1. What is MOM?
The “Media Ownership Monitor” (MOM) has been developed as a mapping tool in order to create a publicly available, continuously updated database that lists owners of all relevant mass media outlets (press, radio, television sectors and online media).
MOM aims to shed light on the risks to media pluralism caused by media ownership concentration (for more information: Methodology). In order to grasp the national characteristics and detect risk-enhancing or risk-reducing factors for media concentration, MOM also qualitatively assesses the market conditions and legal environment.
2. Who is behind MOM?
Since 2015, MOM has been incubated by Reporter ohne Grenzen e. V. – the German section of the international human rights organization Reporters Without Borders (Reporters sans frontières, RSF), which aims to defend freedom of the press and the right to inform and be informed anywhere in the world.
In 2019, the project was spun-off to the Global Media Registry (GMR), an independent, non-for profit social enterprise registered under German law.
In each country, MOM is implemented in cooperation with a local partner organization. In Tunisia, RSF worked with Al Khatt. The project was funded by the German Federal Ministry of Economic Development and Cooperation (BMZ).
3. Why is transparency of media ownership important?
Media pluralism is a key aspect of democratic societies as free, independent, and diverse media reflect divergent viewpoints and allow criticism of people in power. Risks to diversity of ideas are caused by media market concentration, when only a few players exert dominant influence on public opinion and raise entrance barriers for other players and perspectives (media ownership concentration). The biggest obstacle to fight it is lack of transparency of media ownership: How can people evaluate the reliability of information, if they don´t know who provides it? How can journalists work properly, if they don´t know who controls the company they work for? And how can media authorities address excessive media concentration, if they don´t know who is behind the media´s steering wheel?
MOM thus aims to create transparency and to answer the question “who eventually controls media content?” in order to raise public awareness, to create a fact base for advocacy to hold political and economic players accountable for the existing conditions.
As we consider ownership transparency as a crucial precondition to enforce media pluralism, we document the openness of media companies/outlets to provide information on their ownership structure. Considering their answers, we distinguish different levels of transparency – which is indicated for each media outlet and media company on their profile.
Media owner’s motivation to remain hidden or even actively disguise their investments can vary from legitimate to illegal and be rooted in personal, legal or business-related reasons – or a mix thereof, in extreme cases even including criminal offenses like tax evasion or breaches of anti-trust laws.
Some of those reasons include the following:
- In several countries, media ownership is restricted by law in order to avoid concentration. So if one individual wants to extend his or her media empire beyond these limits, proxy owners and/or shell companies registered abroad, even off-shore, are frequently being used.
- Sometimes, media owners receive personal threats or face other dangers either originating from governments or competing businesses and therefore decide to remain unknown to protect themselves.
- In many cases, media ownership is intertwined with undue political or economic interests, even more so if individuals are involved that hold a public office and who don’t want to disclose such a conflict of interests.
- In rare cases, the disguise of media ownership happens unintentionally because over time and through mergers and acquisitions, corporate structures became so complex that the original beneficial owner is difficult to identify.
- Last not least, there are ‘normal’ – i. e. non-media-related reasons for owners to hide, such as tax evasion.
4. What kind of concentration regulation does MOM suggest?
MOM doesn’t make normative statements – it doesn’t suggest how to control media ownership. Which form of media concentration control can work, depends on the country context, the existing legal and market conditions, the ownership landscape.
MOM provides a transparency tool to enforce a democratic discussion on that issue as well as good governance: decisions are likely to be of higher quality and to better reflect the needs and wishes of the people if they have access to adequate information and broad consultations, with views and opinions freely shared.
5. How is data collected and validated?
Preferably, official data sources, and/or sources with a high level of reliability and trust are used.
Whenever not publicly available, information was directly requested of media companies, political representatives and research institutes.
All sources are thoroughly documented and archived.
We used mainly data made available by
• Media outlets/companies
• JORT (Official Journal)
• l’ONT (National Broadcasting Office)
• HAICA (Independent Authority for Audio-Visual Communication)
• Media Use in the Middle East 2015 by Northwestern University in Qatar
In order to guarantee and verify the objective evaluation, MOM worked with an advisory group that commented and consulted throughout the research process. It was composed of national specialists with a substantial knowledge and experience in the media and communications fields. Amongst others, the following experts were accompanying the research process.
The Advisory Group included :
• Yasmine Kacha, RSF Tunisia
• Ons Ben Abdelkarim, Al Bawsala
• JazemHalioui, Web Radar
• Hamida El Bour, TAP
• Larbi Chouikha, Professor
• Inès Bel Aiba et Guillaume Klein, AFP
• Ziad Dobban, SNJT
• MouhebGaroui, IWatch Organisation
In addition to media representatives who have responded positively to the request for an interview, the following people shared their expertise:
· Nouri Lajmi, Hichem Snoussi & Habib Belaid, HAICA
· Elouaer Lamjed, National Broadcasting Office
· Kamal Labidi, ex-President of INRIC
· Dhafer Neji & Sonia Memmich, Présidence du Gouvernement
· Abdelkrim Hizaoui, Professor IPSI
· Hichem Guerfali, C3
· Hana Cherif, MediaScan
· AmenallahAyari, Ipsos
· TaïebZahar, FTDJ
· Saloua Ghazouani Oueslati, Article 19
· MongiKhadhraoui, Journalist at Dar Anouar
· Lamia El Kateb, Registre de Commerce
· NejiBghouri, FahemBoukadous, SNJT
References are available on request from Al Khatt.
6. How is "most relevant media" defined?
The main question is: which media outlets influence the opinion-forming process? In order to scan all relevant media, we included all traditional media types (Print, Radio, TV, Online).
The media were selected according to the following criteria:
- MOM focused on media with the highest reach, measured by audience share. At most 10 media outlets per media type (TV, radio, print, Online) were selected.
- The news worthy and opinion content. The study focuses on general information with a national focus. As such, media with specific thematic focus (music, sport), social networks, search engines and advertisement were excluded.
- The selection based on these criteria initially consisted of plus/minus ten media outlets per media type (TV, print, online. Shedding light on these most relevant media outlets already allows revealing tendencies in media concentration. More media outlets were and will be added – if they proof to be relevant in terms of their owner or of their influence on public opinion (read more - “How are media outlets selected?”).
7. How are the media outlets selected?
According to the methodology, the 40 media were supposed to be chosen based on audience figures. Obtaining reliable audience figures however posed several problems in Tunisia (see measuring audience). Nevertheless, the team was forced to choose 40 media based on these figures. A different source was used for each media type, subject to availability and to diversify the sources. The list of 40 media will be updated once truly reliable data is available.
The audience data for television channels are based on Ipsos; these are figures for April 2016. These figures were chosen taking into account the fact that Ipsos works at the national level and does not seem to have any conflict of interest (unlike other research institutes)
Source : Ipsos (2016), TV Viewership in Tunisia 2016
The choice of radio stations is based on the audience data from Sigma Conseil. Sigma Conseil was chosen as it is the only research institute that conducts a survey at the national level (unlike Mediascan that focuses on Tunis, Sousse and Sfax). As most radio stations are broadcasted only in certain regions and the audience varies enormously according to each region, a survey with a national focus was necessary. The average audience share of last year (April 2015-March 2016) was calculated to determine the 10 most popular stations. Ramadan (June / July) was excluded due to lack of numbers and changing habits. In addition, Diwan FM was included as some of its shareholders are common with other radio stations of the analysis.
Source: Sigma Conseil (2016/2015). Average of january, february, march 2016, April, May, August, September, October, November, December 2015, available at:
The print outlets were selected based on:
- their frequency of publication. The media outlets selected must be updated at least once a week with current content.
- latest readership figures available. The only figures that the team was able to obtain are the 2015 readership figures from Mediascan.
- There is a lack of circulation and sale figures. Despite the legal obligation to publish circulation figures, newspapers do not do so. No institute or organization holds accurate circulation and sale figures. Research institutes are the only ones that elaborate readership figures based on people’s declarations.
The websites were chosen based on the following criteria
• Their rank on Alexa.com on 17 May 2016, as there were no other available rankings. An additional website was included to show the problems of Alexa. In June 2016, one of the 10 websites was not anymore in the ranking as it had cancelled its Alexa subscription. Its traffic numbers are now estimated. Another website, however, subscribed and thus moved up in the ranking (see measuring audience).
• A Tunisian website with news/opinion content. As such, social networks, online stores and advertisement websites were excluded.
• The advisory board debated the inclusion of the website « tunigate.net » as it is little known in the media landscape. The site was included as it is in the Top 10 Alexa sites.
8. Why Tunisia?
The media landscape is in a transition phase since the 2011 revolution. New decrees/laws on transparency and ownership concentration were enacted; new regulatory authorities created (HAICA) or are under discussion (Press Council); new media received their licences and others were confiscated by the state. Freedom of press improved in recent years. In 2016, Tunisia ranks 96th in the Press Freedom Index published by Reporters Without Borders.
At the same time, important challenges remain for press freedom and diversity. During this transformation period, the MOM provides a detailed analysis about concentration and ownership, to propose and push for reforms that ensure true media diversity.
9. Does the MOM only exist for Tunisia?
MOM was developed as a generic methodology that can be universally applied – and potentially will be. Notwithstanding that media concentration trends are observable worldwide; implementation and analysis will first take place in developing countries. MOM has been implemented in around 20 countries over the course of three years. All country projects can be found on the global website.
10. What are the limitations of the study?
· No reliable audience data: the audience figures available are highly contested (see measuring audience). Therefore, these figures were used only for the selection of the 40 most important media, and not for the calculation of indicators. The lack of reliable data is a risk to a diverse media market.
· No economic data: There are no exact figures on the economic market. Only a few media shared their financial data, which are published on their profiles. The only data on advertising are from research institutes, but they are inflated.
· Conflicting data: It is difficult to obtain accurate data on the number of existing media in Tunisia. The various sources (ONT, report of the President of the Republic) are not consistent.
· Data is not up-to-date: It is impossible to know whether the available data on the Registry of Commerce is updated. Firstly because the Registry of Commerce is not able to follow up with all companies to ensure they report every change. Secondly, the courts do not transfer all documents to the Registry of Commerce, even if they are obliged to do so.
11. Who do we target?
· allows citizens and anyone else to learn about the media system in Tunisia and to know the owners of the media they follow. It also encourages awareness about the importance of ownership and transparency.
· creates a database and discusses issues related to diversity and transparency of the Tunisian media sector, which can be used by civil society organizations in their lobbying, by the government to strengthen diversity and by the HAICA and future regulatory bodies to better fulfil their mandates.
12. What happens next?
The database is a snapshot of the current situation, contextualized by historical facts. It will be updated regularly by Al Khatt.
The project aims to generate a public debate and changes, particularly on the following topics:
· Media transparency
· Measuring audience
· The sale of confiscated media
· the economic situation
· Political affiliations
13. Are there similar projects?
The Media Ownership Monitor is mainly inspired by two similar projects. Especially the indicators for a later ranking rely heavily on the EU-funded Media Pluralism Monitor of the Centre for Media Pluralism and Media Freedom (CMPF) at the European University Institute (EUI, Florence). Moreover, Media Pedia, an ownership database developed by investigative journalists in Macedonia served as inspiration for the Media Ownership Monitor. An overview over other similar projects can be found in the table below.
A Spanish NGO that works in the field of media ownership transparency in several European countries.
An NGO which works in the field of press freedom. It implements media concentration projects.
The Media Freedom Navigator of Deutsche Welle provides an overview of different media freedom indices.
A database of television and audiovisual services in Europe.
The Website provides a summary and analysis of the state of the media in Europe and neighbouring countries.
The Media Pluralism Monitor assesses risks for media pluralism in the EU Member States.
The network provides information of the state of the media in many countries.
The Media Sustainability Index (MSI) provides analyses of the conditions for independent media in 80 countries.
The Website provides information about media ownership in Great Britain.
The organisation publishes an interactive database about media in the United States.
Monitors media ownership and the impact on media pluralism in southeastern Europe and EU member states.
A research that works with authors from 30 countries in the world about media concentration using a common methodology.
A database of international corporations of the world´s biggest media.
Media Development Indicators - A framework for assessing media development.