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Transparency as a democratic requirement

Liberal democracies have consistently ascribed democratic roles to news media, namely to provide citizens with accurate information about current affairs, to mediate different interests in societies, and to expose wrongdoings and abuse of power (Trappel & Tomaz, 2021). Democratic accountability with regard to the fulfilment of these roles requires media ownership transparency, as encouraged by the European human rights framework (Craufurd Smith, Klimkiewicz, & Ostling, 2021; European Commission, 2020). Standards and guidelines are provided in several official documents, such as the Audiovisual Media Services Directive (AVMSD) (European Parliament & Council of the European Union, 2018) and the Recommendation CM(2018)1 on media pluralism and transparency of media ownership (Council of Europe, 2018). In its Recommendation, the Council of Europe (CoE) indicates that Member States have the positive obligation of ensuring “transparency of media ownership, organisation and financing” (Council of Europe, 2018, Appendix, para. 1.7). Disclosure of this information should occur both upwards (to the public bodies, such as media regulatory authorities) and downwards (to the public, citizens, civil society) (Council of Europe, 2018, Preamble, para. 1; Craufurd Smith et al., 2021).

Scope of monitoring

Transparency in media ownership and control should be monitored across all media involved in news provision that influences public opinion. This includes print, broadcast and online media. The bigger focus lies on organisations and brands that produce news content, as they are the anchors of the public debate even in highly digitalised societies (Benkler, Faris, & Roberts, 2018; Hindman, 2009; Jakubowicz, 2015; Newman et al., 2021).

At the same time, control over news provision in the current information environment must also consider institutions and processes involved in content distribution. Economic, technological and legal developments have constrained potential control over news content by organisations involved in linear distribution (print and broadcasting). In non-linear distribution, however, digital media increasingly curate content (prioritising, promoting, up-ranking), directly interfering with exposure of users to news (Johnson, 2020; Mazzoli & Tambini, 2020; Nieborg & Poell, 2018). The CoE explicitly recommends to “improve the transparency of the processes of online distribution of media content, including automated processes” in order to make clear to the public who makes decisions with regard to the (news) content available (Council of Europe, 2018, Appendix, para. 2.5). Therefore, in its pilot phase, the EurOMo covers relevant media distributors as well, monitoring exclusively non-linear distribution (digital information intermediaries).

Ownership and control dimensions

The analysis of media ownership and control must go beyond legal ownership and refer to the ultimate decision-making power, as emphasised by recent scholarly literature (Benson, 2018; Gallego Ramos, 2021; Noam, 2016; Sjøvaag & Ohlsson, 2019).

In media supply, the EurOMo translates the different levels of decision-making power into the following dimensions (mostly inspired in Gallego Ramos, 2021, p. 201):

  • Legal: owners and ownership forms of news media outlets acknowledged by competent authorities;
  • Economic: financial beneficiaries, funders and funding models of media outlets, as well as involvement of other business interests in their funding;
  • Managerial: stakeholders who define editorial objectives of media outlets and their resources allocation;
  • Associative: related individuals, groups or institutions with capacity to influence the ultimate decision-making power in media outlets, especially political ties.

With regard to the transparency of distribution decision-making power, digital information intermediaries are analysed in three dimensions (Johnson, 2020; Mazzoli & Tambini, 2020):

  • Legal: owners acknowledged by competent authorities;
  • Technical: features such as interfaces, code, and automated decision-making that can promote or constrain dissemination of news content;
  • Economic: commercial deals or ownership relations between intermediaries and news content providers.

The role of public policy

EU and national laws establish the legal framework in which both media supply and distribution operate. Some degree of transparency in their ownership and control dimensions is required in several laws, especially media law, company law, and competition law (Picard & Pickard, 2017, p. 29). An analysis of this framework requires a comparable database of these laws as well as the assessment of their adequacy to achieve the standards established by the EU human rights framework.

Concerning media supply, national regulation should reflect at least the latest review of the Audiovisual Media Services Directive (AVMSD). It is necessary to assess the legal obligations to disclose ownership information, the role of media regulatory authorities and the provisions for public accessibility of media owners’ identities (European Parliament & Council of the European Union, 2018).

Regulatory approaches to distribution should enforce legal provisions to limit influence of distribution channels in news provision and to make transparent any entanglements between them and news providers, such as disclosure requirements of technical features and commercial arrangements (Mazzoli & Tambini, 2020; Picard & Pickard, 2017, p. 30).


Benkler, Y., Faris, R., & Roberts, H. (2018). Network propaganda: Manipulation, disinformation, and radicalization in American politics. New York, NY: Oxford University Press.

Benson, R. (2018). Rethinking the sociology of media ownership. In L. Grindstaff, M.-C. M. Lo, & J. R. Hall (Eds.), Routledge Handbook of Cultural Sociology (pp. 387–396). Routledge.

Council of Europe. (2018). Recommendation CM/Rec(2018)1 of the Committee of Ministers to member States on media pluralism and transparency of media ownership. Strasbourg: Council of Europe Publishing. Retrieved from

Craufurd Smith, R., Klimkiewicz, B., & Ostling, A. (2021). Media ownership transparency in Europe: Closing the gap between European aspiration and domestic reality. European Journal of Communication, 36(6), 547–562.

European Commission. (2020). Protecting European democracy from interference and manipulation – European Democracy Action Plan. Retrieved 7 August 2020, from

Gallego Ramos, J. R. (2021). Las formas de propiedad de los medios de comunicación: Estado de la cuestión. Anagramas Rumbos y Sentidos de la Comunicación, 20(39), 197–221.

Hindman, M. (2009). The myth of digital democracy. Princeton: Princeton University Press.

Inter-American Development Bank & Organization for Economic Cooperation and Development. (2019). A beneficial ownership implementation toolkit. Inter-American Development Bank.

Jakubowicz, K. (2015). New media ecology: Reconceptualizing media pluralism. In P. Valcke, M. Sükösd, & R. G. Picard (Eds.), Media pluralism and diversity (pp. 23–53). London: Palgrave Macmillan UK.

Johnson, C. (2020). The appisation of television: TV apps, discoverability and the software, device and platform ecologies of the internet era. Critical Studies in Television, 15(2), 165–182.

Mazzoli, E. M., & Tambini, D. (2020). Prioritisation uncovered: The discoverability of public interest content online. Council of Europe. Retrieved from Council of Europe website:

Newman, N., Fletcher, R., Schulz, A., Andı, S., Robertson, C. T., & Nielsen, R. K. (2021). Reuters Institute Digital News Report 2021. Oxford: Reuters Institute, University of Oxford. Retrieved from

Nieborg, D. B., & Poell, T. (2018). The platformization of cultural production: Theorizing the contingent cultural commodity. New Media & Society, 20(11), 4275–4292.

Noam, E. M. (Ed.). (2016). Who owns the world’s media? Media concentration and ownership around the world. Oxford; New York: Oxford University Press.

Picard, R. G., & Pickard, V. (2017). Essential principles for contemporary media and communications policymaking. Oxford: Reuters Institute for the Study of Journalism. Retrieved from

Sjøvaag, H., & Ohlsson, J. (2019). Media ownership and journalism. In H. Sjøvaag & J. Ohlsson, Oxford Research Encyclopedia of Communication. Oxford University Press.

Trappel, J., & Tomaz, T. (2021). Democratic performance of news media: Dimensions and indicators for comparative studies. In J. Trappel & T. Tomaz (Eds.), The Media for Democracy Monitor 2021: How leading news media survive digital transformation (Vol. 1, pp. 11–53). Gothenburg: Nordicom. Retrieved from

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