Frequently Asked Questions

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.

MOM has been proposed and launched by Reporter ohne Grenzen e. V. – the German section of the international human rights organization Reporters Without Borders (Reporters sans frontières, RSF), that 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, GMR cooperates with a local partner organization. In Montenegro, GMR worked with Balkan Investigative Reporting Network (BIRN Montenegro). The project is funded by the European Union.

The website affords a PDF download containing all website content. The PDF is automatically generated and thus updated on a daily base. It exists for all website languages. In order to generate the PDF, scroll down to the website footer, choose your preferred language and “Download complete website as PDF”.

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 and / or economic interests, even more so if individuals involved hold public office and do not 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 but not least, there are ‘normal’ – i. e. non-media-related reasons for owners to hide, such as tax avoidance.

MOM doesn’t make normative statements – it doesn’t suggest how to regulate media ownership. Which form of media concentration regulation 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.

Preferably, official data sources, and/or sources with high 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 in the Library. Further information is available upon request at BIRN Montenegro.

Audience data for the purpose of TV sampling was provided by IPSOS, while for other media formats, there is not any audience measurement system. For print – we have included all three newspapers, and one political weekly that we have in Montenegro. Portals were selected based on our own research on visits, using SimilarWeb data. For radios, but also some TVs that are not in the IPSOS measurement, we used official data of the Agency for Electronic Media (AEM) regarding their territorial coverage. 

Information on ownership structures, shareholders and financial statements of media companies and related individual owners were obtained from the Montenegrin Business Register, but also database of the Tax and Customs Administration with financial statements. The registers’ databases are online and publicly accessible in the Montenegrin language. 

MOM also sent information requests to all investigated media companies and used other relevant, accessible documents, foreign and domestic, including the data of AEM and the Ministry of Culture and Media.  

To guarantee objective sampling, MOM worked with an advisory group that commented and consulted throughout the research process. It was composed of national specialists with substantial knowledge and experience in the media and communications fields.

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).

For TVs we had access to the limited audience measurement, and all those were included in the sample. In order to ensure a higher sample, the rest was added, based on the highest territorial coverage. For radios territorial coverage was also used, as there is not any measurement in place.

Online media were selected using the highest number of visitor criteria, while the data was gathered through our research. When it comes to dailies, all were included in the sample.

In addition, all selected media were cross-referenced with third-party public opinion surveys that measure public trust in media, and all media mentioned in those research are in the sample. 

The media were selected according to the following criteria:

For TVs, MOM focused mostly on media with the highest reach, measured by audience share. The basis for selection was audience research data for 2022 provided by IPSOS. For media not included in the measurement, we used the additional criteria based on the highest coverage, using data available at the Agency for Electronic Media (AEM). 

For radios, since there is no measurement system in place, we used the criteria based on the highest coverage, using data available at AEM.

Online media were selected based on the internal research, using SimilarWeb software, covering the period from February to April 2023. All online media with more than a million visits in the reporting period were included in the sampling. 

When it comes to newspapers – all three dailies, as well as one political magazine that is published in Montenegro, were included in the sample. 

Montenegro ranks 39 (out of 180 countries) in the 2023 World Press Freedom Index published by Reporters without Borders. 

As the most advanced EU membership candidate of all countries, Montenegro faces significant foreign ownership in the most influential media. Since Montenegro is also a NATO member, it is very important for the public to know who owns Montenegrin media.  

In addition, Montenegro never previously had extensive media ownership research. 

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.

• Economic data: Market concentration based on market share could not be calculated for any media formats, as there is no information on the market size. In addition, most media revenues are not calculable since their company has another media outlet under the same roof, has other businesses, or is a non-profit organization. 
• Official audience measurement data is not publicly available.
• Some investigations, particularly into the diverse local markets and more hidden ownership structures and ownership disguised behind third persons would require more time and resources.
• Public spending/advertising for media is not transparent. It is impossible to identify public funds spent on media because they are not always clearly labelled as advertising, or the data are entirely missing. 

The data base 

• allows each citizen to get informed on the media system in general;

• creates a fact base for civil society’s advocacy efforts to further promote public consciousness on media ownership and concentration;

• serves as a point of reference for consulting competition authorities or governmental bodies when establishing suitable regulatory measures to safeguard media pluralism.

The database is a snapshot of the current situation, contextualized by historical facts. We aim at updating the website, depending on the situation. New country editions are being added frequently. 

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.