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This document presents a summary of the theoretical rationale we used to develop the methodology and collect the data for the Euromedia Ownership Monitor (EurOMo) database.

Following its mandate by the EU Commission expressed in the European Democracy Action Plan (European Commission, 2020), the EurOMo has a single mission: enhance transparency of news media ownership and control in European Union countries.

The monitor intends to fulfil it by (1) providing systematic information on ownership and control of the most important news media outlets in EU Member States, (2) indicating which relevant information is missing, and (3) assessing risks to transparency of media ownership and control.

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).

In the European Union, 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). The EurOMo considers transparency towards the public as the gold standard, the reference point to assess performance.

Scope of monitoring

Transparency in media ownership and control should be expected, hence 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). There is no consensus on how to measure and assess which news organisations influence public opinion, but the EurOMo considers exposure to news as a functional proxy for this influence (Mutz & Martin, 2001; Yang et al., 2020).

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

This accords with the CoE Recommendation, which speaks of “different levels of strength that lead to exercising control or direct or indirect influence over the strategic decision making of the media outlets” (Council of Europe, 2018 Appendix, para. 3.5). Even beneficial ownership, according to the OECD, includes not only legal ownership interest, but also other forms such as “control of a significant percentage of voting rights, or the ability to name or remove the members of an entity’s board of directors” (Inter-American Development Bank & Organization for Economic Cooperation and Development, 2019, p. 4).

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

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

While content production remains extremely relevant, assessment of 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 players increasingly curate and moderate content (promoting, prioritising, downranking, or even suppressing), 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 monitors relevant stakeholders operating non-linear distribution, also known as digital information intermediaries or digital platforms (search engines, social media, video-on-demand services, news aggregators). At the same time, we seek to understand their role in context, taking into account their relevance in comparison with other types of media distribution (print, broadcast, direct online, online via digital intermediaries).

Considering the influence digital intermediaries can have in news provision (Johnson, 2020; Mazzoli & Tambini, 2020), the EurOMo is concerned about transparency in technical and economic aspects. The technical one refers mostly to criteria for automated content curation that can promote or constrain dissemination of news content. The economic influence addresses commercial deals between intermediaries and news content providers that might lead to different treatment.

Finally, EU and national laws establish the legal framework in which both media content production and distribution operate. Some degree of transparency in 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.

National regulation should reflect at least the latest review of the Audiovisual Media Services Directive (AVMSD), in 2018. 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). These topics are addressed in the public policy dimension of the EurOMo.

In summary, the EurOMo theoretical framework considers that assessing and enhancing transparency in media ownership and control requires a multidimensional approach that covers:

  • Ownership structure
  • Management
  • Economic control
  • Relations
  • Distribution
  • Public policy

Based on this framework, we developed indicators for data collection and assessment. Read the methodology for the details.


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