Monitoring media pluralism in Europe : application of the media pluralism monitor 2017 in the European Union, FYROM, Serbia & Turkey : country report : Ireland.
Date: 2019-10-14
Institutions: Robert Schuman Centre for Advanced Studies
Subjects: European Union, Ireland, North Macedonia, Serbia, Türkiye, 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

Country Report: Ireland

Author: Roddy Flynn

Monitoring Media Pluralism in Europe: Application of the Media Pluralism Monitor 2017 in the European Union, FYROM, Serbia & TurkeyTABLE OF CONTENT

1. 

2. 

3. 

About the Project 

Introduction 

Results from the data collection:  
assessment of the risks to media pluralism 

3.1. 

Basic Protection (29% - low risk) 

3.2.  Market Plurality (57% - medium risk) 

1

3

5

7

8

3.3. 

Political Independence (11% - low risk)  10

3.4. 

Social Inclusiveness (61% - medium risk)11

4. 

Conclusions 

Annexe 1. Country Team 

Annexe 2. Group of Experts 

13

15

15

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
1. ABOUT THE PROJECT

1.1  OVERVIEW OF THE PROJECT

The Media Pluralism Monitor (MPM) is a research tool that was designed to identify potential risks to media pluralism 
in the Member States of the European Union. This narrative report has been produced within the framework of the 
second EU-wide implementation of the MPM, carried out in 2017. The implementation was conducted in 28 EU 
Member States, Serbia, Former Yugoslav Republic of Macedonia (FYRoM) and Turkey with the support of a grant 
awarded by the European Union to the Centre for Media Pluralism and Media Freedom (CMPF) at the European 
University Institute.

1.2 METHODOLOGICAL NOTE 

The CMPF cooperated with experienced, independent national researchers to carry out the data collection and to 
author the narrative reports, except in the cases of Malta and Italy where data collection was carried out centrally by 
the CMPF team. The research is based on a standardised questionnaire and apposite guidelines that were developed 
by the CMPF. The data collection was carried out between June and December 2017.

In Ireland, the CMPF partnered with Dr Roddy Flynn of FuJo (the Institute for Future Media and Journalism) at the 
School of Communications, Dublin City University who conducted the data collection and annotated the variables in 
the questionnaire and interviewed relevant experts. The scores assessing the risks for media pluralism were provided 
by  the  CMPF  and  calculated  according  to  the  algorithm  developed  by  the  Centre  itself.  The  national  report  was 
reviewed  by  CMPF  staff.  Moreover,  to  ensure  accurate  and  reliable  findings,  a  group  of  national  experts  in  each 
country reviewed the answers to particularly evaluative questions.

Risks to media pluralism are examined in four main thematic areas, which are considered to capture the main areas 
of risk for media pluralism and media freedom: Basic Protection, Market Plurality, Political Independence and Social 
Inclusiveness. The results are based on the assessment of a number of indicators for each thematic area (see Figure 1 
below). 

Basic Protection

Market Plurality

Political 
Independence

Social Inclusiveness

Protection of freedom of 
expression

Transparency of media 
ownership

Political control over media 
outlets

Access to media for 
minorities

Protection of right to 
information

Media ownership 
concentration (horizontal)

Editorial autonomy

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

Journalistic profession, 
standards and protection

Cross-media concentration 
of ownership and 
competition enforcement

Independence and 
effectiveness of the media 
authority

Commercial & owner 
influence over editorial 
content

Media and democratic electoral 
process

Access to media for people 
with disabilities

State regulation of resources 
and support to media sector

Access to media for women

Universal reach of 
traditional media and 
access to the Internet

Media viability

Independence of PSM 
governance and funding

Media literacy

The results for each domain 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 a total 
absence or certainty of risk. For more information on the MPM methodology, see the CMPF report “Monitoring 
Media Pluralism in Europe: Application of the Media Pluralism Monitor 2016 in EU-28, Montenegro and Turkey”, 
http://cadmus.eui.eu//handle/1814/46786 

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Disclaimer: The content of the report does not necessarily reflect the views of the CMPF or the EC, but represents 
the views of the national country team that carried out the data collection and authored the report. Due to updates 
and refinements in the questionnaire, the MPM2017 scores may not be fully comparable with those of MPM2016. 
For  more  details,  see  the  CMPF  report  on  MPM2017,  which  will  soon  be  available  on  http://cmpf.eui.eu/media-
pluralism-monitor/ 

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2. INTRODUCTION

The Republic of Ireland occupies 84,000 square km of the island of Ireland which is shared with Northern Ireland. 
As of 2016, the population is just under 4.8m people of whom 1.3m live in the capital, Dublin. Although Ireland has 
two official languages – English and Irish – the latter is not commonly spoken and daily use is confined to fewer than 
80,000 people. (In fact Polish is the second most spoken daily language in Ireland)

Notwithstanding increased immigration since 1990, Ireland remains culturally homogenous as compared with other 
Western European states. According to the 2016 census 92% of the population was White Irish or came from another 
White background while just 3.5% of the population were identified as coming from a Black or Asian ethnicity. The 
Irish Traveller community accounts for approximately 0.66% of the population but is not yet officially recognised as 
an ethnic minority.

A period of rapid economic growth from the 1990s (commonly referred to as “The Celtic Tiger”) fuelled a property 
bubble which burst dramatically in 2008. In 2010 the state was forced to seek a €85bn bailout from the European Union, 
IMF and European Central Bank. The loan conditions lead to significant public expenditure cuts. Unemployment 
rose from 4% in 2006 to 15.2% in 2012 while average earnings fell consistently between 2008 and 2014. In December 
2013 Ireland exited the bailout programme and most key economic indicators have improved since then: monthly 
unemployment for example fell from 7.4% in January 2017 to 6.1% in January 2018. According to EU figures GDP 
growth in 2017 was three times the Euro area average at 7.3%, up from 5.1% in 2016. 

Two  parties  have  dominated  Irish  politics  since  the  foundation  of  the  state.  From  1932  on,  the  Fianna  Fail  party 
consistently held the most parliamentary seats until the economic crash of 2008 but at the 2011 election the Fine 
Gael party moved into the ascendancy. Both parties are ideologically centrist: their main distinctions being positions 
adopted in 1922 regarding the nature of Irish independence. The post-2011 political environment has witnessed the 
emergence of more broadly leftwing blocs with the Irish parliament (although the longest established of these – the 
Labour Party suffered heavy losses at the 2016 election) but these have yet to play a leading role in an administration.

Ireland’s small population limits the scale of media markets whilst the country’s Anglophone status has allowed UK-
based media to account for a substantial share of media audiences. UK papers account for one in four weekday and 
one in three Sunday newspaper sales. In television the combined market share of all Irish-based television stations, 
public and private, is just 46.1%. (It should be noted that the largest private television group in Ireland – TV3 - is 
owned by US-based giant Liberty Global). By contrast Irish audiences overwhelmingly listen to Irish radio stations, 
though the sale of the Wireless Radio Group in August 2016 means that the second largest private radio group is now 
owned by News Corporation.

Irish print media and television consumption is in line with EU average. According to TAM Ireland/Nielsen figures for 
2016, the average Irish adult spends 231 minutes a day watching television of which 90% is consumed “live”. According 
to Eurobarometer figures for 2016 82% of people watch television via a TV set everyday. 37% of the population watch 
television via online platforms at least 2-3 times a week which is significantly higher than the EU average of 23%. 73% 
of the population claim to read a newspaper at least 2-3 times a week although historically newspaper circulation 
per capita has been lower than the European average and only 31% of the population read a paper nearly every day. 
By contrast the Irish use radio more than any other EU Member State barring Germany, with 65% of the population 
listening daily. With 69% of the population claiming to access the internet daily, Ireland is somewhat ahead of the 
EU28 average of 61%.

The internet has altered local news consumption patterns. According to the 2017 Reuters Digital News Report for 
Ireland,[2]  66%  of  Irish  adults  respondents  identify  online  sources  as  a  weekly  source  of  news,  though  television 
remains  the  leading  source  with  68%.  Furthermore  Irish  audiences  are  more  likely  to  source  news  through  social 
media (52%) on a weekly basis than they are through either radio (46%) or print (40%). It should also be noted that 
across all media their use for accessing news in Ireland is declining.

In addition to online viewing, television is accessed via satellite, cable and DTT. The late introduction of a state-run 
(via Radio Telifis Eireann, the public service broadcaster) DTT service to Ireland in 2011 means two international 
players, Sky and the Liberty Global dominate television distribution via, respectively their satellite and cable platforms. 
As of the start of 2017 just 12% of television homes exclusively rely on DTT for broadcast television although many 
more use it as a secondary platform along with cable or satellite.

Responsibility  for  media  regulation  is  spread  across  a  number  of  bodies  including  the  Broadcasting  Authority 
of  Ireland  (BAI),  the  Press  Council  of  Ireland,  the  Internet  Advisory  Board  and  the  Competition  and  Consumer 
Protection Commission. The role of the Press Council and the Advisory Board is limited to post-hoc medium-specific 

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content  regulation  whilst  the  Commission’s  role  in  relation  to  media  is  limited  to  assessing  the  market  impact  of 
media mergers. The role of the BAI is much broader: it not only licences independent radio and television stations, 
but  administers  content  regulation  codes  (backed  by  the  power  to  administer  fines  to  broadcasters),  operates  the 
Broadcasting Complaints Commission and funds public service content production via the Sound and Vision Scheme. 
In addition, since the 2014 Competition and Consumer Protection Act, it plays a role in assessing the impact of media 
mergers on diversity and pluralism.

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3. RESULTS FROM THE DATA COLLECTION: 
ASSESSMENT  OF  THE  RISKS  TO  MEDIA 
PLURALISM

Recent elections and referenda across the western world may raise doubts as to whether the whole project of Liberal 
Democracy still has the capacity to engage citizens in the consensus building work critical to the operation of such a 
polity. Yet even if the Liberal Democratic project is not broken, it appears to be the case that the speed at which Irish 
legacy media outlets has declined over the past decade has not been matched by local policy responses designed to 
maintain the operation of a functioning public sphere (even assuming that such measures exist at all). The generally 
static or falling revenues of legacy media and declining readership for print media in particular has left such media 
institutions and their staff in an increasingly precarious position, one which undermines their capacity to gather and 
process the kind of information critical to informed public debate. In parallel with this, online media have emerged as 
both the single largest destination for Irish advertising expenditure and increasingly as the site in which fragmented 
public spheres (note the emphasis on the plural) proliferate. According to Eurobarometer figures from 2016, 54% of 
Irish citizens at least occasionally follow public debates via social media, yet Irish citizens also consider social media 
to be the least reliable medium: just 32% of citizens in 2016 considered it reliable as opposed to 66% for radio and 55% 
for both television and print media. (Eurobarometer, 2016) Media Pluralism and Democracy (Special Eurobarometer 
452).

In this regard it is notable that, in Ireland as elsewhere, though existing regulatory regimes broadly work well, they are 
still overwhelmingly focused on the supervision of legacy media while online media – despite an acknowledgement of 
their growing influence – are, largely left to self-regulation. This is reflected at the level of broadband roll-out which has 
been primarily driven by market forces with the result that more than 20% of the population – especially in rural areas 
– still lacks domestic access to high speed internet services. At a point when media consumption increasingly relies 
upon online services, such disparities, limit the capacity for all citizens to make active use of notional communicative 
guarantees such as freedom of expression. (Against this, the networking power available to the majority who do have 
access to online and social media has facilitated the rise of social movements campaigning for changes to aspects of 
Irish constitutional law relating to marriage equality and the termination of pregnancies.)  

Indeed, the presence of alternative news sources online has been used to legitimate the gradual consolidation of Irish 
radio,  television  and  print  media  outlets  into  larger  media  group  by  suggesting  that  access  to  a  diversity  of  views 
is sustained by the range of perspectives available via the Internet. This may also account for the absence of strict 
quantitative limits on the scale of media concentration within in Ireland. It is certainly the case that threats to media 
viability – and specifically the assertion that joining a larger media group may make otherwise financially marginal 
media propositions feasible – has been used to legitimate such media merger and acquisition activity in Ireland since 
2014. What is less clear is whether the economies of scale such mergers afford have actually improved the overall 
viability of specific media sectors in Ireland.

 The question of who is represented and who controls representation in Irish media also remains a live issue in Ireland. 
Although  gender  inequality  is  increasingly  the  subject  of  Irish  public  discourse  this  is  not  necessarily  reflected  in 
concrete actions to correct such imbalances within Irish media, especially amongst private media whose boards tend 
to male-dominated. Furthermore the focus on gender inequality in the media continues to obscure the absence of 
identities – and in particular non-White Irish ethnicities - from the mainstream media in Ireland. Such imbalances are 
not trivial since they are clearly reflected in the construction of national news and current affairs agendas.

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3.1 BASIC PROTECTION (29% - LOW RISK)

The Basic Protection indicators represent the regulatory backbone of the media sector in every contemporary democracy. 
They  measure  a  number  of  potential  areas  of  risk,  including  the  existence  and  effectiveness  of  the  implementation  of 
regulatory safeguards for freedom of expression and the right to information; the status of journalists in each country, 
including their protection and ability to work; the independence and effectiveness of the national regulatory bodies that 
have the competence to regulate the media sector, and the reach of traditional media and access to the Internet.

The first indicator “Protection of Freedom of Expression” scored as a low risk (14%). Section 40.6.i of the Constitution 
guarantees the “right of the citizens to express freely their convictions and opinions” but qualifies this stating that 
‘organs of public opinion’ (i.e. media outlets) may not be used ‘to undermine public order or morality or the authority 
of  the  State’.  Ireland  has  signed  both  the  ICCPR  and  European  Convention  on  Human  Rights,  which  include 
stronger commitments to freedom of speech. Unusually Ireland has included blasphemy as an offence since 2009. 
Furthermore Irish journalists routinely assert that libel law has a “chilling” effect on their work not least because of 
the unpredictability of the damages resulting from legal actions. The 2009 Defamation Act’s introduction of a “public 
interest” defence for publishing a defamatory statement only partially remedied this although the Act’s removal of the 
charge of criminal libel, effectively de-criminalised defamation.

At 13%, the indicator “Protection of Right to Information” is considered a low risk but is higher than last year’s 3% 
because of a new sub-indicator relating to the treatment of whistleblowers. The Freedom of Information Acts of 1997, 
2003 and 2014 oblige government departments and other public bodies (universities, health boards, etc.) to publish 
information on their activities and to make information they hold - including personal information - available to 
citizens. Compliance with the Act is generally good and although the imposition of a fee for FOI requests in 2003 
diminished the number of requests, the fee was removed following the 2014 Act. With regard to whistleblowers, the 
2014 Protected Disclosure Act notionally protects employees in the event of their making a charge of wrongdoing 
by their employer or colleagues. In practice there have been a number of incidences where whistleblowers do not 
appear to have received such protection. The most notable example of this is that of Sergeant Maurice McCabe whose 
treatment by his Police force employees is currently the subject of the Protected Disclosures Tribunal. 

The indicator for “Journalistic Profession, Standards and Protection” scored a medium risk (38%). Although there 
are no legal impediments towards becoming a journalist in Ireland (e.g., no state licencing system), the scarcity of 
some groups within the profession – working classes, ethnic minorities and the disabled – points to the existence 
of  less  tangible  barriers.  Furthermore  if  security  of  tenure  is  a  precondition  for  journalists  adopting  a  watchdog 
role, this is clearly undermined by the increasing prevalence of freelance employment and casualization. Although 
the National Union of Journalist’s Code of Conduct (together with the parallel code operated by the Press Council 
and the BAI’s codes on fairness and objectivity) underwrites a commitment to professional standards, the ongoing 
decline in NUJ membership levels is not encouraging in this regard. Ireland generally scores well on the Reporters 
Without Borders Press Freedom Index (14th out of 180 countries in 2017). However, an incident in July 2017 when 
US-based blogger and political scientist, Catherine Kelly was temporarily detained by two police officers following 
an  Irish  government  minister’s  complaint  that  Ms  Kelly  has  harassed  the  minister  on  social  media  raises  some 

7

 
concern. There is also evidence that journalists – and in particular crime journalists – have received threats to their 
physical safety from figures involved in an ongoing Dublin gangland feud. Furthermore, journalists have asserted 
that the Communications (Retention of Data) Act 2011 has been invoked by the Irish police force to legitimate digital 
surveillance of journalist communications. 

Regarding the “Independence and effectiveness of the Media Authority”, this indicator achieved a low risk level (15%). 
Although there is a high level of political involvement in appointing the main media authority – the Broadcasting 
Authority of Ireland – it operates within clearly defined legal structures, and consistently acts in a manner which is 
both transparent and which appears to be independent from political and/or commercial interference.

The Universal reach of traditional media and access to the internet is just short of constituting a high risk at 63%. Given 
the near-universal availability of legacy broadcast media this may seem surprising. However, the ongoing delay in 
extending high speed broadband to rural areas raises the risk profile. Eurostat data from 2016 suggests that 77.2% 
of the Irish population had access to 30MBps or faster: anything under 78% is considered high risk by the MPM 
instrument. Furthermore, although EU directive 2015/21201 cemented the principle of net neutrality into EU law 
from 30 April 2016, at the time of writing (September 2017) the Irish State had not published penalties relating to 
infringements of the directive. As a result the relevant regulator – Comreg – was effectively unable to enforce the 
directive.

3.2 MARKET PLURALITY (57% - MEDIUM RISK)       

The  Market  Plurality  indicators  examine  the  existence  and  effectiveness  of  the  implementation  of  transparency  and 
disclosure provisions with regard to media ownership. In addition, they assess the existence and effectiveness of regulatory 
safeguards to prevent horizontal and cross-media concentration of ownership and the role of competition enforcement and 
State aid control in protecting media pluralism. Moreover, they seek to evaluate the viability of the media market under 
examination as well as whether and if so, to what extent commercial forces, including media owners and advertisers, 
influence editorial decision-making. 

“Transparency of media ownership” scores a medium risk (50%). Although in practice the public may have some 
knowledge of which individuals or companies own media outlets operating in Ireland, Irish company law does not 
require any company, media-related or otherwise, to disclose who holds the beneficial interest in shares. The public 
may consult the contracts - which include information relating to ownership structures - of BAI-licenced radio and 
television media outlets. Such contracts are not available online and must be examined at the BAI offices limiting their 
accessibility. Furthermore Section 28 of the 2014 Competition and Consumer Protection Act states that in the case 
of any media merger/acquisition the undertakings involved must notify the Minister for Communications of details 
relating to the ownership of those undertakings.

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The indicator on Media ownership concentration scores a high risk (97%). This is largely accounted for by the absence 
of defined limits on media ownership. The 2014 Competition and Consumer Protection Act, section 4 of which is 
entirely devoted to media mergers, does not specify quantitative thresholds to prevent an increase in media ownership 
concentration. Section 25 of the Broadcasting Act 2009 requires the BAI to maintain open, pluralistic and diverse 
media  markets,  but  again  does  not  specify  limits  on  ownership  thresholds.  In  it’s  2012  Ownership  and  Control 
Document the BAI argues that, in the absence of a practical matrix determining a reasonable share of media markets, 
media acquisitions and mergers should be assessed on a case-by-case basis. Despite this, the high risk figure perhaps 
overstates the extent of concentration in Ireland where, in any case, some cognizance of the impact of small market 
size should be acknowledged. Although the C4 score (measuring the market share of the top four players) for the 
newspaper sector is considered as high at 79%, the figures for radio (61%) and television (52%) would be regarded as 
constituting medium levels of concentration. 

The indicator on cross-media ownership scores a medium risk (44%) due in part to – again - the absence of specific 
upper limits on media ownership but also the practical implementation of the media merger measures contained in 
the 2014 Competition and Consumer Protection Act. For the most part media mergers since 2014 have proceeded 
without  significant  regulatory  intervention.  Since  2015,  TV3,  UTV  Ireland  and  Setanta  have  all  been  acquired  by 
larger players, namely Liberty Global, ITV Plc and Eir. In the radio market, UTV’s former Irish radio holdings were 
acquired by News UK in July 2016 as part of the latter’s purchase of UTV’s Wireless Group. The only recent example 
of active intervention with regard to a media merger relates to Independent News and Media’s September 2016 move – 
subsequently abandoned - to acquire the Celtic Media Group regional newspaper chain. The overall risk figure would 
be higher still were it not for the presence of annual monitoring of the level of state funding paid to public service 
media in Ireland. Since the passage of the 2009 Broadcasting Act, there has been a robust regime designed to ensure 
that, in keeping with EU competition law, public funding to public service broadcasters does not exceed the amount 
necessary to fulfill their public service remit. RTE and TG4 must submit annual budgets to the BAI with detailed plans 
for public service content. The BAI uses these to make annual recommendations to the Minister for Communications 
as to the level of public funding required by RTE and TG4.

The  medium-to-high  score  (63%)  under  “Commercial  and  owner  influence  over  editorial  content”  is  primarily 
informed  by  the  lack  of  formal  protections  to  prevent  such  influence  rather  than  consistent  evidence  that  such 
influence  is  being  exerted.  Although  the  2003  European  Communities  (Protection  Of  Employees  On  Transfer  Of 
Undertakings)  Directive  ensures  new  owners  must  observe  workers’  pre-existing  terms  and  conditions,  this  does 
not  specifically  afford  protections  to  journalists.  Nor  does  any  other  Irish  legislation  afford  such  protection.  That 
journalists are occasionally subjected to unfair dismissal by Irish media outlets seems supported by a number of high 
profile legal cases taken since 2001. 

By contrast there are regulatory measures obliging Irish journalists to avoid commercial influence – Article 10 of the 
NUJ’s Code of Conduct and Section 2.3 of the Press Council Code of Practice warn against endorsing commercial 
products or allowing undisclosed interests to influence editorial content. There is one potentially grey area in this 
regard, however: “Advertiser Funded Programming” is a mechanism which permits broadcasters to charge “guests” on, 
for example lifestyle programming, to promote their brand. If the broadcaster displays a product placement graphic 
in advance of such segments, such practices are not considered as breaches of the BAI’s General Communications 
Code.

With regard to owner influence, there have repeated public assertions – to our knowledge not legally challenged – 
suggesting that media owners have sought to directly intervene in editorial content. However, such overt interference 
does not appear to be extensive and, in any case, it is not clear it directly leads to an actual change of content. By 
definition it is much harder to establish the extent to which the simple fact of media ownership can indirectly shape 
editorial content by creating a context where journalists may avoid adopting lines which they believe to run counter 
to the interests or preferences of their owners.

The Media viability score (32%) represents a significant increase on the 8% for the previous MPM report in 2016. 
The increase is driven by the ongoing revenue difficulties for media sectors. Though online and television advertising 
revenues in Ireland have risen consistently since 2013, radio revenues appear to be static while newspaper advertising 
figures appear to be declining. Though print media attempts to explore new revenue models – especially by monetizing 
digital content – have met with only limited success and do not compensate for the reduction in print advertising 
revenues. Though there has been some public discussion of shoring up private sector media either by establishing 
new state funds or diverting broadcast licence fee income, there seems to be little political appetite for such schemes.

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3.3 POLITICAL INDEPENDENCE (43% - MEDIUM RISK)

The  Political  Independence  indicators  assess  the  existence  and  effectiveness  of  regulatory  safeguards  against  political 
bias  and  political  control  over  the  media  outlets,  news  agencies  and  distribution  networks.  They  are  also  concerned 
with the existence and effectiveness of self-regulation in ensuring editorial independence. Moreover, they seek to evaluate 
the  influence  of  the  State  (and,  more  generally,  of  political  power)  over  the  functioning  of  the  media  market  and  the 
independence of  public service media.

The indicator on the “Political Independent of Media” outlets scores a 50% risk. Despite the medium risk recorded here 
there is little evidence of direct day-to-day political control over public or private media in Ireland. Serving politicians 
are  barred  from  sitting  on  the  board  of  both  state-owned  broadcasters  –  RTE  and  TG4  –  and  the  Broadcasting 
Authority of Ireland. Furthermore, since the closure of the Irish Press Group in 1995 there has been no “party press” in 
Ireland. Nonetheless, the medium risk score is based on the fact that there is no absolute prohibition on an individual 
simultaneously holding political office and owning media outlets in Ireland.

Again though the figure for editorial autonomy records a medium risk (50%) this should not be interpreted as pointing 
to evidence of active interference by politicians in editorial content. Rather it reflects the absence of regulatory or 
industry-wide  adherence  to  self-regulatory  codes  prohibiting,  for  example,  political  interference  when  appointing 
senior editorial staff to media outlets. 

The indicator on Media and democratic electoral process scores the lowest risk in the area of Political Independence 
(26%). The 2009 Broadcasting Act strongly asserts the need for fair representation of viewpoint in broadcast coverage. 
Article 39 states that all broadcasters must ensure that “the broadcast treatment of current affairs, including matters 
which are either of public controversy or the subject of current public debate, is fair to all interests concerned and 
that the broadcast matter is presented in an objective and impartial manner and without any expression of his or her 
own views”. Furthermore the BAI has actively defended this principle via a series of decisions taken in the context of 
its Broadcasting Complaints process. However, although BAI rules imply that competing political parties should be 
able to access broadcast media on an equitable basis, there is no overt obligation on either public service or private 
broadcasters to facilitate such access. In practice, RTE routinely offer airtime for party political broadcasts in the run-
up to elections though this is less common on private channels. Furthermore, the question of which factors to take 
into account in allocating airtime (proportion of parliamentary representation, opinion poll performance etc.) is not 
defined by the BAI and thus remains contested. More generally since the regulator does not actively monitor the extent 
and nature of how different political actors are represented – relying instead on complaints from the public (including 
political parties) to draw attention to disproportionate representation – there is a lack of objective data which could 
be used to definitely assess the fairness of political representation. Finally, although paid-for political advertising on 
radio and television – other than party political broadcasts - is banned outright in Ireland, the same restrictions do not 
apply to either print or the increasingly significant online markets and there is no institution in Ireland charged with 
monitoring how political actors use online political advertising in the country. 

State regulation of resources and support to media sector scores a low (33%) risk, but borders on the medium risk 

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band. Ireland lacks the kind of direct state media supports to private media found in, for example France and some 
Scandinavian countries. However, the state and related bodies are significant advertisers in their own right. Neilsen 
figures suggests that “Government, Social and Political Organisations” spent spent just over €60m on advertising in 
2017, raising the question of what criteria are used when choosing media outlets for such advertising. The answer is 
not entirely clear. Any public body seeking to place an advert in Irish print media must do so via an intermediary 
(usually an ad agency) appointed via a public tender process. This intermediary places print ads on behalf of public 
bodies as per the instructions of the latter. In other words, it appears that the public body should determine where the 
advertising is placed. With regard to the placement of state advertising in Irish newspapers circulation is a primary 
determinant but other, less clear, factors also seem to play a role.

Finally,  the  indicator  on  Independence  of  PSM  governance  and  funding  records  the  highest  risk  to  political 
independence although at 58% it remains in the medium risk band. This reflects the fact that six of RTE’s 12 Board 
members are directly appointed by the Minister for Communications – subject to a consultation cross-party Joint 
Oireachtas  (Parliament)  Committee.  That  committee  nominates  a  further  four  candidates  as  directors  although 
the Minister is not absolutely required to accept them. As such, there is clear political influence involved in these 
appointments. Furthermore, although the Director-General of RTE is chosen by the RTE Board, the appointment is 
subject to the consent of the government. Similarly, although public funding for public service media in Ireland is less 
subject to political influence than in the past, the Minister for Communications remains the final arbiter of the licence 
fee. Section 124 of the 2009 Broadcasting Act outlines a mechanism relating increases in the fee to the Consumer Price 
Index subject to BAI advice. Since 2008 the BAI has made several recommendations for such increases but as of 2017, 
the government has consistently refused to do so.

3.4 SOCIAL INCLUSIVENESS (52% - MEDIUM RISK)

The Social Inclusiveness indicators are concerned with access to the media by various groups in society. The indicators 
assess regulatory and policy safeguards for community media, and for access to media by minorities, local and regional 
communities, women, and people with disabilities. In addition to access to the media by specific groups, the media literacy 
context is important for the state of media pluralism. The Social Inclusiveness area therefore also examines the country’s 
media literacy environment, as well as the digital skills of the overall population.

The indicator on “Access to media for minorities” scores a very high risk (88%). Part of the issue lies in the fact that, 
as  per  the  Irish  Human  Rights  and  Equality  Commission,  there  is  no  Irish  legal  definition  of  what  constitutes  a 
minority and thus there are no legally recognised minorities. Although in general terms the Broadcasting Act of 2009 
provides for the access of different social and cultural groups to broadcast media, this is less an obligation and more 
an aspiration. Thus, with the exception of Irish-language communities, Irish media face no specific requirements to 
provide access to minority groups, however defined. 

11

Although the mid-2000s saw the emergence of some media addressing “new Irish” audiences and the inclusion of 
“multicultural”  programming  on  radio  and  television,  these  were  not  sustained  and  are  now  largely  confined  to 
community media.

The  indicator  “Access  to  media  for  local/regional  communities  and  for  community  media”  scores  low  risk  (25%). 
Although there is no strict legal obligation for it to do so, the PSM RTE maintains eight regional offices (with associated 
correspondents) which broadly cover the entire island of Ireland. Local and community media in Ireland are mainly 
constituted by independent radio stations and have been a feature of the Irish broadcasting landscape since the 1988 
Radio  and  Television  Act.  The  2009  Broadcasting  Act  requires  broadcast  network  providers  to  allocate  space  for 
any BAI-licenced  broadcast service:  at present  the BAI licences 22 community/community of interest stations (or 
which two are television) and 32 local or regional commercial broadcasters. Although commercial broadcasters rely 
on advertising revenue, community stations are restricted in this regard and tend to rely on short-term – and thus 
unpredictable –  funding from a variety of state bodies such as the Department of Social Protection.

The indicator “Access to media for people with disabilities” scores as a low risk (21%). This reflects active regulatory 
and practical efforts to facilitate access to broadcast and print content for people with disabilities. Nonetheless these 
efforts have not yet resulted in a comprehensive set of policies in this area. The 2009 Broadcasting Act requires the BAI 
to draw up “Access Rules” laying down requirements for the provision of subtitling, captioning, audio description and 
Irish sign language. In practice the extent of these varies according to the specific access method and the nature of the 
broadcaster. Thus while subtitling obligations are quite significant, the provision of audio description is very limited. 
Furthermore public service media face more stringent obligations in this regard than their commercial counterparts. 
Finally, although on-demand audiovisual media services constitute an increasingly popular offering from both PSM 
and private media, there is as yet no legal obligation to attach any audio description or subtitling to such content. 

Part of the high risk (79%) for “Access to Media for Women” derives from the lack of available relevant data (which 
constitutes a risk in and of itself). Although the Global Media Monitoring Project does survey Ireland, it aggregates 
UK and Irish figures for publication so it is not possible to state what share of news is constituted by female reports 
and subjects. With regard to representation at board and executive level, Irish PSM are relatively equal: one PSM is 
currently headed by a woman, the other by a man while both have near 50:50 gender representation on their boards. 
The same is not true of private TV companies in Ireland which are overwhelmingly male at both executive and board 
level.  

The indicator “Media literacy” scores medium risk (46%). Although efforts to mainstream media literacy as part of 
the primary and secondary level education curricula go back to the 1980s, the state has only recently adopted media 
literacy as an overt policy objective. Although a new National Literacy and Numeracy Strategy in 2011 expanded the 
definition of literacy to include media literacy and the introduction of a new Junior Cycle (typically 13-15 year old 
students) in 2014 integrated some additional media literacy courses into the curriculum, universal access to media 
literacy activities is currently limited to primary school students. Access at second level education is patchy and at 
third level, it is limited to those who have actively chosen to study the subject. Outside formal education, although 
organisations like the Irish Film Institute offer some evening classes these tend more towards a film appreciation-style 
than an overt media literacy approach.

12

4. CONCLUSION

As with previous reports, although this year’s edition finds that Ireland exhibits a medium or high risk in 12 out the 
20 indicators described above, it should be emphasized that in some of these cases, the risk is potential rather than 
present. Thus under the political indicators, although political influence clearly plays a role in appointments to public 
service media and to regulatory bodies and in setting the precise level of the licence fee, it remains the case that there 
is limited evidence that such power is substantially abused.

Nonetheless  there  are  clearly  issues  to  be  addressed.  In  outlining  policy  recommendations  below  the  report  has 
particularly focused on addressing the following key issues:

• 

• 

the financial precarity of both media entities and those who work for them

the lack of diversity amongst both those who oversee/regulate media and those who work within them

Recommendation One – The Minister for Justice should consider a redraft of the 2009 Defamation Act to cap the 
level of financial damages awarded in libel cases. The main objective of libel law is to protect the reputation of the 
libelled  party,  not  to  enrich  them.  Protection  of  reputation  can  arguably  be  achieved  through  high-profile  public 
acknowledgement of this when a media outlet is found to have libelled an individual. This suggests capping financial 
damages at a level which, while retaining their power as a disincentive, avoids reaching levels which can potentially 
bankrupt a media outlet.

Recommendation Two – The Department of Communications and/or the Broadcasting Authority of Ireland should 
maintain  an  up-to-date  publicly  accessible  online  database  of  media  ownership  in  Ireland  which  allows  users  to 
identify cross-outlet and cross-medium ownership structures.

Recommendation Three – The television licence fee should be immediately replaced by a Household Broadcasting 
Charge  to  circumvent  ongoing  levels  of  revenue  losses  through  broadcast  licence  fee  evasion.  The  Department  of 
Communication should also consider whether and how the additional funding raised might be used to support a 
broader  range  of  public  service  media  production  conceptualised  as  referring  not  just  to  RTE  output  or  even  to 
broadcast content but also to public service content production by private or community-based entities operating in 
non-broadcast media (print/online etc.)

Recommendation Four – The Department of Communication should consider a new mechanism for appointing RTE 
and BAI authorities to broaden the range of individuals considered for such boards. This might be done by drawing 
on advice/nominations from what might broadly be termed social partnership groups (e.g. trade unions, employer 
bodies, universities, migrant groups, the charity sector, churches, environmental groups, sporting bodies etc.)

Recommendation  Five  – Though  it  may  make  relatively  little  different  to  current  actual  practice,  the  Department 
of  Communications  and  Department  of  Business,  Enterprise  and  Innovation  should  consider  the  implications  of 
adjusting the 2014 Competition and Consumer Protection Act to 

a) prohibit serving politicians from owning media outlets and 

b) introduce a clause prohibiting beneficial owners of media outlets from overtly influencing editorial content. 

Given that there may be an argument in favour of media owners having precisely the right to exercise such influence, 
proposal b) might be replaced with a requirement that  the exercise of ownership on influence should operate in a 
transparent manner (e.g. through a publicly available written letter as applied during the operation of Section 31 of 
the 1960 Broadcasting Act).  

Recommendation  Six  –  Commencing  rollout  of  the  long-promised  National  Broadband  Plan  is  vital  to  bringing 
broadband penetration in Ireland to a level considered a low risk by the MPM instrument. Given that the plan has 
repeatedly been delayed by the reluctance of private partners to fulfill the plan, the Department of Communications 
should consider whether the state should take on direct responsibility for completing the project. This costs associated 
with  this  are  far  from  trivial  but  in  an  era  where  broadband  access  is  already  a  de  factor  consumption  norm  for 
those in urban areas, lack of such access for those living in rural areas constitutes a growing social, civil and political 
disadvantage.  

Recommendation Seven – Future iterations of the Global Media Monitoring Project should disaggregate the reporting 
of  results  for  Ireland  from  the  UK  figures.  The  current  conflation  of  two  often  quite  different  media  ecospheres 
does not offer a solid basis on which to draw up policies relating the promotion of gender equality within the Irish 
marketplace. 

13

Recommendation Eight – The BAI should promote a public debate to identify mechanisms to bring a greater diversity 
of ethnicities, social classes and physical/mental abilities to the fore within Irish media organisations. The range of 
measure  may  include,  redrafting  those  sections  of  the  2009  Broadcasting  Act  which  (indirectly)  refer  to  minority 
groups, promotion of minority media education within third level institutions, more emphasis on minority personnel 
/content within broadcast schedules, adoption of codes of best practice within media organisations, etc.)

Finally, given that the report clearly identifies concentration of media ownership as a very high risk, it might reasonably 
be asked why this is not addressed in the recommendations above. The main reason for this recommendation is that the 
report finds that the existing legislative structure regulating media ownership – the 2014 Competition and Consumer 
Protection Act – already offers sufficient powers to the Minister for Communications to restrict further concentration 
if and when it threatens to undermine media pluralism and diversity. If there is a recommendation, however, it is to 
encourage the relevant Minister to consider whether, given the relatively high levels of concentration already evident 
in some Irish media markets, the initial assumption when assessing future mergers is that they will lessen diversity 
and pluralism. In other words that the onus would be on the parties to a merger to demonstrate that it does not have 
such an impact rather than on the Department of Communications and/or BAI to assert that it would.

14

ANNEXE I. COUNTRY TEAM

First 
name

Last 
name

Position

Institution

MPM2017 CT Leader 
(please indicate 
with X)

Roddy

Flynn

Associate Professor

Institute for Future Media and Jour-
nalism, School of Communications, 
Dublin City University.

X

ANNEXE II. GROUP OF EXPERTS

The Group of Experts is composed of specialists with a substantial knowledge and experience in the field 
of media. The role of the Group of Experts was to review especially sensitive/subjective evaluations drafted 
by the Country Team in order to maximize the objectivity of the replies given, ensuring the accuracy of the 
final results.

First 
name

Ciaran

Last name

Position

Institution

Kissane

Senior Manager

Broadcasting Authority of Ireland

Lisa 

Ni Choisdealbha

Seamus 

Dooley

Ailbhe 

O’Neill

Gavan 

Titley

Executive Direc-
tor
Irish Secretary

Assistant Profes-
sor
Senior Lecturer

Independent Broadcasters of Ireland 

National Union of Journalists

School of Law, Trinity College, Dublin 

Maynooth University

15

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ISBN:978-92-9084-688-8
doi:10.2870/087944