Digitalisation of content challenges legacy media products and contributes to market exit and consolidation across geographical markets. Media market structures are changing continuously, and the observation of increasing market concentration is not at all a new one. Over the last three decades, the Finnish mass media markets have become highly concentrated. Ala-Fossi et al. (forthcoming, 2022) have presented three reasons for that. First, foreign investments used to be strictly limited in Finland, but since the 1990s, the Finnish media policy has not actively aimed at preventing acquisitions or consolidation with any ownership limitations or regulations. Second, indirect tax subsidies, that is, a reduced rate of VAT favouring the largest newspaper publishing companies, may have even accelerated ownership concentration of the news media. Third, there is no special competition legislation for media to prevent ownership concentration or to protect diversity of ownership.
The highest degree of concentration is in radio broadcasting, which is dominated by three key players, public broadcaster Yleisradio Oy, Sanoma Media Finland Oy (part of the Sanoma Group) and Bauer Media Finland Oy (subsidiary of German Bauer Media Group). The two largest companies collect approximately four-fifths of all revenues of commercial radio stations in Finland. The three largest players in terrestrial television broadcasting are Yleisradio Oy, commercial broadcasters Sanoma Media Finland Oy and MTV Oy (a subsidiary of a Swedish multinational telecommunications company Telia Company Ab). Other television broadcasters include subsidiaries of international media groups like Warner Bros. Discovery and The Walt Disney Company Ltd. At the national level, newspaper ownership is slightly less concentrated than radio or television broadcasting (Ala-Fossi et al., 2020; Manninen & Hjerppe, 2021).
Nonetheless, it is the newspaper publishing that is presently characterised by frequent mergers and consolidation. When assessing the concentration of ownership of newspapers or, more broadly, print news media, one must be considered when assessing the structure of the markets. Only a few newspaper titles, including tabloids, can be classified as national and newspaper publishing markets are divided to several regional markets that are characterised by relatively large enterprises publishing one or several newspapers with predominantly regional circulation. With concentration and consolidation, most of the regional newspaper companies have reached a monopoly-like position in their markets, as they own the majority or all the local papers and free-sheets in the surrounding area (Björkroth & Grönlund, 2021). In 2021, the Keskisuomalainen Group owned almost a third (31%) of 234 member publications of the News Media Finland (NMF). The five largest newspaper publishing companies, measured by number of titles (including Keskisuomalainen Oyj, Sanoma Oyj, Hilla Group Oyj, Kaleva Oy and TS-Yhtymä Oy), owned more than half (59%) of all member titles of the NMF.
There are also significant differences in the ownership structure of even the largest newspaper publishers. Among listed companies, for example, Keskisuomalainen Oyj’s ownership is widely distributed and the share of even the largest owner remains at only about 5 per cent. Most of the company’s owners are private individuals. Instead, the owners of Sanoma Corporation, for example, have a lot of both foundations and institutional investors. The share of the largest owner is also a quarter. TS-Yhtymä Oy and Kaleva Oy, on the other hand, are unlisted companies where ownership is concentrated in one or a few families. From the data on direct ownership in the Finnish newspaper industry, one can find some substantial degrees of cross-ownership between the major newspaper publishing companies. Additional features that could affect the effective concentration are the existence of joint ventures, the indirect ownership of several rivals and that some newspapers have common institutional shareholders (Björkroth & Grönlund, 2021).
In terms of transparency and type of information that is missing from the database, there are noticeable differences in how generously the different companies report ownership related data to the public. Nevertheless, according to the Companies Act, an alphabetical list of shareholders in accordance with the share list must be kept, which must contain the shareholder’s name and address and the number of shares of each shareholder by share class. The list of shareholders is public. It is required by law to be kept at the company’s headquarters for all to see. In other words, any person outside the company is entitled to see the shareholder register without a separate request. In addition, everyone has the right to receive a copy of the shareholder register or part thereof after reimbursing the company’s expenses. The differences in transparency are of course most obvious between public corporations and limited companies, which are not traded on the stock market. However, a few of the limited companies did not provide any information about their owners on their website nor in their annual reports and did not provide this data when we requested a list of shareholders by e-mail. In a study conducted in 2018, about 25% of Finnish media outlets (n=197) did not have any reference to their owners on the front page of their websites (Ala-Fossi et al., 2018).
These are some of the reasons why Finland has performed rather poorly in the international comparison regarding ownership transparency and reporting of tax information (Finnwatch – Financial Secrecy Index). New amendments to the Trade Register Act will take effect in August of 2022 and these amendments should improve the ownership transparency of companies in Finland. Moreover, in the Money Laundering Act, a beneficial owner refers to a person who either owns the company or otherwise controls it. In most cases, the beneficial owners are the owners of the company. The Finnish Patent and Registration Office (PRH) provides details on beneficial owners entered in the Trade Register. However, the details on beneficial owners are not public in the same way as other company details entered in the Trade Register. The information about whether the notification of beneficial owners has been registered is public and free of charge. The PRH provides details on beneficial owners to only those whose purpose of use of the details is in accordance with the Act on Money Laundering, but the details are subject to a fee. Research on clarifying the concentration of ownership by researchers is not an activity that falls under this categorisation.
In Finland, the Foundation Act (487/2015) regulates the operation and supervision of the foundation. Each foundation has its own purpose that determines why that foundation exists. The establishment of a foundation will provide funds to fulfil a useful purpose as defined in the rules. The purpose cannot be to conduct business or generate a financial advantage for a related party and can only be changed to a limited extent. The foundation has its own administration, separate from its founders and other donors. Three of the analysed media companies were ultimately owned by foundations, which is of course not a transparency issue of the same magnitude as with limited liability companies – foundations are not in actuality owned by anyone. These foundations (Allerfonden, Harry Schaumans Stiftelse and Konstsamfundet), which are owners of the majority of the Swedish language newspaper titles in Finland, were however very transparent in their annual report in relation to economic figures and the companies they owned. Konstsamfundet’s main purposes, according to the statutes, are to support arts and different fields of culture for the Swedish-speaking Finns in our society. Harry Schaumans Stiftelse supports culture, education and science in Swedish-speaking Ostrobothnia. In addition, biggest owner of Sanoma Group is Jane and Aatos Erkko Foundation whose purpose is to support high-level, international scientific research as well as arts and culture. In addition, the fifth biggest owner of Sanoma Group is the Helsingin Sanomat Foundation, whose purpose is to secure the future of Finnish media and quality journalism as well as to support freedom of speech. In the Finnish context, foundations have multiple goals and ambitions as owners of media companies. However, hiding the ownership of the founders of the foundations is not a major incentive or priority.
Other missing information was mostly market sector-related data (absolute figures of distributed circulation and figures about the online audiences) and information regarding the newsroom’s participation in choosing the editor-in-chief. The online audience data of the different print and broadcasting media was underwhelming and was not reported by the companies themselves in any fashion. The only reliable data for measuring online audience was found at FIAM (Finnish Internet Audience Measurement). Their reports consist mainly of the internet audience of the newspaper outlets, and thus we could not get a comprehensive picture of how relevant the online market for the radio sector really is. The actions of Sanoma Oyj and Bauer Media Oy to concentrate nearly all of their (radio)broadcasting online presence to the applications Supla (Sanoma) and Radioplay (Bauer Media) also exacerbated the issue – Supla for example, offered no information in the app of who was editorially responsible for their news-related content.
Finland is a relatively large and sparsely inhabited country with many newspapers. In 2016, there were 39 daily papers (published four to seven times a week) and 135 other newspapers with a joint total circulation of 1.6 million copies (Ala-Fossi et al. 2018). The number of newspaper titles has remained almost the same, but now only five Finnish newspapers have subscribed to a report on their circulation (Media Audit Finland, 2022). The Finnish postal service Posti used to enjoy a special public support for newspaper delivery until 1993. However, the delivery support is about to be re-introduced at least temporarily. This reflects both the collapse of the volume of the postal market as well as the continuing importance of the printed papers. The Parliament is expected to grant an annual €15 million state subsidy for newspaper delivery until 2027, which would be available for Posti as well as private delivery companies. The subsidy would cover the expense of newspaper delivery on those two days a week when no other mail is no longer delivered. The amendment of the Postal Act should enter into force by the end of 2022 (MINTC, 2022).
The most important broadcast distributor, Digita, is currently owned by a global private investment company DigitalBridge. The former distribution division of public service broadcaster Yleisradio is still the only company in Finland, which operates nationwide broadcast networks with almost 100% geographic coverage and the only company with nationwide digital terrestrial television multiplex licences. In radio distribution, Digita is the only company with high-power FM transmitter sites, while the other radio broadcast distributors have only smaller towers and lower powers to provide. Digita has been identified by the national regulatory authority as a company with significant market power in the broadcast distribution wholesale market.
Digita delivers broadcast TV on two digital formats (DVB-T and DVB-T2), while radio is broadcast in Finland only on FM. Both AM radio as well as digital radio on DAB, DVB-T and DVB-H have been discontinued. The share of households using antennas for TV reception is about 50%. In May 2022, 89% of all television households and 77% of antenna TV households were able to receive HDTV using DVB-T2. Finnish TV broadcasters originally agreed to make the switch-off to DVB-T2 in 2020, but this plan was cancelled in 2018 and no new date for switch-off has been set (Ala-Fossi et al. 2018; Ala-Fossi et al. 2020; Traficom 2022a). In 2021, 74% of all TV viewing in Finland was still based on antenna or cable reception (broadcasting) while 26% was using broadband instead. Among people under 45 years, broadband TV is already 54% of viewing (Brun, 2022).
In Finland, 96% of households have an internet connection, and only 2% rely just on fixed broadband while 51% of the households are using both fixed and mobile broadband. But 43% of the Finnish households are dependent on mobile broadband only, which is proportionally more than anywhere else in the EU (Traficom, 2022b). Finland is also the world leader in mobile data consumption with 31 GB per subscription in a month (OECD, 2020). One reason for this is that the Finnish government granted mobile spectrum licences without any auctions until 2013, so the telecom operators were more interested in developing their mobile businesses than making additional investments into fixed networks. As a result, the availability of high-speed fixed broadband has improved relatively slowly. In 2021, 71% of households had at least 100 Mbit/s connection available (Ala-Fossi et al., 2018; Traficom, 2022c).
There are three major telecom companies: Telia, Elisa and DNA, which dominate both the fixed broadband and mobile broadband markets in Finland. In fixed networks, the market leader is DNA with 32% share, followed by Elisa with 30% and Telia with 25% market share. The other players are Finnet with 9% and all the other operators together with 4% share. The mobile market is even more consolidated, as Elisa has 39% share, Telia 31% and DNA 29% (Traficom, 2022d; Traficom, 2022e). In all these three major companies there is a significant Nordic state ownership involved. In 2019, DNA became a subsidiary of Norwegian Telenor, where the State of Norway directly owns the majority of shares (54%). The State of Sweden owns 39.5 % of Telia (including the former Telecom Finland) and the holding company of the State of Finland owns about 10 % of Elisa. Telenor is the biggest of the three as its turnover in 2020 was more than six times larger than Elisa’s turnover. Besides telecom business, Telia is involved also in TV business as it owns in Finland also a major commercial broadcaster, MTV3 (Koskinen, 2021).
Finnish news media are in a comparatively somewhat better position when it comes to dependence on the tech giants (Linden et al, 2021). In a study by Reunanen and Pöyhtäri (2021), the online news sites of legacy media companies have an 81% weekly reach. This is higher than in any other country in the international survey carried out yearly by the Reuters Institute at Oxford University (Newman et al., 2021). Finns usually go straight to the web pages or apps of legacy media for news delivery (71%), while 45% access news through social media, which is less than in the majority of countries.
However, the global intermediaries are globally major supporters of journalism. Companies such as Google and Facebook have created a variety of training initiatives, laboratories, and on-going collaborations with news organisations to help journalism succeed in the new digital media landscape. These initiatives also include funding and support for enhancing newsrooms’ capabilities in boosting productivity and collaboration in news production and distribution through technology. Many news media companies have agreed to take part in these initiatives. For example, in April 2020, Google News Initiative launched the global Journalism Emergency Relief Fund to support small and medium-sized news organisations producing original news for local communities. The aim of the Fund was to support the production of original journalism for local communities in the face of the Covid-19 pandemic. According to data provided by Google, 80 Finnish newsrooms received funding, (Lindén et al., 2022).
The newspaper print circulation data is no longer produced for commercial purposes and that is why all comparisons based on circulation data have now become impossible. In addition, the national postal service Posti does not publish anymore its statistics on the newspaper delivery market for business reasons. Even the national regulator has to rely on estimates.
The pricing practices of a broadcast delivery company with significant market power, Digita, are not transparent. For example, the exact Digita prices of delivering public television services for Yleisradio have to be removed from all public documents and replaced with a certain range of pricing.
The ownership of the major telecom operators is not fully transparent. For example, almost 50% of Elisa’s owners are foreign companies, which are allowed to be nominee registered. The information on the shares is entered in the nominee register and their ownership is not primarily public.
During the last ten years, online advertising has grown to half (50%) of all media advertising and two international intermediaries, Google and Facebook, collect most of the revenues in Finland. Facebook and Google do not publish country-specific information about their profits from advertising, so estimations are based on secondary information. (Lindén et al., 2022)
There are various types of transparency requirements through the Limited Liability Companies Act and other company-related legislation, but there are no regulations in this area specifically related to the media. The Finnish corporate governance model of listed companies is based on the principle of majority rule, which promotes a strong ownership role and is balanced out by the principle of equal treatment, qualified majority requirements, and the rights given to minority shareholders, as well as a clear division between the responsibilities of the company’s governing bodies. The most essential domestic legal provisions are included in the Limited Liability Companies Act, the Securities Markets Act, the Auditing Act, and the Accounting Act. Finnish listed companies are also bound by the EU-level regulations, as well as the Rules of the Helsinki Stock Exchange (including the Corporate Governance Code and the associated reporting requirements), as well as the regulations and guidelines issued by the Financial Supervisory Authority (FIN-FSA).
Regarding company law on mergers and takeovers, there is no media specific competition legislation to prevent ownership concentration or to protect diversity of ownership. However, under the Competition Act and EU competition rules, the activities of companies must not restrict competition. Companies may not take part in a cartel, excessively restrict contractual partner’s activities, or abuse its dominant market position. In this sense, from the point of view of legislation, media companies are, at least for the most part, treated in the same way as any other companies.
As with the above-mentioned transparency regulation, the legal framework of media is for the most part covered in general legislation. There are, however, two acts that are relevant and media specific in Finland: The Act on Electronic Communication Services (917/2014) and The Act on Yleisradio Oy (1380/1993). The Act on Electronic Communication Services aims to ensure efficient use of radio frequencies, promote competition in the market sector and to ensure that the national communication networks and services are technologically advanced, of good quality, affordable, reliable, and secure. The Act on Yleisradio Oy defines the duties of the state-owned company’s supervisory board, the company’s public service duties among other things. The company’s task is to create a versatile and comprehensive television, radio and additional service to the public and these services must be available to everyone on equal terms.
Between 2000 and 2021, the Finnish Competition and Consumer Authority (FCCA) has given its decisions to approximately 30 media company-related acquisitions. Almost all of them have been approved as such and only a few of the decisions are directly related to the news media. During the same period, the FCCA made roughly twenty other decisions, mostly related to suspected abuses of dominant positions, concerning media companies.
Ad-hoc media policy lacking long-term goals and commitment:
Media actors/industry representatives and communication policy researchers have long criticised Finnish communication policy for its lack of an overall view and for ad-hoc and one-sided approaches. In addition, there is no single body or authority that would be fully responsible for leading and coordinating media policy, but decision-making and its implementation are spread over a few different administrations and ministries, and the information used as a basis for decision-making is often quite fragmented, slender in content or industry-specific, despite its apparent abundance (see Ala-Fossi et al., 2018).
No direct subsidies for media:
Finland has currently no permanent system for direct media support besides a small special support for cultural publications, so the Finnish government has had to save so far two crucial private news organisations (the Finnish News Agency in 2018 and MTV3 News in 2015-2018) from bankruptcy with separate tailor-made cash injections. Again, during the Covid-19 epidemic, a separate temporary subsidy system had to be developed. At the same time, indirect subsidies in form of reduced VAT remain significant, but are often neglected in public discussion.
Transparency of cross-border ownership remains unsolved question:
In Finland, every Finn who owns shares is required by law to have an account at Euroclear Finland, so we can have exact data of the Finnish owners. However, this kind of direct holding system is not very typical in the EU. And even in Finland, all the foreign investors can use nominee accounts, which allow to hide the names of the true owners.
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Traficom (2022a). Increase in HD ready equipment in households. Retrieved from: https://tieto.traficom.fi/en/statistics/increase-hd-ready-equipment-households
Traficom (2022b). Broadband penetration in households. Retrieved from: https://tieto.traficom.fi/en/statistics/broadband-penetration-households
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Traficom (2022d). Fixed broadband subscriptions. Retrieved from: https://tieto.traficom.fi/en/statistics/fixed-broadband-subscriptions
Traficom (2022e). Mobile subscriptions. Retrieved from: https://tieto.traficom.fi/en/statistics/mobile-subscriptions