the basis of OSCE’s Oslo 
Recommendations (OSCE, 1998, p. 6) that states the following: “Persons belonging to national minorities should have 
access to broadcast time in their own language on publicly funded media. At national, regional and local levels the 
amount and quality of time allocated to broadcasting in the language of a given minority should be commensurate 
with the numerical size and concentration of the national minority and appropriate to its situation and needs.” The 
indicator is also in line with the Council of Europe’s European Charter for Regional or Minority Languages (Council of 
Europe 1992, article 11) and its Framework Convention for the Protection of National Minorities, which emphasises 
that the Convention Parties shall ensure, within the framework of their legal systems, that persons belonging to a 
national minority are not discriminated against but facilitated in their access to the media (Council of Europe, 1995, 
article 9). 

The MPM definition of minorities is based on the concepts outlined by the Special Rapporteur of the United Nations 
Sub-Commission  on  the  Prevention  of  Discrimination  and  the  Protection  of  Minorities  (UN,  1979)  and  by  the 
European  Union  Agency  for  Fundamental  Rights  (FRA,  2011).88  In  brief,  the  Monitor  considers  minorities  to  be 
cultural or social groups that are:89

● 

● 

● 

numerically inferior to the rest of the population and to the majority group in the country,

in a non-dominant position,

whose members possess ethnic, religious or linguistic characteristics differing from those of the rest of the   
population.

88 
 It is worth mentioning that there is no internationally agreed definition as to which groups constitute minorities. For example, the 
Framework Convention for the Protection of National Minorities of the Council of Europe (CoE) does not contain a definition of a “national 
minority”, as there is no general definition that is agreed upon by all the CoE’s member states.
89 

 For a complete MPM definition of minorities and the apposite references, please see Annex I. 

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It is  important to  note  that  MPM variables  that are concerned with legal aspect are restricted to the definition of 
minorities that includes only minorities recognised by law, while for other, practice-oriented variables, the definition 
of minorities is expanded to include also minorities not recognized by the law. 

The results on the indicator Access to media for minorities show that this is one of the highest risk indicators in the 
area and among the top risk scores across all of the Monitor’s areas. Eight countries score a high risk, and only four 
score a low risk. In the great majority of countries minorities have adequate access to airtime, but with significant 
exceptions (medium risk).

Figure 1.4.3. Access to media for minorities -  Map of risks per country

The  indicator  Access  to  media  for  minorities  contains  two  sub-indicators.  The  first  sub-indicator  examines  if  the 
law guarantees access to airtime on PSM channels to minorities and if minorities have access to it in practice. In the 
variable that assesses the legal safeguards the definition of minorities is restricted to national minorities recognised 
by the law. Half of the countries (15) do not have this type of legal guarantees. In the variable that covers access to 
airtime  in  practice  the  definition  of  minorities  is  expanded  to  include  also  minorities  not  recognized  by  the  law. 
At  a  first  glance,  the  data  seems  to  indicate  that  the  availability  of  legislation  does  not  lower  the  risk  of  access  in 
practice. However, the results have to be interpreted with caution since the two variables adopt different definitions of 
minorities. As a case in point, in Slovakia only minorities recognised and catered for by the law have access to airtime 
in practice, which means it scores low risk on legislation and high risk on the actual practice. 

The results on this sub-indicator are polarised with about half of the countries (13) scoring low risk and the other 
half  (14)  scoring  high  risk,  while  only  three  countries  score  medium  risk.  On  the  high  risk-end  the  results  are 
quite worrying since also countries such as Germany and Finland, which score low risk on many media pluralism 
dimensions, score as high as 75% respectively. Germany and Finland have no legal safeguards for access to airtime 
on PSM for minorities. In Germany, only churches and Jewish communities are guaranteed access to airtime on PSM 
by law. In practice, there are no specific TV or radio channels for minorities. In general, the MPM reveals that access 
to airtime on PSM varies across different minority groups in many of the examined countries. As a case in point, in 
Romania some minorities have access to airtime that is proportional to their share of the population in the country, 
while others have no access at all. The Romanian country team attributes this to the social and political representation 
of minority groups, where some minorities (such as the German minority in Romania) benefit from a positive public 
perception and symbolic capital, and also come to be more entitled to have airtime than more marginalized groups. 
Moreover,  the  MPM  detects  several  cases  where  legally  recognized  minorities  are  better  represented  than  non-

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recognised minorities in the media. For example, the two legally recognized minorities (Sámi and the native Swedish 
speaking Finns) are fairly well-represented in Finnish media. They have their own TV and radio channels via the 
Finnish PSM corporation Yleisradio. Other ethnic minorities, however, tend to be underrepresented on all channels 
in Finland, except when it comes to crime news. Ethnic and other minorities also tend to be misrepresented in other 
ways in Finland, for example by placing them in the role of a minority representative instead of treating them as, for 
example, employees or parents.90

Six countries score the highest possible risk (97%) on the sub indicator regarding access to PSM (Cyprus, Denmark, 
Greece, Malta, Luxembourg and Ireland). In Ireland, the Irish-language speakers are well catered for on PSM relative 
to  their  numeric  prominence  in  the  population.  Outside  the  Irish-language  community,  however,  the  PSM  RTÉ 
(Raidió Teilifís Éireann) has only a very sporadic record of producing content for other minorities and providing 
access to the airwaves for such groups. The media expert Gavan Titley, interviewed by the Irish country team, stressed 
that since 2010 “RTE has no dedicated programming” targeting ethnic minorities. In 2013, RTE published a 2013-
17 strategy document, which briefly considered “On Air Diversity”. The document tacitly acknowledged that RTE 
programming  to  date  might  not  have  fully  represented  the  makeup  of  the  country  as  a  whole  and  committed  to 
broadening the range of on-air contributors. Specifically the document stated the programme makers should begin 
to  track  on  air  contributions  by  “age,  gender,  region,[and]  ‘new’  Irish”.  In  April  2016,  the  outgoing  RTE  Director-
General, Noel Curran, publicly acknowledged that RTE had “fallen on ethnic minorities absolutely, we have not done 
enough” (Kapila, 2016), although he asserted that going forward would be a priority for the organisation. In the case of 
Luxembourg, also scoring 97% on this sub-indicator, the sum of minority groups in the country will soon become the 
‘majority’. In 2016, almost half of the population did not have the Luxembourgish nationality and Luxembourgish was 
the primary language for only 3.8% of the population. Despite this large presence of other nationalities and linguistic 
groups in the country, the PSM services are essentially in Luxembourgish, thereby excluding most minority groups 
and a large share of the overall population.

The second sub-indicator assesses if the space for minorities on TV, radio and in newspapers is proportional to the 
size of the minority population in the country.91 A large majority of countries (25) score either medium or high risk 
on this sub-indicator, which means that programming hours on TV and radio, as well as newspapers dedicated to 
minorities are not proportional to the size of minorities in most European countries. Almost half of the countries (12) 
score high risk and five countries score the highest possible risk (Ireland, Bulgaria, Finland, Germany and Slovenia). 
In Bulgaria, the coverage of most minorities is not proportional to the size of their populations in the country. Media 
monitoring reports indicate a general tendency of discriminatory or prejudice-driven representation of minorities, 
especially on TV. The Bulgarian country team also points out that it is not only a question of number of programming 
hours dedicated to minorities, but also to how they are represented. For example, the mainstream audiovisual media 
in Bulgaria covers Roma-related issues frequently, including in prime-time news and talk-show programmes. The 
representation, however, is often biased, scandalous and driven by negative prejudices; and hate speech takes place. 
In  Slovenia,  the  interviewed  expert  Boris  Vezjak  suggests  that  the  high  risk  score  regarding  proportionality  of 
representation is related to the absence of systemic regulations and lack of funding to support minorities’ access to 
media.92

During the testing rounds of the MPM, we encountered a number of measurement problems related to e.g. definition 
of minority media, framing of proportionality of access, and lack of research and statistics on minorities. It is worth 
noting that it was difficult to get accurate data in many of the surveyed countries. Moreover, it is difficult to establish 
if the dedicated media space is proportional to the minority populations since the statistics on both programming 
hours and the size of minority groups in the country (especially those not recognised by the law) are often missing. 
For example, there is no reliable statistics on the Roma population in Sweden. Collecting this type of ethnicity related 
data is a loaded and political issue. The available data tends to be uncertain with the number of Roma in Sweden 
ranging from 30,000 to 500,000 depending on the source.93 To get more reliable results and an additional evaluation 
of the issue, the country teams conducted interviews with at least one expert on minorities in their country regarding 
all except one of the variables in this indicator (the legal one). 

90 
 This information is based on an interview with the Finnish authority Non-discrimination Ombudsman conducted by the Finnish 
country team in April 2016. This assessment is also partly confirmed by Karina Horsti, which assesses that Yleisradio has yet to properly serve 
and represent minorities chapter in an edited volume on European PSM (“National conversations: public service media and cultural diversity in 
Europe”) (Horsti, 2014).
 The variables in this sub indicator assessed if the programming hours on TV and radio channels dedicated to minorities are propor-
91 
tional to the size of the minority population, and if the number of newspapers dedicated to minorities is proportional to the size of the minority 
population. When coding the latter variable, the readership of the newspapers in question was considered since there might be many minority 
newspapers but with very few readers or, alternatively, only a few minority newspapers but with many readers. Again, in this practice-oriented 
variable the definition of minorities is expanded to include also minorities not recognized by the law.
92 
93 

 Interview with Boris Vezjak, professor at the University of Maribor, conducted on 8 June 2016 by the Slovenian country team.
 Information from the country expert for the Monitor implementation in Sweden, dated 24/09/2015. 

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ACCESS TO MEDIA FOR LOCAL/REGIONAL COMMUNITIES AND COMMUNITY MEDIA

Media  at  the  regional  and  local  level  is  particularly  important  for  democracy  since  its  relationship  with  the  local 
audiences tends to be closer compared to national media. That proximity is confirmed by both the user statistics and 
by the level of participation in the media. Regional and local media can also serve as alternative spaces for discussion 
for identities and languages that are marginalised by the national media. A solid regulatory framework and support 
measures can help regional media in its democratic mission (Cappello et al., 2016). This is becoming increasingly 
important in times when more and more local and regional newspapers and broadcasters are struggling to survive.

Community media is also critical for ensuring media pluralism and are an indicator of a sound democratic society. 
They tend to focus on local issues and can contribute to facilitating local discussions (UNESCO, 2017). In the MPM, 
community media is defined as media that are non-profit and accountable to the community that they seek to serve. 
They are open to participation by members of the community for the creation of content. As such, they are a distinct 
group within the media sector alongside commercial and public media. Community media are addressed to specific 
target groups and social benefit is their primary concern.

This MPM indicator assesses if local and regional communities are guaranteed access to media, both in terms of legal 
safeguards and in terms of policy or financial support. It also covers community media, both from the point of view of 
legal and practical guarantees of access to media platforms and independence, as well as in terms of policy measures. 
Almost two thirds of the countries (17) are in the medium or high risk band (see Figure 1.4.4). As many as one third 
(9)  score  high  risk.  The  sub  indicator  on  community  media  scores  higher  risk  compared  to  the  one  on  local  and 
regional communities: almost half of the countries (14) score high risk, and four countries (Bulgaria, Cyprus, Portugal 
and Latvia) score the highest possible risk (97%).

Figure 1.4.4. Access to media for local/regional communities and community media -  
Map of risks per country

The first sub-indicator examines if there are legal safeguards for access to media for local and regional communities, 
and if the state supports local and regional media through subsidies or policy measures. The MPM assesses if the law 
contains specific provisions granting access to media platforms to regional or local media, and if they are implemented. 
Moreover, it assesses if the PSM are obliged to keep their own local/regional correspondents or branches (as opposed 
to relying on material acquired from news agencies) and if they have obligations to broadcast national news in regional 

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and minority languages.94 The overall results on this sub-indicator show that around half of the countries (14) are in 
the low risk band. Six countries even score very well at the minimal possible risk level (3%).95 At the same time, eight 
countries score high risk. For example, the Baltic countries (Estonia, Latvia and Lithuania) are all in the high risk 
band. The access of regional and local media to media platforms is not guaranteed by law, and the state provides very 
little support to this type of media in terms of policy measures or subsidies. Moreover, the PSM are not obliged to keep 
their own local/regional correspondents or to transmit national news in regional and minority languages.

In most of the countries (22), the legal guarantees for access of regional/local media to media platforms are in place. 
Relevant provisions concern reservation of TV or radio frequencies; or guarantees for access to radio and TV networks 
via must-carry rules. The legal provisions are implemented effectively in all but one country (Turkey). On the other 
side of the spectrum, seven countries lack this type of legal provisions (Estonia, Latvia, Lithuania, Greece, Finland, 
Czech republic, and Croatia). In about half of the countries, PSM also lack legal provisions on keeping local/regional 
presence and on broadcasting news in regional and minority languages (16 and 15 countries respectively). 

Regarding support measures directed towards regional and local media, the results represent a mixed picture. About 
one third of the countries does not support regional/local media at all (high risk), while another third has support 
measures in place but only to a limited extent. In the Netherlands, the Media Act (2008: Article 2.170b)96 establishes 
that local PSM receive a subsidy of 1,30 euro per household, disbursed by the municipalities. However, the Dutch 
media authority concludes that not all municipalities meet the subsidy requirements (too little is paid) and the financial 
situation of one third of the local PSM’s is worrying.97 In Poland, for a long time, an approach to local media markets 
has not envisaged any direct subsidies or other schemes. Although there have been some indirect subsidies (lowered 
tax) for the press and book sector, these supported book and press sectors generally, without taking into consideration 
specific conditions of local and regional media. As a result, the Polish media landscape is relatively centralized and this 
centralization is steadily growing, particularly in the press market.

The second sub-indicator examines potential risks to community media. In particular, the MPM assesses if community 
media  are  guaranteed  access  to  media  platforms  (e.g.  by  reservation  of  TV  or  radio  frequencies  for  community 
media or guarantees for access to networks via must-carry rules). The MPM also examines if the community media’s 
independence is safeguarded, and if these media benefit from state support, subsidies or targeted policy measures. 
Almost half of the countries score high risk, and four of them (Bulgaria, Cyprus, Portugal and Latvia) score the highest 
possible risk. In Bulgaria, community media are not envisaged in the law and there are no statutory regulations on the 
licensing or the functioning of community media. There is no tradition of community media and community media is 
basically non-existent. Over the years, there have been just a few media outlets with some characteristics of community 
media. These media have been licensed and functioned under different regimes (as public or as commercial media).

ACCESS TO MEDIA FOR PEOPLE WITH DISABILITIES

All citizens have the right to access media and persons with disabilities need this access in order to live independently 
and participate fully in all aspects of life (European Blind Union, 2016). This is an issue for a large number of people 
since there are circa 30 million visually impaired98 and 50 million deaf or hard of hearing Europeans,99 which together 
constitutes about 10% of the total EU population. The UN Convention on the Rights of Persons with Disabilities, 
which has been ratified by over 170 states and by all of the EU countries (European Commission, 2016), stresses that 
states should encourage the media, including providers of information through the Internet, to make their services 
accessible  to  persons  with  disabilities;  and  that  they  should  promote  the  use  of  sign  languages  (article  21).  The 
Convention also asserts that states shall take all appropriate measures to ensure that persons with disabilities enjoy 
access to television programmes in accessible formats (article 30).100 “Denying access to TV and on-demand content 

 Regional or minority languages are defined in accordance with the European Charter for Regional or Minority Languages (1992) as: 
94 
traditionally used within a given territory of a State by nationals of that State who form a group numerically smaller than the rest of the State’s 
population; and different from the official language(s) of that State. European Charter for Regional or Minority Languages (1992). ETS No.148. 
Strasbourg, 05/11/1992. http://www.coe.int/en/web/conventions/full-list/-/conventions/treaty/148 
 The six countries are : Austria, France, Italy, Slovakia, Spain and United Kingdom. 
95 
 Mediawet 2008 [Media Act 2008]. http://wetten.overheid.nl/BWBR0025028/2017-02-01 
96 
 Commissariaat voor de Media (CvdM) (2013). Evaluatie van de financiering van de lokale publieke media instellingen in de jaren 
97 
2009-2012 [Evaluation of the funding of local public media institutions in the years 2009-2012]. p. 13. http://www.cvdm.nl/wp-content/up-
loads/2013/12/evaluatie-van-de-financiering-van-de-lokale-publieke-media-instellingen-in-de-jaren-2009-2012.pdf 
98 
99 
consultations/2011/audiovisual/non-registered-organisations/european-federation-of-hard-of-hearing-people-efhoh-_en.pdf 
 The Convention establishes that “States Parties shall take all appropriate measures to ensure that persons with disabilities can exer-
100 
cise the right to freedom of expression and opinion, including the freedom to seek, receive and impart information and ideas on an equal basis 
with others and through all forms of communication of their choice.” See Article 21 and 30: Freedom of expression and opinion, and access to 
information of the UN Convention on the Rights of Persons with Disabilities: https://www.un.org/development/desa/disabilities/convention-

 European Blind Union: http://www.euroblind.org/resources/information/#details 
 European Federation of Hard of Hearing People (2011). State of subtitling accessing EU. Report. http://ec.europa.eu/internal_market/

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means discrimination on the basis of article 30 of that Convention.101

At the European level, the Audiovisual Media Services Directive (AVMSD, 2010, article 7) contains a non-binding 
measure stating that “Member States shall encourage media service providers under their jurisdiction to ensure that 
their services are gradually made accessible to people with a visual or hearing disability”. In 2015, when the Commission 
started a revision of the AVMSD, several civil society organisations requested to strengthen the accessibility provisions 
(European Disability Forum, 2016, European Blind Union, 2016, European Union of the Deaf, undated). Presently, 
the EU regulation related to accessibility of audiovisual media services is under discussion.102 

The MPM indicator assesses the regulatory framework, including the policies and laws on access to media content 
for people with disabilities, and the availability of support services for people with hearing and visual impairments. 
In the framework of the MPM people with disabilities are defined as blind, partially sighted, deaf and hard of hearing 
people. This is the indicator showing the lowest risk in the Social inclusiveness area, although it still lies in the medium 
risk band (37% on average). Most countries score medium risk and only Luxembourg scores high risk (75%). Among 
the twelve countries scoring low risk, five countries score the lowest possible risk (Belgium, United Kingdom, Czech 
Republic, Denmark and Sweden at 3%). Overall, there is a lot of variation across the 30 countries in terms of the level 
of accessibility for people with disabilities. 

Figure 1.4.5. Access to media for people with disabilities -  Map of risks per country

The first sub-indicator covers the regulatory framework and assesses whether there are laws requiring signing and 
audio  descriptions,  and  if  policies  on  access  to  media  content  are  coherent  and  well-developed.  Most  countries 
have an adequate regulatory framework (16 score low risk) and only two countries score high risk (Lithuania and 

on-the-rights-of-persons-with-disabilities/convention-on-the-rights-of-persons-with-disabilities-2.html 
 http://www.euroblind.org/newsletter/2016/july-august/newsletter/online/en/newsletter/feature/ 
101 
 In December 2015, the Commission adopted a proposal for a horizontal Directive on accessibility of goods and services (the Euro-
102 
pean Accessibility Act (EAA)) that also covered accessibility of audiovisual content. In the light of the forthcoming EAA, the European Com-
mission deleted article 7 from the proposal for the AVMSD of 25 May 2016. At the same time, several civil society stakeholders stressed that the 
AVMSD and the EAA should complement each other, and suggested that future revisions should contain compulsory accessibility targets in the 
AVMS directive that are specified through functional requirements in the EAA (European Disability Forum, 2016, The European Blind Union, 
2016, European Union of the Deaf, undated).

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Luxembourg).  In Luxembourg, the government has ratified the United Nations Convention on the Rights of Persons 
with Disabilities but there is no specific law implementing the Convention. The government has decided to implement 
the  Convention  through  several  action  plans  with  targeted  measures.  A  particularly  relevant  measure  states  that: 
“The national news must be accessible to people with hearing disorders (using synchronized subtitles in German and 
French and publishing online articles written in plain language). Some programmes of general interest broadcast live 
should also be translated into sign language.”103 However, an NGO representative interviewed by the Luxembourgish 
country team observed that, in the absence of legal requirement, several newspapers do not offer online versions that 
are accessible for blind people. Moreover, radio in Luxembourg is not accessible for people with hearing impairments. 
Also in Lithuania, policy-making in this thematic area is still under development. The main policy-related principles 
are  outlined  in  the  Law  on  equal  opportunities;  the  National  Programme  for  Social  Integration  of  People  with 
Disabilities  2013-2019,  which  outlines  key  problematic  areas  in  this  field;  and  in  international  conventions  (i.e. 
Convention on the Rights of Persons with Disabilities that Lithuania has ratified). The Lithuanian PSM adhere to the 
generic values of openness, transparency and accessibility in its internal strategies and documents, and applies these 
in offering information for people with hearing and other disorders. In practice, the Lithuanian National Radio and 
Television (LRT) has an annual budget targeted at adapting its programmes to people with hearing problems (e.g. in 
order to hire sign language translators and provide subtitling). However, one of the consulted experts stresses that 
while there are programmes for persons with hearing impairments, there is a lack of programmes for people with 
visual impairments. 

In contrast to the Luxembourgish and the Lithuanian cases, the United Kingdom offers a good practice. The UK has 
a well-developed policy in this area. The communications regulator in the UK, Ofcom, is required by law to draw up 
and periodically review a code related to enabling persons who are deaf or hard of hearing, blind or partially sighted, 
or who have a dual sensory impairment (deafblind) to be able to access television services. Ofcom’s code sets out the 
requirements  regarding  subtitling,  audio  descriptions  and  signing,  and  it  applies  to  all  TV  channels,  although  the 
requirements are higher for PSM, particularly for the BBC. The legislative requirements for audio description apply 
also for on-demand audiovisual media. In addition, Ofcom also conducts periodic reviews of the way broadcasters are 
meeting the quotas set by the code. The latest Television access services report in 2015 showed that the broadcasters are 
meeting the requirements and even voluntarily delivering significantly over the statutory requirements. When targets 
are missed, it is only marginally. According to the European Blind Union, an umbrella organisation for 44 national 
NGOs, the binding legislation in the UK has ensured much higher levels of audio description and subtitles compared 
to other EU Member States that lack such legal requirements.104 Moreover, the British NGO Action on Hearing Loss, 
interviewed by the country team, stresses that since Ofcom introduced monitoring of the legal implementation, the 
quality of subtitles had improved significantly. 

According  to  an  Ofcom  representative  on  the  MPM  group  of  experts,  Ofcom  also  works  with  industry  and 
disability  groups  to  improve  the  access  of  people  with  disabilities  to  audiovisual  content.  Some  of  their 
most  recent  initiatives  relate  to  access  in  on-demand  audiovisual  services,  and  cooperation  with  industry 
to  further  improve  the  quality  of  live  subtitling,  potentially  aiming  to  update  best  practice  guidance  in 
this  area.  Ofcom  has  also  extended  obligations  on  the  provision  of  signing  to  non-domestic  channels 
licensed  by  Ofcom  (i.e.  those  who  broadcast  to  other  countries  in  the  EU  and  in  Europe  more  widely).  
The second sub-indicator evaluates whether, and to what extent, support services for people with hearing and visual 
impairments are available in practice (i.e. subtitles, signing, sound descriptions and audio description). Overall, 17 of 
30 countries score medium or high risk, which means that support services are either non-existent or only available 
on an irregular basis. This indicates that in relation to support services there is considerable room for improvement 
in  most  of  the  examined  countries.  The  results  are  polarised  with  nine  countries  showing  high  risk  and  nine  the 
lowest possible risk (3%). Several countries that score high risk on this sub-indicator, including Bulgaria and Slovenia, 
report that support services are offered by PSM only, and not by private media. A particularly burning issue is that 
audio descriptions for blind people are absent in one third of the countries (10 scoring high risk), and available only 
on an irregular basis in eleven countries (scoring medium risk). Figure 1.4.6. shows that more countries score risk 
regarding support services for blind people than regarding services for people with hearing impairments. This finding 
is in line with the European Commission’s assessment of availability of access services, which concluded that the level 
of services for the visually impaired is much lower compared to such services for people with hearing impairments 
(European Commission, 2016).

103 
team).
104 

 Plan d’Action de mise en œuvre de la CRDPH du Gouvernement luxembourgeois (2012), p. 10. (Statement translated by the country 

 http://www.euroblind.org/newsletter/2016/july-august/newsletter/online/en/newsletter/feature/ 

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Figure 1.4.6. The availability of support services for people with hearing impairments 
(left-hand map) and for people with visual impairments (right-hand map) in audiovisual 
media

In the case of Bulgaria, none of the public or private broadcasters offer audio descriptions for blind people. In the 
past few years, the national Council for Electronic Media has repeatedly pointed to serious insufficiencies in regard 
to this issue and has reminded the media service providers of their obligations to provide blind people with better 
access to media content by introducing audio descriptions. The situation regarding support services for people with 
hearing impairments is better. The PSM Bulgarian National Television (BNT) provides sign language interpretation 
of the daily news every weekday and also has a weekly TV show aimed at the social integration of people with hearing 
impairments that has been on air for more than 30 years. The whole programme is interpreted in sign language. At the 
same time, the two largest private broadcasters examined do not provide media content in sign language. Subtitles are 
used on irregular basis by public and private broadcasters. As a whole, access to TV content by people with hearing 
impairments is very limited. The country team reports that people with such impairments are dissatisfied with the 
current situation, in particular with the quality and the frequency of the sign language transmissions on the PSM. Also 
the Council for Electronic Media has detected these insufficiencies and urged the media service providers to introduce 
subtitles and sign language.

In Montenegro, all kinds of support services (subtitles, signing, sound and audio descriptions) are extremely limited. 
The only programme that has been translated into sign language is a special daily news broadcast by the PSM, which 
has a duration of only five minutes per day. In Romania, despite an improvement compared to the situation in 2015, 
many TV channels still fail to provide sufficient subtitles, signing and sound descriptions.105 The key reasons are the 
lack of appropriate funding, limited technical possibilities and specialized interpreters at the local level. The overall 
situation is particularly critical for audio descriptions, which are not required by the law. 

ACCESS TO MEDIA FOR WOMEN

Gender  equality  is  a  fundamental  value  (Treaty  on  European  Union,  2008)  and  a  strategic  objective  of  the  EU 
(European Commission, 2015b). The Council of Europe considers gender equality as an integral part of human rights, 
inter-related  with  media  freedom,  including  editorial  freedom,  and  hand-in-hand  with  freedom  of  expression,  as 
fundamental right (Council of Europe Recommendation, 2013). However, gender gaps are still a reality in the media 
sector. The EU-wide study conducted by the European Institute for Gender Equality (EIGE, 2013, p. 59) stresses that 
significant inequalities, including under-representation and career barriers, remain entrenched in the media sector. 
Part of the EIGE conclusions are confirmed by the results of this indicator. 

The indicator Access to media for women evaluates the regulatory framework related to women’s access to media; 
as well as the share of women at the level of management, among news reporters and in news content. This is the 

105 
sions regarding the provision of sign language.

 The country team reports that as of February 2016, 98 of the 224 regional/local TV and cable channels did not apply the legal provii-

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indicator with the highest risk score in the Social inclusiveness area (54%) and it is among the top risk indicators 
across all the MPM areas. The group at risk of being excluded by media systems is of significant size. In the EU:28, 
there are circa 260 million women, which make up 51% of the total European population.106 

As  illustrated  by  the  map  in  Figure  1.4.7,  eight  countries  score  high  risk  on  average  and  only  four  score  low  risk 
(France, Finland, Sweden and Bulgaria) on this indicator. The concerns are particularly strong about the representation 
of  women  in  media  organisations  and  in  news  content.  None  of  the  examined  countries  scored  low  risk  on  the 
share  of  women  as  subjects  and  sources  in  news  (on-  and  offline),  which  indicates  that  women  might  be  heavily 
underrepresented in media across Europe.

Figure 1.4.7. Access to media for women -  Map of risks per country

The first sub-indicator covers the existence and implementation of equal rights laws, and assesses if the PSM have a 
comprehensive gender equality policy. Equal rights laws that apply to employment of women in media organizations 
are  in  place  and  implemented  in  most  of  the  thirty  countries.  Only  three  countries  lack  equal  rights  law  (Latvia, 
Montenegro, Slovenia). Interestingly, the Bulgarian country team notes that the country’s accession to the EU was a 
key incentive for introducing legislative measures on gender equality.107 

The situation is less positive regarding gender equality policies. In 13 countries PSM lack gender equality policies 
altogether.108 Moreover, in one third of all countries, the policies are not comprehensive.109 For example, Denmark 
scores medium risk because the PSM policies do not cover programming content. Both the Danish TV2 (a publicly 

 http://ec.europa.eu/eurostat/statistics-explained/index.php/Gender_statistics 
 Source: The Law on Equality between Women and Men (Translation to English by the CMPF).  Закон за равнопоставеност на 

106 
107 
жените и мъжете. Обн. ДВ. бр.33 от 26 Април 2016г. http://www.lex.bg/bg/laws/ldoc/2136803101 
108 
 In Ireland despite repeated efforts by the country team to make contact with the responsible department within the PSM, researchers 
were not able to get reliable information. Since PSM is generally a public institution that should promote high standards of transparency, no data 
in this case was coded as a high risk.
109 
 The country experts had to evaluate the availability and quality of policies in the form of risk assessment where high risk meant that 
PSM do not have any policy, medium risk that a policy is in place but is limited in scope, and low risk that PSM have a comprehensive policy. 
The experts considered that a gender equality policy is available if such a policy exist as a specific document or if gender equality objectives or 
measures with regard to personnel issues or programming are mentioned as part of other documents.

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owned  subscription  TV)110  and  the  PSM  Danish  Broadcasting  Corporation111  have  gender  equality  policies  with 
concrete targets (minimum 33% and 40% of the underrepresented gender in management positions respectively). 
However,  the  policies  do  not  cover  media  content.  A  good  practice  example  is  the  gender  equality  policy  of  the 
Swedish PSM SVT (Sveriges Television).112  The policy states that the SVT programming should factor in equality and 
reflect it both in the choice of topic and focus, as well as in the number of participating women and men. It also sets 
numerical goals, e.g. that the proportion of female and male managers in all managerial levels must be equal or have a 
deviation of no more than 10%, and that the percentage of women and men participating in programmes should not 
have a deviation of more than 10% over a period of one year. However, a shortcoming is that it is unclear if and how 
the policy is monitored in practice.113 

The second sub-indicator assesses the representation of women at the level of PSM management, and among news 
reporters  and  in  the  news  content  in  both  private  and  public  media. The  variable  examining  the  share  of  women 
on PSM management boards114 was designed to reflect the Council of Europe recommendation (2012) regarding a 
balanced representation of men and women in decision-making bodies of PSM. Half of the countries (15) show high 
risk for this variable.115 Several countries have very few women on PSM boards and two countries even none (Estonia 
and Turkey). Moreover, even countries that score low risk display percentages that are close to the minimum threshold 
(40% of women on boards). Only two countries in Europe have PSM management boards that are composed of more 
than 50% women (Sweden 61% and Bulgaria 60%). Our findings are in line with Eurostat data116 and the EIGE study, 
which show that despite overrepresentation of women among graduates in journalism and information, and despite 
a high number of women working in the media sector in Europe, women remain underrepresented in management 
positions in media (EIGE, 2013). In public media in the EU:28 women hold only 22% of strategic decision-making 
positions  (EIGE,  2013).  This  is  alarming  since  PSM  should  be  at  the  forefront  of  ensuring  gender  equality  in  its 
internal organisation by committing to the diversity at the top (Council of Europe Recommendation, 2013).117 

The MPM also examines the share of women among news reporters and in news content in both private and public 
media. This is done by using secondary data from the Global Media Monitoring Project (GMMP, 2015).118 The GMMP 
has been running in a large number of countries since 1995 and shows very slow progress in bringing women’s voices 
in  the  news  media.  Also  the  assessment  of  the  MPM  country  sample  generally  shows  that  women  are  not  well-
represented as news subjects either on- and offline, or as reporters. The majority of the countries scores high risk 
on the presentation of women in news (18 countries for offline and 16 for online news), while none of the countries 
score low risk. This means no country adequately represents women as subjects and sources in news according to 
the threshold set by the MPM at a share of at least 40% women. As illustrated in Figure 1.4.8., both off- and online 
representation stands at maximum 35% and 38% (Romania), and minimum as low as 14% and 7% (Montenegro and 
Cyprus).

  SVT  Gender  equality  policy  (undated):  http://www.svt.se/omsvt/fakta/article1313222.svt/BINARY/J%C3%A4mst%C3%A4lld-

110 
  Source:  TV2  CSR  annual  report  2015.  http://monitor.cmpf.eui.eu/uploads/sources/Denmark/TV_2_CSR-redegoerelse_2015.pdf 
and  TV2  Public  Service  annual  report  2015.  http://omtv2.tv2.dk/fileadmin/user_upload/pdf/public_service/TV_2_Public_service-redegoer-
else_2015.pdf 
 Source: DR Public Service annual report 2015 and DR Annual report 2015 (http://www.dr.dk/om-dr/fakta-om-dr/publikationer); 
111 
and DR Personnel policy 2008.  https://www.dr.dk/NR/rdonlyres/E853CA40-6DEE-4632-AF97-CD2767FF6236/2728010/DR_personalepoli-
tik_webudgave1.pdf 
112 
hetspolicy 
 A deeper analysis of the variable on PSM’s gender equality policies will be published in the journal Comunicazione Politica (ComPol) 
113 
in 2017. Nenadic I. and Ostling A. (forthcoming). “Public service media in Europe: Gender equality policies and the representation of women 
in decision-making roles”. Comunicazione Politica (ComPol). Special issue titled “Gender, politics and the media. Lessons learned and struggles 
for change twenty years after the Beijing Fourth World Conference on Women” to be published in September 2017.
 Given that the term “PSM management board” is not a standard name across countries we focused on PSM boards responsible for 
114 
media content during data collection. We chose to monitor decision-making boards concerned with content, as opposed to structures with over-
all legal, policy or other responsibility for the broadcaster (i.e. board of directors or governors) since we assumed that more women on boards 
deciding about content would eventually lead to better representation of women or women’s viewpoint in PSM content.
115 
more women. 
116 
 Women constitute 64% of journalism and information graduates in EU:28, and as much as 70% in Turkey (Eurostat 2012). Moreover, 
the employment data for 2008-2015 in EU:28 show that  the percentage of women employed in the media sector on average is oscillating around 
40% (41% in 2015) (Eurostat 2015).
117 
118 
137, 138) in this sub-indicator.

 See also the Recommendation CM/Rec(2007)3 on the remit of public service media in the information society.
 Please note that the GMMP data does not cover all of the 30 countries assessed by the MPM2016 on each of the three variables (136, 

 The representation thresholds were set as follows: high risk: 29% or less women; medium risk: 30-39% women; and low risk: 40% or 

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Figure 1.4.8. The GMMP data on the presentation of women in traditional news (left-hand 
graph)119 and in online news (right-hand graph) 120

The situation is better regarding women among news reporters: only three countries score high risk. About one third 
of the countries (11) score low risk, having over 40% women among reporters at the time of the GMMP measurement. 
The data is also in line with the Eurostat data on employment for 2008-2015 in EU:28, which show that  the percentage 
of women employed in the media sector on average is oscillating around 40% (41% in 2015) (Eurostat, 2015).121

Figure 1.4.9. The share of women among news reporters 122

 The GMMP lacks data on the presentation of women in online news for the following countries: Bulgaria, Czech Republic, Greece, 

 The GMMP lacks data on the presentation of women in offline news for the following countries: Czech Republic, Greece, Latvia, 

119 
Lithuania, Slovakia, Slovenia
120 
Latvia, Lithuania, Malta, Slovakia, Slovenia.
121 
average is oscillating around 40% (41% in 2015) (Eurostat, 2015).
 Please note that the GMMP is a study of media content, and not a study of media employment. So it actually measures the percentage 
122 
of women who reported the news on the day of the study, and not the percentage of women who were employed as reporters (in newspapers, 
radio and television news). The GMMP lacks data on the share of women among news reporters for: Czech Republic, Greece, Latvia, Lithuania, 
Slovakia, Slovenia.

 The Eurostat employment data for 2008-2015 covering EU:28 show that the percentage of women employed in the media sector on 

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MEDIA LITERACY 

Media literacy is a fundamental aspect of an accessible media system, and a core element of media pluralism. People 
need to master media literacy skills to fully enjoy fundamental rights such as freedom of expression and access to 
information (UNESCO, 2013). The European Commission has recently put the promotion of media literacy as one 
of the key follow-up actions to the Annual Colloquium on Fundamental Rights in 2016.123 Moreover, the European 
Audiovisual Media Services Directive (AVMSD, 2010) requires both the development of media literacy in all sections 
of society and measurement of its progress.124 

The Monitor bases its definition of media literacy on both the AVMSD text and on the European Association for 
Viewers Interests’ (EAVI) media literacy study carried out in 2009: 

“Media  literacy  is  an  individual’s  capacity  to  interpret  autonomously  and  critically  the  flow,  substance,  value  and 
consequence  of  media  in  all  its  many  forms”  (EAVI,  2009).  “‘Media  literacy’  refers  to  skills,  knowledge  and 
understanding  that  allow  consumers  to  use  media  effectively  and  safely.  Media-literate  people  are  able  to  exercise 
informed choices, understand the nature of content and services and take advantage of the full range of opportunities 
offered  by  new  communications  technologies.  They  are  better  able  to  protect  themselves  and  their  families  from 
harmful or offensive material” (AVMSD, 2010).

The MPM indicator covers two dimensions of media literacy: environmental factors, and individual competencies, 
which  follow  the  logic  of  the  categorization  used  by  EAVI  (2009,  p.  5).  EAVI  defines  environmental  factors  as  a 
set  of  contextual  factors  that  impact  the  broad  span  of  media  literacy,  including  informational  availability,  media 
policy, education and the roles and responsibilities of stakeholders in the media community. Individual competences 
are  defined  as  an  individual  capacity  to  exercise  certain  skills  (including  inter  alia  cognitive  processing,  analysis, 
communication). These competences draw on a broad range of capabilities, and embrace increasing levels of awareness, 
the capacity for critical thought and the ability to produce and communicate a message (EAVI 2009).

The media literacy indicator scores medium risk on average (45%). As illustrated in Figure 1.4.10. circa one third of 
the countries (9) show low risk, while six countries show high risk. Examining the data in more detail, two thirds of 
the countries either have underdeveloped media literacy policies or no media literacy policy at all. Moreover, in most 
countries, limited efforts are dedicated to teaching media literacy both in and outside schools. In circa two thirds of 
the countries, the media literacy subject is either absent or present only to a limited extent in the education curriculum 
or in non-formal education. Media literacy activities are widespread across the country and across different groups 
of people only in seven countries. 

 European Commission (2016). “The European Commission presents follow-up actions from Fundamental Rights Colloquium on 

123 
media pluralism and democracy”. Published: 9 December 2016. http://ec.europa.eu/newsroom/just/item-detail.cfm?&item_id=51071 
124 
 The AVMSD is currently under revision. The latest developments show that the European Parliament’s Committee for Culture and 
Education has on 25 April 2017 proposed to maintain media literacy measures in the Audiovisual Media Services Directive (AVMSD). Source: 
EAVI (2017). Press Release: European Parliament Votes for Media Literacy. https://www.eavi.eu/5637/?lang=it

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Figure 1.4.10. Media literacy -  Map of risks per country

The first sub-indicator assesses the media literacy environment, and covers the quality of the media literacy policy, the 
presence of media literacy in the education curriculum and in the non-formal education offer, and the extent of media 
literacy activities carried out. Two thirds of the countries do not have a fully developed media literacy environment 
(medium or high risk), and five countries score high risk (Malta, Bulgaria, Montenegro, Italy and Latvia).

In terms of media literacy policy, the results show that two thirds of the countries (20) have no or underdeveloped 
media  literacy  policy.  Half  of  the  countries  (15)  have  policies  in  place  but  these  are  not  comprehensive  (medium 
risk). Five countries (Bulgaria, Estonia, Romania, Italy and Malta) have no media literacy policy at all (high risk). 
For example in Italy, there are no legal documents framing media literacy and no designated authority that oversees 
media  literacy  initiatives.  There  are  national  policies  regarding  the  promotion  of  digital  literacy.  However,  these 
policies focus primarily on the incorporation of technologies in the learning environment, which is not the same as 
media literacy. In the case of Austria, which scores medium risk, there are a lot of initiatives fostering media literacy 
competence among young people and improving media-pedagogical work (mainly sponsored and/or hosted by the 
Federal Ministry for Education, Arts and Culture). However, a comprehensive governmental strategy is missing. An 
expert in media literacy interviewed by the Austrian country team stresses that an effective policy is needed to foster 
media literacy as a key component of the mandatory school curriculum for all children and schools.

Two  variables  in  this  sub-indicator  focus  on  media  literacy  education,  covering  both  formal  and  non-formal 
education. The presence of media literacy in the compulsory education curriculum is recommended by the European 
Commission,  and  considered  to  be  a  key  competency  for  lifelong  learning  by  the  European  Parliament  and  the 
Council.125 The first variable assesses whether media literacy is present in the education curriculum, as a separate 
subject, as a cross-cutting subject or as part of another subject (e.g. ICT or language). In two thirds of the countries 
media literacy is either absent or present only to a limited extent in the education curriculum (high or medium risk). 
It is completely absent from the education curriculum in Malta, Italy, Lithuania, Croatia and Bulgaria. 

Regarding media literacy in non-formal education, the MPM defines this as learning and training which takes place 
outside  recognised  educational  institutions,  e.g.  with  community  groups  and  civil  society  organizations.126  In  two 

 Introduction of media literacy in the compulsory education curriculum is recommended in the Commission Recommendation of 20 
125 
August 2009 on media literacy in the digital environment for a more competitive audiovisual and content industry and an inclusive knowledge 
society (2009/625/EC) and is part of the provision of key competences for lifelong learning, set out in the Recommendation of the European 
Parliament and of the Council of 18 December 2006 on key competences for lifelong learning.
126 

 Non-formal education is defined as learning and training which takes place outside recognised educational institutions (Tight 1996). 

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thirds  of  the  countries  (19),  the  media  literacy  subject  is  present  in  non-formal  education,  but  only  to  a  limited 
extent (medium risk). On the positive side, it is completely absent from non-formal education only in Austria, Latvia 
and Montenegro (high risk). In Montenegro, the media literacy expert interviewed by the country team stated that 
non-formal initiatives related to media literacy are sporadic and mainly carried out in the framework of very few 
international  projects  that  involve  civil  society.  The  expert  also  underlined  that  support  from  the  media  and  the 
private sector in this area is missing.

The MPM also assesses the extent of media literacy activities, such as trainings, information days and distribution 
of information, and more generally as education of users, especially young people, parents and teachers on media 
literacy. Media literacy activities can be carried out by civil society organisations, public or private bodies. The aim of 
this variable is to capture also what is going on in addition or outside of state initiatives. Media literacy activities are 
widespread across the country and across different groups of people only in seven countries. Two thirds score medium 
risk, which means that activities on media literacy are limited to some parts of the country or to certain groups of 
people. In three countries (Malta, Latvia and Montenegro) media literacy activities are hardly ever conducted.

The second sub-indicator covers individual competencies and focuses particularly on digital skills.127 The assessment 
is based on data from a composite indicator from the European Commission’s Digital Scoreboard Agenda,128 which 
has been shaped into two variables in the Monitor: (1) digital usage skills, and (2) digital communication skills.129 The 
former contains the measurement of individuals who have basic software skills, information skills and problem solving 
skills, hence focusing mainly on technical skills and on the ability to retrieve information. The latter measures digital 
communication skills, emphasising skills needed for exchanging information, participating (in social networks) and 
sharing content. As illustrated in Figure 1.4.11 more than two thirds of the countries (22) scored medium or high risk 
on this sub-indicator. Most of the countries are in the same risk band regarding the digital usage and communication 
skills.130 The Figure represents the share of individuals, who are using the internet, with basic or above basic digital 
usage and communication skills in a given country.

 It is worth noting that the sub indicator does not include any direct measure of the ability to interpret or to critically assess on- or 

In general, formal education is linked with schools and training institutions; while non-formal education takes place with community groups 
and other organizations. The types of non-formal education considered are training, research and studies of media literacy.
127 
offline content.
 “Recognising the crucial role of digital competence in today’s society, the European Commission’s 2010 Digital Agenda for Europe 
128 
devoted a whole pillar to digital literacy, skills and inclusion.” https://ec.europa.eu/digital-single-market/en/download-scoreboard-reports and 
the result was a “Digital skills indicator” in the Digital Scoreboard: https://ec.europa.eu/digital-single-market/en/digital-scoreboard 
129 
available at: https://ec.europa.eu/digital-single-market/en/download-scoreboard-reports 
130 
is at high risk on usage and medium risk on communication skills.

 There are only three exceptions: Croatia and Greece are at medium risk on usage and high risk on communication skills; and Portugal 

 The Digital skills Indicator based on the 2015 data of the Digital Scoreboard Agenda. The accompanying methodological note is 

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Figure 1.4.11. The level of risks on digital usage and communication skills131 

Legend:  The  risk  levels  are  represented  by  green  (low),  yellow  (medium)  and  red  (high  risk).  The  first  column  per 
country represents the percentage of respondents with basic or above basic digital usage skills and the second one digital 
communication skills.

Despite  the  fine-tuning  of  the  MPM2016  compared  to  MPM2015,  the  MPM  media  literacy  indicator  still  has 
considerable limits. The CMPF gathered a number of international media literacy experts for a consultation regarding 
the improvement of the media literacy indicator in Florence in November 2016 (see Annex II for further details about 
the outcome of the consultation). The experts confirmed that the main gap of the current media literacy indicator 
is  the  lack  of  questions  on  capacity  of  individuals  to  analyse,  interpret  and  produce  media  messages.  To  capture 
these crucial dimensions, it is necessary to conduct an EU-wide survey of individuals, which would go beyond the 
MPM2017 remits.

131 
 Source: DATASET: Individuals’ level of digital skills [isoc_sk_dskl_i]. TIME: 2015. IND_TYPE: All Individuals using the internet 
at least once a week in the last 3 months. Country data for EU:28 and Turkey (no data for Montenegro). Eurostat (2015). http://ec.europa.eu/
eurostat/data/database?node_code=isoc_sk_dskl_i 

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1.5 CONCLUSIONS

The MPM2016 findings confirm most of the trends from previous test-implementations, and in particular corroborate 
the observation that no country is free from risks when it comes to media pluralism. Detailed results for each country 
can be found in the country narrative reports, as a result of the work done by the MPM2016 national country teams. 
While the country reports explain the context and the specificities of each media environment, the general trends 
emerging from the cross-cutting analysis of the data are summarised in this section.

Figure  1.5.1  The  average  scores  per  indicator  for  EU-28  and  EU-28,  Montenegro  and 
Turkey

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Figure 1.5.1 gives an overview of the average scores per indicator under each MPM area, and compares the averages 
per  indicator  in  EU-28  with  the  averages  in  EU-28,  Montenegro  and  Turkey.  With  the  exception  of  the  indicator 
on  Media  ownership  concentration  (horizontal),  risk  scores  of  EU-28  are  lower  than  those  of  the  EU-28  and  the 
two candidate countries. Disaggregate data show that the very high scores of Turkey strongly contribute to raising 
the average risk for the indicators on Protection of freedom of expression, Protection of right to information, and 
Independence and effectiveness of the media authority.  In contrast, the risk scores of Montenegro are in general more 
comparable with the EU-28 averages. 

Amongst the 20 indicators of the MPM2016, concentration of media ownership, especially horizontal, represents one 
of the highest risks for media pluralism and one of the greatest barriers to diversity of information and viewpoints 
represented in media content. In addition to sector-specific economics, including high entry barriers and the ability 
to reap large economies of scale, another factor which has driven concentration of media ownership is regulatory 
leniency. A tolerant approach towards mergers and acquisitions in the media sector and the trend towards relaxation 
and/or abolition of ownership restrictions in several countries (e.g., the UK, Spain, and the Netherlands) have enabled 
large media groups to expand throughout the EU and to thereby solidify their presence in numerous media markets. 

The lack of transparency is another important risk captured by the MPM on different levels and in different relations 
to media operations. Be it the transparency of media ownership or the transparency of state support to media, it is 
one of the essential preconditions of accountability and trust in the media, as well as one of the key safeguards from 
political and commercial interference. Many European countries still lack reliable and accessible information on who 
owns and controls the media. This makes it difficult for the public to understand the biases in media content and 
impedes a proper assessment of risks for media pluralism. It is therefore of utmost importance to make data on media 
ownership available and to support studies on the political affiliations of media owners. As a first step, all national 
regulatory bodies that are concerned with media should be entrusted with the task of collecting and making publicly 
accessible (online) data on media ownership. Moreover, to ensure the independence of media, governments should 
make data on allocation of state subsidies and advertising fully transparent. The MPM results show that currently only 
a few countries have a system in place for doing so. 

Regarding  the  basic  conditions  for  media  pluralism,  the  MPM2016  illustrates  a  generally  positive  picture  of  the 
situation in Europe. Most of the indicators in the area of Basic protection score low risk on average (see Figure 1.5.1) 
and the regulatory framework on freedom of expression is in line with international standards in most of the analysed 
countries. However, the basic guarantees for an “enabling environment” for freedom of expression and journalism are 
deteriorating in a growing number of countries. This is mainly due to the chilling effect of awarding high damages 
and to the criminal legislation on defamation, and to limitations to freedom of expression on the basis of national 
security requirements or state of emergency situations. The situation in Turkey is an example of particular concern in 
this respect, and its risk scores in the Basic Protection area as a whole are especially high. 

The MPM2016 also shows that basic guarantees for journalists are not fully ensured across Europe. The indicator on 
the Journalistic profession, standards and protection scores an average 30%, which is a significant level of risk, despite 
belonging within the low risk band. In particular, the editorial autonomy stands out as one the most vulnerable aspects 
of media systems, susceptible to both commercial and political influences. Regulatory or self-regulatory provisions on 
the autonomy of journalistic and editorial work are present in most of the examined countries. However, they are usually 
insufficient or inefficient in ensuring that journalists and editors operate in an independent and free environment. 
Particularly  neglected  is  the  role  of  editors-in-chief.  Bearing  in  mind  that  this  person  holds  the  responsibility  for 
editorial policies and operations, and stands between the newsroom and the owner (who might have different political 
or commercial interests) it is alarming that most countries have no safeguards to guarantee neither involvement of the 
newsroom nor autonomy when appointing and dismissing editors-in-chief. There is at least occasional interference 
in relation to these procedures in almost two thirds of examined countries. Even in some countries where there is 
no evidence of unwanted influence, the related decisions are usually made behind closed doors, especially in case of 
private media companies. 

The  PSM  have  more  obligations  to  ensure  independence  in  appointing  and  dismissing  editors-in-chief,  and  more 
monitoring is done in this regard. Nevertheless, political interference is still reality in many European countries. The 
MPM2016 confirms the findings of the two MPM pilot studies carried out in 2014 and 2015, suggesting that there are 
relatively high risks of politicization of PSM through appointment procedures, not only of editors but also of people 
in managing and board functions. A stronger independence from political interests would help the PSM to strengthen 
their role in a media landscape that is facing increasing disruption. 

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Overall, to ensure appropriate standards on editorial autonomy, the role of the organisation in both private and public 
“media companies” must be acknowledged as being essential for media pluralism. 

Independence is needed also as regards the governance of the media system. The MPM2016 data show that media 
authorities,  notwithstanding  their  political  appointment,  are  overall  perceived  (with  some  remarkable  exceptions) 
as  effective  in  regulating  the  media  market.  However,  they  often  face  strong  political  pressures.  Clearer  European 
standards on the media authorities’ competencies could help in strengthening the legal protection against instrumental 
political interferences.

Transparent  and  independent  media  systems  are  necessary  but  not  sufficient  for  achieving  pluralism.  Also  the 
diversity of the people living in Europe has to be reflected in the content and in the organisation of media. Social 
inclusiveness is the area where the MPM reveals the highest risk, after Market plurality. The risks relating to access 
to media for minorities and for women are particularly high. The MPM shows that women are underrepresented in 
managerial positions in media organisations, and in news content. Many of the assessed countries are also failing to 
provide adequate and proportional access to media for the numerous minorities residing in the European Union. 
Moreover, the analysis points to gaps in regulatory safeguards for local and community media across Europe, as well 
as a complete lack of community media in certain countries. This raises serious concerns, since decentralized and 
community media are particularly important for local democracy, and because local and regional news outlets are 
currently struggling to survive. 

Finally,  the  MPM  reveals  significant  risks  relating  to  media  literacy.  An  overwhelming  majority  of  European 
countries  either  have  an  underdeveloped  media  literacy  policy  or  no  media  literacy  policy  at  all.  Most  countries 
are  also  dedicating  limited  efforts  to  teaching  media  literacy  in  and  outside  schools,  while  only  a  few  countries 
showcase widespread media literacy activities across different socio-cultural groups. Overall, the MPM analysis and 
the consultation with international experts in the field reveal that a proper assessment of media literacy in Europe 
necessitates the implementation of an EU-wide survey of individuals in order to evaluate the capacity of individuals to 
analyse, interpret and produce media messages. In terms of policy measures, the EU Member States should ensure that 
they have comprehensive media literacy policies in place and that these put an emphasis on developing critical skills 
of citizens across different age groups and different socio-economic backgrounds. Moreover, Member States should 
make media literacy an obligatory topic in the primary and secondary school curricula, and invest in teacher and 
educator training to ensure an adequate level of education in media literacy. At the EU-level, the CMPF recommends 
that the EU puts responsibility on Member States to promote media literacy in their countries. Moreover, measures at 
country and EU levels to enhance critical skills of online users are crucial for media pluralism. 

Overall, the findings of the MPM2016 implementation confirm that no EU Member State is free from risks to media 
pluralism. The observed risks are best understood considering the specificity of each country context, including its 
distinct media and political systems. At the same time, measuring risks to media pluralism is an essential exercise 
for the promotion of both media pluralism and media freedom. By doing this, the MPM provides a basis for further 
analysis  by  researchers  and  civil  society  and  for  policy-making,  with  the  ultimate  aim  to  foster  an  informed  and 
democratic debate on the future of our media.

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2. METHODOLOGY. THE RESEARCH DESIGN

The Media Pluralism Monitor organises the risks for media pluralism into four main areas: Basic Protection, 
Market Plurality, Political Independence and Social Inclusiveness. This categorisation allows for an assessment that 
encompasses the different components and meanings of “media pluralism”. These areas are assessed according to the 
scoring of 20 indicators and 200 variables in total. 

The research design of the MPM is based on a questionnaire that is compiled by the national country teams, which 
consist of experts in media pluralism and media freedom. The questionnaire is composed of legal, economic and 
socio-political questions in order to allow an assessment of media pluralism risks in any given country, taking into 
account the legal framework, its implementation, and the effective conditions of the media landscape. Legal and socio-
political questions are closed, while economic questions ask for a numeric value that is translated into a level of risk. 

For  a  number  of  particularly  sensitive  and  complex  indicators  the  MPM  employs  an  external  peer  review,  called 
Group of Experts. This group of experts, which includes national stakeholders and experts in the area, conduct a 
review of the answers to questions that require a qualitative type of measurement and/or cannot be based on 
measurable and easily verifiable data.

Data for MPM2016 was gathered through a structured questionnaire with closed questions (except for the economic 
questions, but benchmarks are set for these in order to calibrate them into qualitative answers – please see the ‘User 
Guide’ in the appendix IV for details). This method allowed for the gathering of both quantitative and qualitative data, 
which proved to be crucial in assessing the risks for media pluralism in the EU. Additionally, this method allowed the 
quantitative analysis of answers and the production of a numerical risk assessment, which is important in order to 
obtain comparable results across countries.

The data is collected using an online platform that was developed by the CMPF. The CMPF checks and supervises the 
quality and consistency of the data collected and of the methodology used. 

The final assessment per area of risk is carried out using a standardised formula, that was developed by the CMPF. 

Each variable is assessed by a question and receives a score from 0 to 1 according to the specific answer. The legal 
questions (yes/no replies) are rated 0 or 1. The other variables (three-option replies) are rated 0/0.5/1 according to the 
band into which the reply falls. The overall result is the average of variables of the same question type.

The MPM is a holistic tool designed to identify the potential risks to media pluralism in Member States. The research 
design  of  the  MPM2016  was  developed  and  tested  during  the  two  pilot  implementations  of  the  Monitor  in  2014 
and 2015. The MPM2016 mostly focuses its analysis on news and current affairs. However, it must be noted that, 
as in previous MPMs (2014 and 2015), “all indicators that assess the general universality of media coverage and the 
outreach of the diffusion of information” (CMPF, 2015 and 2016) are included in the MPM2016. “They are considered 
to be basic indicators that are relevant to the infrastructure and universality principles as a whole” (CMPF, 2015 and 
2016).  In  particular,  indicators  on  access  to  media  for  minorities,  people  with  disabilities,  and  media  literacy,  are 
preserved as part of this holistic principle. 

In order to meet the challenges emerging from this periodic large scale comparative analysis, the MPM2016 is mostly 
informed by secondary data, collected through a questionnaire, and supplemented with primary data gathered through 
interviews and document analyses (e.g. of legal and academic texts), together with a group of experts’ evaluation of 
the variables that were difficult to measure and/or that required a qualitative type of measurement and/or showed a 
lack of measurable and easily verifiable data. In addition, the first MPM pilot-test implementation (2014) revealed 
that there are many reliable, available materials which can be used as primary and secondary sources, e.g., national 
laws, case law, decision practice, governmental documents, NGO reports, official statistics, and academic research. 
Therefore, the secondary data analysis has proved to be a useful approach to ensure reliable and valid findings in the 
context of this project.

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2.1 MPM2016 STRUCTURE AND CALIBRATION

All of the questions in the MPM2016 questionnaire have been classified as variables. Variables are grouped into sub-
indicators, and sub-indicators into indicators, which are integral parts of each MPM2016 area. 

In addition, each question in the questionnaire has been classified as belonging to one of the four question types: Legal 
existence (L-e) questions, focused on whether or not a particular provision exists in a country’s legal framework; Legal 
implementation (L-i) questions, designed to examine whether due process is in place to ensure the effectiveness of 
the legal safeguard; Socio-political (S) questions examine the actual practice (i.e., a reality check); while economic (E) 
questions were designed to assess the risk based on the economic data (e.g., market revenues, audience shares) that 
are related to media pluralism. 

In order to determine the risk for each variable, sub-indicator and indicator, a standardised formula has been applied 
to the entire MPM2016 questionnaire. The formula was designed by drawing from previous studies in which indices 
were based on a list of questions/indicators where answers were calibrated on a scale from 0 to 1 (e.g., Gilardi, 2002; 
Hanretty, 2009). In other words, in the process of calibration quantitative and qualitative answers of both dichotomous 
(e.g., yes - no) and polychotomous (e.g., low, medium, high risk) nature have been transformed into a scale ranging 
from 0 to 1, assigning values to the answers of the Monitor.

Each variable received a score from 0 to 1, according to the answer to the specific question, with scores closer to 0 
pointing to a low risk assessment, and those closer to 1 pointing to a high risk assessment. Specifically, answers to the 
Legal-existence (L-e) questions, whose response type was yes/no, were coded as 0 or 1. Questions with a three-option 
reply (low, medium, high risk) were coded as 0, 0.5 or 1, according to their risk assessment. The same calibration was 
applied to the Economic questions (E), whose answers were firstly transformed into qualitative replies (low, medium, 
high risk), based on set benchmarks. 

The  MPM2016  kept  the  innovation  of  the  second  round  of  piloting  (MPM2015)  -  the  possibility  to  answer  using 
the options ‘not applicable’ and ‘no data’ to all questions. The option ‘not applicable’ has been introduced to better 
capture the specificities of the national contexts and to allow for the exclusion of questions which are irrelevant, or 
that are not applicable to a country’s media system. For example, if a country does not have any state subsidy to media, 
the  questions  relating  to  existence  and  implementation  of  the  legislation  to  ensure  fair  and  transparent  allocation 
were coded as ‘not applicable’. This reply option was also used with logically dependent variables. For example, if the 
variable question asks whether there is a media law that aims to secure the pluralism of political viewpoints in the 
PSM reporting, and the answer to this question is ‘no’, then  the following variable which asks about effectiveness of 
the law has also been coded as ‘not applicable’. It was decided that all questions coded as ‘not applicable’ would be 
excluded from the final calculation. 

As the previous implementations have shown, some of the economic data are missing across many of the EU Member 
States, and in order to better capture this information, the Monitor allows the option of a ‘no data’ answer. Following 
the choice of this answer, the country teams were asked to evaluate whether the lack of data represents a transparency 
problem within their national context, i.e., to evaluate whether the lack of data should be seen as being problematic 
in their country. In this way also, the specific characteristics of the national context were accounted for, since there 
may be a variety of reasons why certain data are not available/accessible across EU Member States and Candidate 
Countries, and not all of these reasons may be causes for concern.

In order to ensure that all ‘no data’ answers contributed to national risk assessments in the same way, a standardised 
procedure to assign values to the ‘no data’ answers was developed by the CMPF. According to this procedure, each ‘no 
data’ answer was coded and assigned one among the following three possible values:

1) 

2) 

3) 

Low Risk: a value of 0.25;

High Risk: a value of 0.75;

Missing data are interpreted as a ‘not applicable’ answer and are excluded from the analysis.

The number of the ‘missing data’ values was limited, as much as possible, and was adopted only as a residual category in 
cases where comments that evaluated the reason behind the lack of data were missing, incomplete, or were impossible 
to interpret.

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In other cases, the following procedure was applied:

Firstly, if the team member took a position in the answer, indicating that a high risk is present, or, in contrast, that the 
lack of data is not problematic, the CMPF has followed this suggestion and has coded the ‘no data’ accordingly, with 
either a low or a high risk value. In cases where the answer was vague, or where its meaning had to be deduced, the 
following criteria were considered:

a) 

b) 

c) 

Taking into account the local context: If the data are not collected because they are considered to be of  
limited  interest, e.g., because the country is too small to collect detailed information, because a particular   
medium has a very limited reach, etc., a ‘low risk’ value was assigned 

If there is a legal requirement to collect the lacking data, a ‘high risk’ value was assigned

For questions concerned with the audience data and the revenue/market share data:

• 

• 

• 

if  the  country  presents  data  on  audience,  but  not  on  revenues/market  share:  the  market  share  data  is 
excluded from the analysis, i.e., the answer is given a ‘missing data’ value, meaning that the findings are 
based on the audience variable alone. In other words, the revenue data are considered to be optional.

if the country presents data on the revenues, but not data on audience shares: the lack of audience shares 
data is coded as being ‘high risk’ in all cases, since it is the standard reference for the market. 

if  the  country  produces  neither  data  on  the  audience,  nor  on  the  market  share:  according  to  above 
mentioned rules, the lack of audience shares’ data is coded as being ‘high risk’, and the lack of market 
shares data as being ‘missing data’

All ‘no data’ assigned values have been double coded, meaning that two independent coders assigned to each ‘no data’ 
answer one of the three values. In cases where the coders disagreed, a discussion was held between the coders until a 
consensus about the final value was achieved.

MPM2016 AGGREGATION METHOD

The aggregation method relied on the approaches used in previous studies (for an overview see Hanretty and Koop, 
2012),  but  taking  into  account  the  traditions  and  logic  of  the  Media  Pluralism  Monitor  project.  Specifically,  the 
method based on the mean of the item scores, used as the most common aggregation method in calculating indices, 
was updated to take into account the logic of the MPM, which has traditionally relied on the groupings of legal, socio-
political and economic indicators. Consequently, the procedure for establishing the risk assessment of an indicator 
was as follows:

1)  

2)  

3)  

4)  

5)  

6)  

7)  

calculate the mean of L-e variables within the sub-indicator

calculate the mean of L-i variables within the sub-indicator

calculate the mean of 1) and 2). This is the value of the L within the sub-indicator (the L variable is ‘e’ or ‘i’   
according to the type of opening question/variable)

calculate the mean of E variables within the sub-indicator

calculate the mean of S variables within the sub-indicator

calculate the mean of 3), 4) and 5). This is the result of the sub-indicator.

the value of the indicator is the mean of all its sub-indicators.

Finally, the risk assessment of the area is calculated as the mean of all its indicators (five per area). It should be noted 
that all values were presented as percentages for ease of use and interpretation (e.g., a score of 0.46 is presented as a 
risk of 46%).

The results for each area and indicator are presented on a scale from 0% to 100%. Scores between 0 and 33% are 
considered low risk, 34 to 66% are medium risk, while those between 67 and 100% are high risk. On the level of 
indicators, scores of 0 were rated 3% and scores of 100 were rated 97% by default, to avoid an assessment of total 
absence or certainty of risk. This trimming of the extreme values, as a methodological novelty of the MPM2016, has 
been developed in a collaboration with Gianni Betti132, Professor of Statistics at the University of Siena. 

132 

 Gianni Betti: https://www.deps.unisi.it/en/department/staff/faculty/gianni-betti 

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The procedure for determining the risk assessment of variables, sub-indicators, indicators and areas, detailed above, 
allowed the MPM to benefit from a standardised formula for all levels of the Monitor. This enhanced the comparability 
of results among the different levels of the Monitor, decreased the arbitrariness in assessing the risk assessments of the 
various indicators, and, overall, this increased the validity and reliability of the findings. Furthermore, this formula 
also contributed to establishing a better balance between the evaluation of the legal framework (L variables) with the 
evaluation of the actual practice, captured by socio-political and economic variables. Finally, the MPM formula also 
enabled the establishment of risk assessments which are better tailored to the specificities of the national contexts 
(through  the  introduction  of  the  ‘not  applicable’  and  ‘no  data’  answers).  In  this  way,  the  differences  between  the 
Member States were better captured and reflected in the risk scores. 

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2.2 DATA COLLECTION

Given that the MPM’s research design rests on two main methods - a questionnaire and a group of experts’ evaluation 
- two main types of data were collected during its implementation - answers to the questionnaire, and comments from 
the experts engaged in the evaluation of the answers. 

THE QUESTIONNAIRE

The MPM2016 questionnaire was answered by national teams that were composed of renowned experts in media 
pluralism and media freedom in each of the countries analysed, excluding Italy and Malta, for which the data collection 
was carried out by the CMPF team. As in previous pilot implementations, cooperation with national teams of experts 
proved to be essential during the implementation of the MPM2016. Firstly, due to the necessity of relying on secondary 
data, which is often in the native language, it was essential to have local experts who were able to collect these data, 
but also to evaluate their reliability and validity. Another benefit of using a local team to implement the Monitor was 
the ability to build on their access to their local networks, particularly access to the local stakeholders. Given that 
one of the objectives of this project is to establish and maintain contacts with the relevant stakeholders, local teams’ 
input in growing the network of informed stakeholders who join in the discussions on media pluralism, proves to 
be invaluable. Finally, local teams are fundamental in providing answers to socio-political questions. In answering 
some of these questions, local teams have to provide their expert evaluation, since objective ways of measurement are 
sometimes missing. Hence, having a reliable and independent local team which consists of renowned experts in this 
field, was crucial for the implementation of this project.

Figure 2.2.1. Local team leaders that carried out the implementation of the MPM2016

 COUNTRY

INSTITUTION

Austria

Belgium
Bulgaria
Croatia

Cyprus 
Czech Republic
Denmark
Estonia
Finland
France
Germany
Greece

Hungary
Ireland
Italy
Latvia
Lithuania
Luxembourg
Malta
Montenegro
Netherlands

Poland 

Institute for Comparative Media and Communication 
Studies (CMC)
KU Leuven
Foundation media democracy
Institute for Development and International Relations 
(IRMO)
University of Nicosia
Charles University
Roskilde University
University of Tartu
University of Jyväskylä
Sciencepo
HIIG & Hans Bredow Institut
ELIAMEP

CEU/CMDS
Dublin City University
European University Institute
Riga StradinsUniversity
Vytautas Magnus University
University of Luxembourg
European University Institute
Media Consultant
Centrum voor Recht & ICT – Rijksuniversiteit Gron-
ingen
University of Krakow

KEY PERSON

Josef Seethaler

Peggy Valcke
Orlin Spassov
Paško Bilić

Christophoros Christophorou
Vaclav Stetka
Ida Willig
Halliki Harro-Loit
Ville Manninen
Thierry Vedel
Hermann Schroeder
Evangelia Psychogiopoulou/ Anna 
Kandyla
Amy Brouillette
Roddy Flynn
CMPF
Anda Rozukalne
Aukse Balcytiene
Raphael Kies
CMPF
Dragoljub Vukovic
Mathieu Paapst

Beata Klimkiewicz

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Portugal
Romania
Slovakia
Slovenia
Spain
Sweden
Turkey
United Kingdom

Universidade Nova de Lisboa
Median Research Centre & CEU
Pan European University
University of Ljubljana
Universitat Ramon Llull
University of Gothenburg
Galatasaray University
University of Westminister

Francisco Rui Nunes Cádima
Marina Popescu
Zeljko Martin Sampor
Marko Milosavljević
Pere Masip
Mathias A. Färdigh
Yasemin Inceoglu / Ceren Sözeri
Jelena Dzakula

Local teams provided answers to the questionnaire, accompanied by comments in which the rationale for the answer 
was described, and the sources on which the answer was based. This was inserted on the online platform designed 
and further developed during the pilot-test implementation (2014, 2015). The platform allowed for centralised data 
collection and the comparison of answers, and it is an invaluable asset in a cross-national comparison of this scale. The 
platform contains not only the questionnaire and the answers to it, but also detailed descriptions of variables/questions, 
suggested databases and methods of measurement, a glossary of definitions, FAQs, and other elements which were 
designed in co-operation with local teams in order to facilitate data collection and to ensure its comparability and 
high quality. 

Another  benefit  of  the  online  platform  as  a  centralised  data  collection  vehicle  was  that  it  allowed  the  CMPF  to 
continuously monitor the progress of the data collection, in order to verify the quality of the responses, and to provide 
feedback to the local teams on how to review their answers in order to increase their quality and/or comparability. 
Specifically, during the data collection of the answers to the MPM2016 questionnaire, the quality and comparability of 
the answers was checked by the CMPF following two checkpoints, one at the end of May. When 50% of the answers for 
the questionnaire were due, and another at the end of June, when 100% of the answers to the questionnaire were due. 
Frequent centralised verifications of the local teams’ answers were necessary in order to ensure that all of the teams 
had understood a question in the same way, that the sources used for the answers were relevant and adequate, and 
that the evaluations of the answers were carried out and were based on the same criteria across countries. In addition, 
frequent validation points have ensured that the final datasets are as complete and comparable as possible, and also 
that the time-frame and deadlines for the project were followed and respected. 

One of the biggest challenges of the MPM in general is to ensure the validity and reliability of the data, which were 
based on the evaluations and answers to those questions for which no objective measurement exists. Building on the 
experience of the pilot-test implementations, this implementation also relied on the revision of particularly sensitive 
and/or difficult to measure questions by national experts and stakeholders. This part of the research design ensured 
that the validity of the results was increased, and that relevant stakeholders had a say in the project and an opportunity 
to share their views and opinions.

GROUP OF EXPERTS’ PROCEDURE

The procedure for the group of experts’ evaluations is now already a standard. The process starts by the local teams’ 
nomination of seven experts and stakeholders in the national media system. All local teams are asked to nominate 
specialists  with  substantial  knowledge  and  experience  in  the  field  of  media,  who  have  a  good  reputation  in  their 
professional community. The group of national experts is supposed to consist of experts from various fields, namely:

● 

● 

● 

● 

● 

● 

2 Academic/NGO researchers on social/political/cultural issues that are related to the media; 

1 Academic/NGO researcher in media law and/or economics;

1 Representative of the media regulators;

1 Representative of a journalists’ organisation;

1 Representative of a publishers’ organisation;

1 Representative of a broadcasters’ organisation.

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The  aim  of  this  specific  composition  of  the  group  of  experts  is  to  ensure  that  all  of  the  relevant  stakeholders  are 
represented, and their views taken into account. 

Once the group of experts for a particular country is defined and confirmed, experts are given access to the MPM2016 
platform  and  the  questions  that  they  are  supposed  to  evaluate.  These  questions,  and  the  local  teams’  answers  to 
them, are previously checked by the CMPF team and, if needed, revised in collaboration with the local team. Hence, 
the answers to the questions that are subjected to the experts’ evaluations are as complete as possible and they are 
motivated by comments and sources before the experts are given access to them. 

Once they are granted access, the experts are asked for confirmation of the accuracy of the country team’s evaluation. 
Each  member  of  the  group  of  experts  records  her/his  agreement  or  disagreement  with  the  scoring  on  the  MPM 
platform, or, alternatively, they have the option to declare that a specific question does not fall within his/her field of 
expertise. In a case when an expert disagrees with the scoring, s/he needs to provide a short written explanation and 
a suggestion for an alternative score on the platform. Once experts complete their evaluations, the country teams 
are asked to review the feedback of each member of the group of experts and to take their views into account when 
providing the final answer to the questions that is a subjected to expert evaluation. Country teams do not necessarily 
need to change their answers if any of the experts disagree with their initial answer, but if this is the case, they are asked 
to explain why they have decided to keep their original answer and to address, in a comment to the final answer, any 
disagreement that is expressed by the experts involved. 

Although the procedure described above ensures that this part of the methodology is applied to all countries’ data 
in a standardised  and consistent  way,  which  increases the comparability of the findings and the robustness of the 
method, several challenges were faced in its implementation. In the first place, a problem was detected in regard to 
nominations in small countries, in which some of the organisations whose representatives were sought did not exist, 
or where there is limited availability. In such cases, exceptions were made, and their group of experts consisted of 
fewer than seven representatives. Additionally, another challenge which was faced was in ensuring the nominated 
experts’ participation. Given that the Monitor’s language is English, some experts faced language barriers, while some 
others weren’t able to participate due to time constraints and previous engagements. Due to the time constraints of the 
project, the decision was made that the group of experts’ procedure was considered finished, either by the fact that all 
of the nominated experts had participated, or that each question has been evaluated by more than half of all experts 
(i.e., four of seven) by the time that the data collection had to close in order that the project meet its deadlines. 

The group of experts, both as a method and as an activity involving stakeholders, proved to be of great value to the 
project. From the methodological perspective, this procedure ensures higher reliability and the validity of answers to 
particularly sensitive and/or difficult to measure questions. Experts also contribute to data collection by providing 
alternative information and sources, which the country teams might not have initially take into account. Finally, by 
employing this procedure, it is ensured that a range of opinions from the most relevant stakeholders within a media 
system are acknowledged and made known. The group of experts’ procedure is also beneficial to the project as an 
activity through which relevant stakeholders are not only informed about the project, but are also able to be actively 
engaged in it. 

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2.3 IMPROVEMENTS FROM MPM2015

The MPM2016 methodology is the result of a thorough analysis of the shortcomings in two rounds of the Monitor’s 
pilot testing. A first revision, following the first pilot implementation in 2014, was based on the SMART criteria. The 
CMPF asked the local teams of the initial 9 selected countries to score and assess the validity of each of, back then, 34 
indicators:

● 

● 

● 

● 

● 

Specific (if it had a sufficiently precise meaning, and a clear and direct link with media pluralism);

Measurable (if the indicator could be expressed by quantitative or qualitative scores);

Achievable/Attainable, if data were available or it were technically possible to obtain data within a   
reasonable time frame and at a reasonable cost;

Result-oriented: if it were feasible to define reliable border values; if there were general agreement over  
interpretation of results;

Time-bound: data can be collected frequently enough to inform the progress and influence the decisions  
(data on this criterion were not provided by all the teams, as it was not mandatory to reply to the    
related question, since the MPM was supposed to measure the status of media pluralism at a given moment  
in time).

In general terms, the analysis of the SMART data showed that legal indicators were assessed as being the most clear and 
specific, and were well selected and useful, for the specific purpose of assessing the risks for media pluralism. A better 
differentiation between the existence of legal measures and their implementation was suggested. All of the economic 
indicators were generally assessed as having a clear and direct link with media pluralism and freedom. Some questions 
were raised on the availability of the data requested, on the clarity of the methodology for measurement, and on the 
need to better differentiate the indicators, depending on whether they were applied to small or big countries. The socio-
political indicators were generally assessed as effectively describing the most important aspects of media pluralism 
and media freedom. As formulated, they had a sufficiently precise meaning, but they were the most problematic in 
terms of measurability and attainability. 

Building on these reflections, the CMPF analysed the logic of the Monitor and made an additional effort to further 
simplify it, in order to obtain a more balanced, user-friendly and streamlined tool. In some cases, major revisions 
were carried out that were based on the SMART analysis. The MPM2016 further took into consideration reflections 
during the MPM2015 pilot testing, as well as the current academic and policy debates on media pluralism topics, and, 
in particular, improvement of the measurements of pluralism in the digital world. 

Unlike  the  previous  pilot  editions,  the  MPM2016  no  longer  contains  sub-variables  to  assess  the  effectiveness  of 
implementation of legal measures. Instead of repeating the same list of sub-variables along the Monitor, the revised 
version  simplifies  the  procedure.  The  implementation  of  the  legal  framework  is  now  being  assessed  with  a  single 
variable and, in order to assess it as effective, several or all of the following aspects have to be satisfied: availability of a 
designated body monitoring compliance with the law; this body having sanctioning/enforcement powers in order to 
impose proportionate remedies (behavioural and/or structural) in case of non-respect of the law; effective use of these 
sanctioning/enforcement powers; availability of appeal mechanisms with regard to the decisions of the designated 
body; and the effectiveness of these appeal mechanisms, including the fact that they are not systematically misused to 
delay the enforcement of remedies.

DIGITAL INDICATORS

CMPF is engaged in a permanent debate with other academics and institutions who are discussing these topics in 
order to find suitable solutions for the measuring of the plurality of the offer and of the consumption of information 
online, with a special focus on the role of the online intermediaries. Several new variables have been introduced in 
2015 to strengthened the capacity of the MPM to assess online related types of risks (the safety of journalists, and the 
violation of freedom of expression online; the ownership concentration of Internet content providers and Internet 
service providers; net neutrality; the access to, and quality of, the Internet infrastructure; the use of the Internet, and 
digital skills).

Building on the experience of 2015 exercise, the MPM2016 further expanded the scope of measurement of online 
related risks to media pluralism. For example, in the Basic Protection area, a specific assessment of respect for the rule 

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of law as regards freedom of expression online was requested, as well as an assessment of arbitrary filtering, blocking 
and take down practices by governments and online intermediaries. In the Political Independence area MPM2016 
introduced the variable that explores whether the existing self-regulatory measures consider online activities of media 
and  individual  journalists,  or  whether  media  organizations  are  developing  new  digital-specific  self-regulation  to 
increase accountability and to reduce the risk of undue influences. The reasoning for this derives from the notion that 
self-regulation usually offers more flexibility and adapts more easily than state regulation in safeguarding editorial 
autonomy in ever changing conditions of online media environment.

Still, measuring pluralism in the digital world remains a very challenging task, and the best method for measurement 
remains to be found. One of the most pressing issues is the lack of reliable and comparative data that would enable 
assessment  of  particularly  important  issues  for  online  pluralism  in  recent  years,  including  (Nenadic  and  Ostling, 
2016):

•  The role of online intermediaries (such as search engines, news aggregators and social media);

•  Concentration of Internet service providers (ISPs) and Internet content providers (ICPs)

•  Media and digital literacy, focusing on the ability to interpret and to critically assess online content, as well as on 

skills needed to contribute the content production and dissemination

Therefore, the methodological effort of the CMPF to design adequate variables and to identify reliable and comparable 
data sources for digital indicators is ongoing. 

UPDATE OF THE USER GUIDE AND ENHANCEMENT OF THE ONLINE PLATFORM

The MPM platform, developed by the CMPF during the two pilot-test implementations, has been made more user-
friendly both for the CMPF team that coordinates the data collection and carries out the analysis, and for the national 
country teams that feed the database. The existing platform of the MPM tool contains the questionnaire, the user-
guide,  the  instructions  for  the  country  teams,  and  also  incorporates  the  procedure  for  the  assessment  by  external 
experts. The main novelty introduced in 2016 is the chat option that allowed for the direct, real time communication 
between the country teams and the CMPF on specific issues under each variable. This feature particularly facilitated 
the process of data verification.

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2.4 CHANGES INTRODUCED PER AREA

Alongside the general methodological improvements that are described above, a number of changes were made to 
the MPM tool in order to improve the scope, the structure and the coherence of the areas, the indicators, and the 
variables. While the general approach of the MPM remains the same, its restructuring into four areas, 20 indicators 
and 200 variables has made the tool even more balanced, user-friendly and more accessible to a broader public. 

Variables, which were found to be problematic during the two pilot-tests, have either been modified or re-worded, 
and an attempt was made to better define what was being measured in order to allow a more precise outcome. As 
a  result,  some  variables  which  were  considered  problematic,  or  that  were  simply  too  vague,  were  either  removed 
or broken down into different questions. Furthermore, a number of variables, which were not present in the MPM 
2014 and 2015, but which were considered to be important in capturing risks to media pluralism and freedom today, 
were added, including, for instance, the allocation of state subsidies to media and the assessment of filtering and/or/ 
monitoring and/or blocking and/or removing online content in an arbitrary way.

BASIC PROTECTION AREA

The Basic Protection area has kept its focus on freedom of expression, freedom of information, status of journalists 
and independence of the media authority. The new indicator under this area is Universal reach of traditional media 
and access to the Internet, which was shifted to this area from Social Inclusiveness (Universal coverage of the PSM 
and the Internet in MPM2015). It includes two variables on net neutrality that in MPM2015 were under the indicator 
Media ownership concentration (horizontal), in the Market Plurality area.

In MPM2016 the variables within the indicator on Protection of freedom have been regrouped to better highlight 
various sub-indicators: Respect of freedom of expression international standards, Guarantees for freedom of expression 
online and Proportionate balance between protection of freedom of expression and dignity. The indicator is enhanced 
with two variables under the sub-indicator on freedom of expression online, relating to filtering, monitoring and/or 
blocking and/or removing online content practices by member states and Internet intermediaries.

The indicator on Journalistic profession, standards and protection was slightly streamlined, as the few variables on 
editorial autonomy were transferred to the relevant new indicator under Market Plurality.

The indicator on Independence and effectiveness of the media authority is the result of a significant reduction of the 
MPM2015 indicator on Independence of national authorities, that aimed to assess the level of risks for media pluralism 
deriving from the level of independence of three authorities (media, competition and telecommunication) dealing 
directly or indirectly with the media market. The MPM2015 indicator was found to be particularly problematic due to 
its composite structure, because it was considered to be disproportionately large if compared to other indicators, and 
it was found to produce unreliable findings. The MPM2016 indicator focuses, then, only on the Media authority. The 
country teams were asked to consider the authority that has regulatory competences in the media market and, in case 
of concurring authorities, to consider as relevant the authority that is part of EPRA or ERGA.

Figure 2.4.1. The list of indicators of the Basic Protection area - MPM2015 and MPM2016

MPM2015

MPM2016

NOTE

Protection of freedom of expression

Protection of freedom of expression New emphasis on online freedom of 

Protection of right to information
Journalistic profession, standards and 
protection
Independence of
national authority(ies)

Protection of right to information
Journalistic profession, standards 
and protection
Independence and effectiveness of 
the media authority
Universal reach of traditional media 
and access to the Internet

expression

variables on editorial autonomy 
shifted to market plurality
focus on one relevant authority

moved from social inclusiveness. 
Added net neutrality from 
Concentration of media ownership.

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MARKET PLURALITY AREA

Compared  to  the  MPM2015,  the  most  significant  novelty  of  the  Market  Plurality  area  is  the  introduction  of  two 
new  indicators:  Commercial  influence  over  editorial  content  and  Media  viability. The  other  three,  though  slightly 
amended, are based on the same rationale as their ‘predecessors’.

The new indicator Commercial influence over editorial content seeks to assess risks to media pluralism that arise 
from the qualitative dimension of ownership concentration, that is, commercial influence over editorial content. To 
this end, variables have been introduced to evaluate a given media landscape in the light of a number of practices 
that  may  undermine  editorial  freedom.  More  particularly,  the  indicator  includes  variables  that  assess,  inter  alia, 
mechanisms granting social protection to journalists in cases where ownership and/or the editorial line change, laws 
prohibiting advertorials, regulation stipulating the obligation of journalists and/or media outlets not to be influenced 
by commercial interests and, more generally, whether the media in the landscape concerned is governed by practices 
whereby commercial interests dictate or heavily impact editorial decisions.

Media viability, as a novelty of the MPM2016, draws from relevant work undertaken by UNESCO, that emphasizes the 
importance of a supportive environment for the emergence, development, and continuance of media.133 This indicator 
mainly assesses market revenue trends in four different sectors, namely television, radio, newspaper publishing and 
online advertising. By total revenues we mainly refer to revenues generated through traditional streams, including 
advertising  revenues,  revenues  from  newspaper  circulation  and  revenues  from  the  sale  of  media  rights.  Yet,  the 
indicator  for  media  viability  also  includes  a  variable  seeking  to  assess  whether  media  companies  operating  in  the 
market under examination are currently developing non-traditional revenue streams.

The indicator on Transparency of media ownership has been amended to distinguish between transparency obligations 
vis-à-vis the public and vis-à-vis the public authorities, which was not the case in previous editions of the Monitor 
where these two dimensions were part of the same subindicator.  The reason for introducing this change to the Monitor 
is two-fold.  First, rules ensuring transparency vis-à-vis the public authorities and rules ensuring transparency vis-
à-vis the public at large serve different purposes. The former enable the competent authorities to effectively apply 
sector-specific  regulation,  including  regulation  restricting  ownership  and  regulation  preventing  interference  with 
editorial independence.134 The latter enable citizens ‘to form an opinion on the value to be given to […] ideas and 
opinions disseminated by the media’, thereby contributing to building a more effective citizenry.135 Second, previous 
implementations of the Monitor have demonstrated that there are countries that have established rules covering both 
dimensions of transparency. The dichotomy is therefore meant to reflect this regulatory reality; in cases where citizens 
are deprived of access to information about media ownership, risks to media pluralism are expected to be higher than 
in cases where relevant rules have been enacted and are effectively implemented.

The  indicator  on  Concentration  of  crossmedia  ownership  was  enhanced  with  a  sub-indicator  that  seeks  to  assess 
how safeguards to ensure proportionality of Public Service Media (PSM) funding, contribute to enhancing media 
pluralism. 

Figure 2.4.2. The list of indicators of the Market Plurality area - comparative overview 
of the MPM2015 and the MPM2016

MPM2015

MPM2016

NOTE

Transparency of media
ownership

Concentration of media
ownership

Concentration of crossmedia
ownership

Transparency of media ownership

now distinguishes between transpar-
ency vis-à-vis the public and vis-à-vis 
the public authorities

Media ownership concentration (horizontal)

reorganized

Cross-media concentration of ownership and 
competition enforcement

reorganized. PSM proportionality test 
added

Commercial & owner influence over editorial 
content

Media viability

new

new

 See: http://www.unesco.org/new/fileadmin/MULTIMEDIA/HQ/CI/CI/pdf/IPDC/ipdc59_Media_viability_indicators.pdf
133 
134 
  See  Council  of  Europe.  Recommendation  No.  R  (94)  13  of  the  Committee  of  Ministers  to  Member  States  on  Measures  to  Promote 
Media  Transparency.  Retrieved  from:  https://wcd.coe.int/com.instranet.InstraServlet?command=com.instranet.CmdBlobGet&InstranetIm-
age=534799&SecMode=1&DocId=515710&Usage=2
135 

 Ibid.

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POLITICAL INDEPENDENCE AREA

The Political Independence area, although restructured to a certain extent, remains focused on assessing the risks for 
media pluralism that are associated with the politicisation of the media system, media companies, newsrooms and 
public service media.

Three indicators from the MPM2015: Politicisation of control over media outlets, Politicisation of control over media 
distribution networks and Independence of news agencies have been merged into one indicator of the MPM2016: 
Political control over media outlets. There are at least two reasons for this: first, the overall composition of the area 
is  now  more  balanced;  second,  the  observations  during  the  pilot  implementations  have  indicated  that  additional 
focus  on  general  prevention  of  conflict  of  interests  is  needed  as  well  as  the  conceptualization  of  control  as  being 
broader than just formal ownership. For the purpose of this specific indicator, control includes both direct ownership 
and indirect control. Indirect control implies that parties, partisan groups or politicians are not directly involved in 
the ownership structure but they exercise their power through intermediaries (e.g. family members). The conflict of 
interests is defined as an incompatibility of government office with media ownership (Djankov et al., 2003).

Two  indicators  in  the  area  of  Political  Independence  for  MPM2016  have  introduced  new  dimensions  of  risks  to 
complement  existing  variables  of  the  Monitor.  Editorial  autonomy  is  a  new  indicator,  designed  to  assess  level  of 
editorial  independence  and  resistance  to  undue  influences.  The  indicator  is  composed  of  two  sub-indicators:  one 
focusing  on  the  existence  and  effectiveness  of  self-regulation  to  guarantee  freedom  from  political  interference  in 
editorial decisions and content, which was already part of the MPM’s structure but was lacking a specific focus; and 
a second one, focusing on Editor-in-chief, which is a novelty of MPM2016 and which gives a special emphasis to 
a publication’s editorial leader, responsible for editorial policies and operations, and hence the first line of defence 
against political interference with editorial autonomy.

State advertising showed to be a problematic area of interplay between the state and media in many European countries. 
This evidence, stemming from the MPM pilot implementations, prompted us to expand the scope of measurement of 
potential risks related with the distribution of state managed resources to media. For this reason, the indicator on State 
regulation of resources and support to media sector has been created and, along with State advertising, encompasses 
also Spectrum allocation and Government subsidies, both direct and indirect. Spectrum allocation and Government 
subsidies are, therefore, a novelty of the MPM2016. They were introduced to capture emerging risks related with, 
on the one hand, technological advancements which may make media more dependent on state’s allocation of finite 
natural resource such as spectrum, and, on the other hand, with the crisis of media business models related to digital 
disruption and economic crisis, which may make media more dependent on state support.

Figure 2.4.3. The list of indicators of the Political Independence area - MPM2015 and 
MPM2016

MPM2015

MPM2016

NOTE

Politicisation of control
over media outlets

Independence of news
agencies

Politicisation of control
over media distribution
networks

Political bias in the
media

State advertising

Political control over media outlets

Three indicators from MPM2015 merged 
in one indicator of the MPM2016; added 
additional focus on Conflict of interests

Editorial autonomy

new indicator, introducing a new focus on 
Editor-in-chief

Media and democratic electoral process

reorganized

State regulation of resources and support to 
media sector

amended with sub-indicators on 
Spectrum allocation and Government 
subsidies

Independence of PSM
governance and funding

Independence of PSM governance and 
funding

amended with additional focus on 
Director General

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SOCIAL INCLUSIVENESS AREA

Social Inclusiveness became a new area in 2015 by merging the previous indicators on cultural, geographical and type/
genre issues. Based on the 2015-pilot of the area, several changes have been introduced both in terms of the structure 
of the area and in terms of indicators and their content. Table 2.4.4 below gives an overview of the changes made by 
comparing the MPM2015 and MPM2016 indicators. In MPM2016, the ‘Social Inclusiveness’ area  examines access 
to media by various social and cultural groups, and with media literacy, which is a precondition for an effective and 
informed media use. One of the more significant and visible changes that have been made in the MPM2016 is the 
development of a whole new indicator on Access to media for women. It was deemed important to cover this aspect of 
inclusiveness since gender equality is a fundamental right that is interrelated with media freedom, while gender gaps 
are still a reality in the media sector.

The  MPM2015  indicator  on  “Access  to  media  of  different  social  and  cultural  groups,  and  local  communities”  has 
been disaggregated into two new MPM2016 indicators (Access to media for minorities and Access to media for local/
regional communities and for community media) in order to better differentiate between the inclusion of different 
groups. Moreover, many of the related variables have been rephrased and some of the definitions have changed (e.g. 
the definition of minorities).

This MPM2015 indicator “Availability of media platforms for community media” has mainly become a sub indicator 
(“Access to media for community media”) in MPM2016 indicator “Access to media for local/regional communities 
and for community media”. However, some of its variables concerning minorities have also been incorporated into the 
indicator “Access to media for minorities”.136 

The  MPM2015  indicator  “Access  to  media  for  the  physically  challenged  people”  has  been  renamed  (now  “Access 
to  media  for  people  with  disabilities”)  and  amplified  from  two  to  five  variables  e.g.  to  cover  also  legal  safeguards, 
including those for on-demand audiovisual media; and support services for people with visual impairments.

This MPM2015 indicator “Centralisation of the media system” has mainly become a sub indicator (“Access to media 
for local/regional communities”) in the MPM2016 indicator “Access to media for local/regional communities and for 
community media”.

The MPM2015 indicator “Universal coverage of the PSM and the Internet” has been moved to the Basic area (see 
“Universal reach of traditional media and access to the Internet”).

The  indicator  “Media  literacy”  has  been  extended  from  three  to  six  variables,  to  capture  e.g.  also  whether  media 
literacy is present in formal or non-formal education, and the extent of ongoing media literacy activities.

Table 2.4.4. List of indicators of the Social Inclusiveness area - MPM2015 and MPM2016

MPM2015

MPM2016

NOTES ON CHANGES

Availability of media plat-
forms for community media

 Access to media for minorities
Access to media for local/regional 
communities and for community media

This MPM2015 indicator has mainly become a 
sub indicator (“Access to media for community 
media”) in MPM2016 indicator 12. 

Access to media for the 
physically challenged people

Access to media for people with disabilities

Centralisation of the media 
system

Access to media for local/regional 
communities and for community media

Universal coverage of the 
PSM and the Internet

Universal reach of traditional media and 
access to the Internet

Media literacy

Media literacy

This indicator has been renamed and amplified 
from two to five variables..

This MPM2015 indicator has mainly become 
a sub indicator (“Access to media for local/
regional communities”)in MPM2016 indicator 
12.

This indicator has been moved to the Basic area.

This indicator has been extended from three to 
six variables.

Access to media for women

New indicator

136 

 E.g. see variable “What is the ratio of TV channels dedicated to minorities to total number of TV channels?”

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Ownership.pdf 

ANNEXE I. MINORITY DEFINITION USED BY THE MPM2016

The CMPF minority definition is in line with the definition given by the Special Rapporteur of the United Nations 
Sub-Commission on the Prevention of Discrimination and the Protection of Minorities, which is summarised below 
(UN 1979).137 ‘’Minority’’ is a cultural or social group: 

•  numerically inferior to the rest of the population of a state,

•  minority groups should be smaller than the majority group in the respective country;

• 

in a non-dominant position,138

•  whose  members  possess  ethnic,  religious  or  linguistic  characteristics  differing  from  those  of  the  rest  of  the 

population.

In the framework of the MPM, minority groups should cover the following criteria:

• 

• 

be characterised by distinctive religion, language, traditions and cultural heritage;

seek to protect, maintain and express their distinctiveness (e.g. establishment or attempts to establish their own 
institutions, to use their language).

In line with definition of the European Union Agency for Fundamental Rights (FRA), minority groups considered by 
the Monitor can fall in any of the following categories (FRA 2011):  

•  Historical national minority groups with territorial/governmental autonomy (e.g. Irish, Scottish or Welsh in the 

UK);  

•  Historical minority groups without territorial/governmental autonomy, and who have been present in the Member 

State for more than a century (e.g. Roma, Sinti, Travellers);

•  Minority ethnic populations (immigrants who have been in the Member State for more than two decades);

• 

Immigrants (people who entered the Member State within the last two decades with the intention of remaining 
there);  

•  Religious minorities;  

•  Diaspora groups (people that are attached to the country because of their nationality or ethnicity, but who live 

abroad). 

 The following definition given by the Special Rapporteur of the United Nations Sub-Commission on the Prevention of 
137 
Discrimination and the Protection of Minorities, Francesco Capotorti is often adopted by UN organisations: ‘’a cultural or social 
group numerically inferior to the rest of the population of a State, in a non-dominant position, whose members - being nationals 
of the State - possess ethnic, religious or linguistic characteristics differing from those of the rest of the population and show, if 
only implicitly, a sense of solidarity, directed towards preserving their culture, traditions, religion or language.’’ (UN 1979).
 The “non dominant” refers to the size, as well as to social, cultural and economic domination: “(...), the requirement to 
138 
be in a non-dominant position remains important. In most instances a minority group will be a numerical minority, but in others 
a numerical majority may also find itself in a minority-like or non-dominant position, such as Blacks under the apartheid regime 
in South Africa. In some situations, a group which constitutes a majority in a State as a whole may be in a non-dominant position 
within a particular region of the State in question.” Office of the United Nations High Commissioner for Human Rights (OHCHR) 
http://www.ohchr.org/EN/Issues/Minorities/Pages/internationallaw.aspx 

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ANNEXE  II.    CONCLUSIONS  FROM  THE  WORKSHOP  WITH  MEDIA  
LITERACY EXPERTS IN FLORENCE

How should we measure risks to Media Literacy in Europe?

Organiser: Centre for Media Pluralism and Media Freedom (CMPF)

Coordinator and contact person: Alina Ostling (alina.ostling@eui.eu)

Place: European University Institute, Florence 

Date: 3 November 2016 

PARTICIPANTS

Name

Paolo Celot

Chawaporn 
Dhamanitayakul

Sara Gabai

Affiliation

European Association for Viewers’ Interests

Lecturer, Rangsit University, Thailand

Lecturer, Open university, Thailand, and Program Director, 
Digital International Media Literacy eBook Project (DIMLE)

Beata Klimkiewicz

Associate Professor, Institute of Journalism, Media and Social Communication, Jagiellonian
 University, Kraków, Poland

Head of the Media Literacy Research at Ofcom (UK)

Researcher coordinating the Social Inclusiveness area and implementation of the media literacy 
indicator in the framework of the Media Pluralism Monitor (CMPF)

Researcher coordinating the Political Independence area in the framework of the Media Pluralism 
Monitor (CMPF)

Alison Preston

Alina Ostling

Iva Nenadic

AIM

Centre for Media Pluralism and Media Freedom (CMPF) gathered a number of international media literacy experts 
in Florence in order to:

•  Discuss pressing media literacy issues in Europe. 

•  Gather  participants’  feedback  about  how  to  improve  the  measurement  of  media  literacy,  in  particular  in  the 

framework of the Media Pluralism Monitor.

FINDINGS

The experts agree that the current indicator on media literacy in the Media Pluralism Monitor is coherent and that 
it constitutes a good baseline for understanding the risks to media literacy in Europe. However, a key limit for the 
Monitor assessment is the lack of access to comparable data and statistics on media literacy. The main gap is the lack 

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of data on the capacity of individuals to analyse, interpret and produce media messages (on- and offline). To assess 
these individual capacities, the Monitor would need to seek additional funding to design and carry out an EU-wide 
survey of individuals. The participants also emphasised the need to create a pool of reputable national experts that 
the Monitor can rely on for assessing risks to media literacy in EU Member States. One of the participants, Paolo 
Celot, suggested that EAVI (European Association for Viewers’ Interests) can help with suggesting national experts. 
The participants also briefly discussed policy recommendations on media literacy (see the last section of this note).

The  participants  provided  concrete  recommendations  on  two  media  literacy  topics  during  the  workshop:  media 
literacy environment and individual media literacy competencies (summarised below):

ENVIRONMENTAL FACTORS

The Monitor should:
• 

Add variables that cover the following questions: Do regulatory authorities provide data on media to the public (e.g.    
about media law, about ownership of media organisations, where these organisations pay taxes, if they are public/pri   
vate/religious ? Are these information easily accessible or not?  

• 

• 

• 

• 

• 

  The Monitor should include data on media consumption, e.g. behavior of people on different media, mobile  

consumption (telecoms), number of mobiles sold (Eurostat). 
Add follow-up variables asking if the media literacy policy is implemented and monitored/evaluated  
(there is already a variable covering media literacy policy).
Ask country experts about the level of critical understanding of media in the country, e.g. during stakeholder meetings.  
Experts could draw on national surveys. This would put emphasis on the importance of critical skills for media literacy. 
Consider a separate variable on teacher’s training or as a criteria in the present variable covering media literacy  
activities. 
During the data analysis, test the correlation between levels of education and levels of media literacy among  
individuals. 

INDIVIDUAL COMPETENCIES

The Monitor should:
• 
• 

  Measure how the media is used and how people interact with the media through surveys of users across Europe. 
Investigate how big data can be used, e.g Twitter profiles and online behavior, ask for data. Get in touch with new  
stakeholders and experts. 
Cover the diversity of sources:  e.g. to what extent users consider different types of sources, what are the preferred news  
sources, if people seek sources they disagree with, what strategy they use to select news content. Awareness of sources,  
especially in social media, where these are less visible (Are you aware you are on youtube? What sources are the news   
coming from?)
Cover critical understanding of media messages: editorials vs. advertorials.
Consider how people access media. The online consumption is growing and this is creating digital divides and  
exclusion, e.g. among older and younger groups (demographic divide). 
Put a particular emphasis on the digital inclusion, e.g. how people use social media (e.g. Facebook news). 
Consider privacy and safety of media consumption. 

PRESSING ISSUES AND POLICY ADVICE ON MEDIA LITERACY

At the national level:
• 

Regulatory bodies in the field of audiovisual services should collect and make accessible to the public data on issues    
such as media ownership, the nature of media outlets (if they are public/private/religious), and about media law. 
In education, more investment should be done in the quality of teachers’ training in the field of media literacy.
At the European Union (EU) level: 

  The new Audiovisual Media Services Directive (AVMSD) should include a reference to media literacy and the EU  

should put more responsibility on Member States to promote media literacy in their countries. 

• 

• 
• 

• 
• 

• 

• 

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ANNEX III. NOTES ON THE FEASIBILITY OF THE MEDIA PLURALISM 
MONITOR

Within the scope of MPM2016 project, the CMPF also carried out the study on sustainability of the MPM focusing 
on the feasibility of regular implementation, its form, and potential funders. The study is based on a questionnaire 
developed by the CMPF team and addressed to the selected list of individuals who are, to a different extent, familiar with 
the Media Pluralism Monitor tool (local collaborators, members of the Group of Experts, Summer School participants 
from 2014-2016, academics, and other stakeholders interested in issues of media pluralism). The dissemination of the 
survey and the collection of responses was conducted through the open online tool SurveyGizmo. The total number 
of respondents was 77 and the results suggest that the monitoring of media pluralism with the MPM tool should be 
implemented annually (42,7%)  or  every  two  years (36%). The majority of respondents (66,2%) said that the most 
adequate source of funding in terms of sustainability and feasibility is the European Union. The European Union and 
the Council of Europe are seen as the funders that could ensure independence of this sensitive and valuable research. 

ANNEX IV MPM2016 USER GUIDE

Link to the MPM2016 user guide

http://cmpf.eui.eu/media-pluralism-monitor/

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