Indicators of Risks to Media Pluralism

Explanation

Media Audience Concentration

This indicator assesses the concentration of audience and readership across media sectors based on audience share. Concentration is measured by using the Top 4 owners in the market. Presented are the sums of the audience / readership / subscription shares of the major 4 owners within each market.

In Mongolia, there are no in-depth media audience surveys available except for the TV market. In 2014, the Press Institute stopped its regular audience surveys due to a lack of funding.

Since 2011, the private company Maxima LLC is monitoring the television market and sells the reports. MOM is using those for TV audience evaluation.

For print the circulation figures of the Press Institutes report Mongolia Media Today 2016 are being used.  

For radio and online news audiences the Press Institutes ranking is based on popularity according to qualitative opinion polls / interviews (See D-1) but with no actual market shares.

Results:
The TV and radio markets have a medium concentration level.

The print media market and Online News sector are highly concentrated.

Television: 

The TV market has a Medium concentration level, with 4 major owners reaching 30, 3 % of the audience.

The public service broadcaster MNB TV has the largest audience shares with channels MNB and MNB2 news channel summed up, reaching 18, 1 %. This needs particular consideration since the government influence on MNB is still quite strong, thus the potential influence on public opinion. The privately owned Mongol TV reaches 5, 5 % of the audience shares in the market. UBS is third with 3, 4 % audience share and TV9 is on rank 4 with 3, 3 %.

biggest owners (company or group) in TV sector

sum of audience share of media outlets by company

MNB / Public Service Broadcaster

18,1 %

Mongol HD TV / Company Gatsuurt

5,5 %

UBS / Ulaanbaatar Television LLC

3,4 %

TV9 / Media Holding LLC

3,3 %

TOTAL

30,3 %

 

Print:
The circulation numbers of print media in Mongolia is contested, as everywhere else. Experts argue that print media tend to exaggerate their circulation shares to attract more advertising and are considered unreliable. MOM team in Mongolia used the self-declared numbers obtained from print media outlets, as documented in Press Institutes “Mongolia Media Today 2016” (D-1).

According to these numbers, the print media market is highly concentrated with four major owners reaching an audience of 64 %. These are Udriin Sonin / Udrin Medee Media House with 24, 9 circulation share alone. Second is Unoodor / Mongol News Group with 15,8 % circulation share, third Zuunii Medee / Zasgiin Medee LLC with 12 % and fourth Undesnii Shuudan newspaper owned by Undesnii Shuudan NGO with 11,3 %.

biggest owners (company or group) in PRINT sector

sum of circulation share of media outlets by company

Udriin Sonin / Udrin Medee Media House

24,9 %

Unoodor / Mongol News Group

15,8 %

Zuunii Medee / Zasgiin Medee LLC

12,0 %

Undesnii Shuudan / Undesnii Shuudan NGO

11,3 %

TOTAL

64,0 %

 

Radio:
For radio audiences the Press Institutes ranking is based on popularity according to qualitative opinion polls / interviews. (See D-1)

The most popular radio in the country is Mongolian National Public Radio 106, 0 which is part of the Public Service Broadcaster MNB. The second most popular radio is Shine Mongol Radio 101.7 owned by the private company Shine Mongol Radio Dolgion LLC with many radio stations in rural areas. Third is Family Radio 104.5 owned by Salkhi Entertainment LLC a comparably small company. Fourth is Elgen Nutag FM 96.9, owned by Ekh Elgen Nutag Company which is owned by Mr. Batbayar Dugarvaj. This rather unique radio places high importance on literature and drama and is the first to introduce classic literature in audio format. So apart from the Public Service Broadcaster there is no big company dominating the radio market.    

The data available allows only an estimation based on data from the Press Institute. According to this estimation the four most popular radio stations and their respective owners have a combined audience share of approximately 36 %. So the radio market has a Medium concentration level.

biggest owners (company or group) in radio sector

Most popular radio channels

MNB Public Service Broadcaster

Mongolian National Public Radio 106

Shine Mongol Radio Dolgion LLC

Shine Mongol Radio 101.7

Salkhi Entertainment LLC

Family Radio 104.5

Ekh Elgen Nutag Company

Elgen Nutag FM 96.9

TOTAL

 Estimated 36 % audience share

 

Online News:

For online news audiences the Press Institutes ranking is based on popularity according to qualitative opinion polls and the percentage of people that used a particular news website “Today / Yesterday”. (See D-1)

The most popular online news websites with 18 % share each are gogo.mn, owned by Mongol Content LLC and ultimately by MobiCom, and news.mn, owned by News Agency LLC. Third is ollo.mn with 9 %, owned by the stock exchange company Ollo LLC. Fourth is ikon.mn with 7 %, owned by Benecraft LLC.

Combined these four news websites and their respective owners have a 52 share in popularity and being frequently used. This means the Online News sector is highly concentrated.

biggest owners (company or group) in Online News sector

Popularity / share of people that used the website “today / yesterday”

Gogo.mn / Mongol Content LLC

18 %

News.mn / News Agency LLC

18 %

Ollo.mn / Ollo LLC

9 %

Ikon.mn / Benecraft LLC

7 %

TOTAL

52 %

 

Concentration measures:

LOW (1)

MEDIUM (2)

HIGH (3)

Audience concentration  

 

If within one country the major 4 owners (Top4) have an audience share below 25%.

If within one country the major 4 owners (Top4) have an audience share between 25% and 49%.

If within one country the major 4 owners (Top4) have an audience share above 50%.

Media Market Concentration

This indicator aims to assess the horizontal concentration in the media market. Concentration is measured by using the Top4 owners. The Top 4 owners are obtained by summing the market shares of the major 4 owners within each market. 

Since financial information on market share is not available in Mongolia this indicator could not be assessed. Only three out of 12 print media, four out of six radio stations, two out of 11 TV channels, and two out of ten news websites gave at least some financial information on their companies, if so mostly on advertisement revenues. (See Companies)  

In accordance with the MOM methodology if the country presents data on audience, but not on revenues/market share: the market share data is excluded from the analysis, i.e. the findings are based on the audience data alone and the revenue data are considered optional.

Indicator Media Market Concentration – No Data

Regulatory Safeguards: Media Ownership Concentration

This indicator assesses the existence and effective implementation of regulatory safeguards (sector-specific and/or competition law) against a high horizontal concentration of ownership and / or control in the different media. 

Results: The Constitution of Mongolia and the Civil Law do not in any way address the issue of media concentration. The Competition law adopted in 2010 and amended in 2015 does not specifically address concentration or monopoly issues in the media sector. Thus, the Competition law does not specifically assign the CRC (which is in charge for licensing and regulating the broadcasting sector) to regulate dominating or monopoly activities in the sector.

However, in March 2016 the CRC approved the “Methodology for defining natural monopoly or dominating enterprises”. Enterprises identified as “dominant” or “monopolistic”, shall, in accordance with the Competition Law submit an application to the Authority for Fair Competition and Consumer Protection (AFCCP) in the case of restructuring through consolidation and merger, purchasing more than 20 percent of common stock and more than 15 percent of preferred stock from  a competitive company which sells similar products or consolidating and merging with a related party. The AFCCP shall draw permitted or refused conclusion within 30 days after receipt of application. A refused conclusion can be drawn if the Authority decides that the restructuring of the respective enterprise will create conditions of restricting competition.

The CRC assessed and named following enterprises as natural monopoly companies:
-  DDish TV LLC in the multichannel television and radio satellite transmission service sector; 
- National Network of Radio and Television (State enterprise) in the radio and television terrestrial transmission service sector
- Sansar Cable TV in the cable TV operator sector
- Mongol Shuudan LLC with state shares in the postal network service sector
- Gemnet LLC in the Internet wholesale service sector.

As of October 2016, no restructuring applications were submitted to the AFCCP by above named companies.

Due to absence of any laws specifically addressing media concentration, there is no legal definition of what constitutes concentration in the media sector. The Competition Law defines market concentration as ‘the share of products sold by an enterprise solely and with others, or by related parties”. However, it does not define how high this share can be in order to reach the level of „concentration.”

Even though there are no laws that specifically address media concentration, the regulations described above, specifically the Competition law and the CRC’s regulations, cover distribution networks, broadcast and online media only. Ownership and concentration of print media remains unaddressed.

Neither the general Procedures for granting licenses in the communications sector, nor other regulations defining the terms and conditions for granting permissions in the radio, television or online news media sectors contain provisions that aim to prevent media monopolies.

In summary, regulatory safeguards specifically on media market concentration do not exist in Mongolia. Likewise a high level of horizontal concentration of ownership and/or control in each media sector cannot be prevented via merger control/competition rules that take into account the specificities of the media sector. (See Context Law)

Therefore, this indicator  is assessed High Risk.  

Tables Regulatory safeguards against high concentration of ownership and/or control in media (horizontal) Legal Assessment (english)(mongolian)

Cross-media Ownership Concentration

This indicator aims to assess the concentration of ownership in the different sectors of the media industry (cross-media). Concentration is measured by using the Top 8 companies. In order to measure this indicator top 8 companies are identified with the highest revenue across all media sectors (TV, Radio, Print, and Internet). The ratio is calculated between the TOP 8 revenues and the entire revenue market across media sectors.
In case when market share is not available cross media ownership is calculated on the basis of audience shares. As such, the results presented are not an indicator for economic strength in different media sectors but rather for the potential influence on public opinion when considering all media types.

Results:
Information on financial data of media companies and thus on market shares is not available in Mongolia; therefore the assessment must be based on audience data.

In Mongolia in-depth audience surveys are only available for the TV market.
For print media the self-declared circulation numbers of the Press Institutes “Mongolia Media Today 2016” can be used.
The ranking of radio and online news media in the Press Institutes report is based on qualitative opinion polls / interviews and reflects “popularity” which does not necessarily translates to audience share.
So the data base for calculation cross-media ownership concentration is not very solid.

Nevertheless, the MOM team looked into the audience shares of the biggest companies in each sector. Given the small population and market of Mongolia we only looked at the top four companies in each sector:

In the TV market the most important companies by audience share are:

biggest owners (company or group) in TV sector

sum of audience share of media outlets by company

MNB (Public Service Broadcaster)

18,1 %

Mongol HD TV / Company Gatsuurt

5,5 %

UBS / Ulaanbaatar Television LLC

3,4 %

TV9 / Media Holding LLC

3,3 %

TOTAL

30,3 %

Of the biggest TV owner companies only Media Holding also owns a top print media that is Zuuny Medee newspaper (C-3007).
The Public Service Broadcaster MNB also “owns” the top radio station.

For print media the most important companies by circulation share are:

biggest owners (company or group) in PRINT sector

sum of circulation share of media outlets by company

Udriin Sonin / Udrin Medee Media House

24,9 %

Unoodor / Mongol News Group

15,8 %

Zuunii Medee / Zasgiin Medee LLC

12,0 %

Undesnii Shuudan / Undesnii Shuudan NGO

11,3 %

TOTAL

64,0 %

Of the most important print companies two also own a top TV channel: Zasgiin Medee LLC also owns TV9 via the Media Holding LLC. And Mongol News Group also owns JAAG LLC which owns TV channel MN 25.

For the radio market the Press Institutes ranking is based on popularity according to qualitative opinion polls / interviews. The data available allows only an estimation based on data from the Press Institute. According to this estimation the four most popular radio stations and their respective owners are:

biggest owners (company or group) in radio sector

Most popular radio channels

MNB Public Service Broadcaster

Mongolian National Public Radio 106

Shine Mongol Radio Dolgion LLC

Shine Mongol Radio 101.7

Salkhi Entertainment LLC

Family Radio 104.5

Ekh Elgen Nutag Company

Elgen Nutag FM 96.9

TOTAL

 Estimated 36 % audience share

Of the most important radio companies only the Public Service Broadcaster MNB also “owns” a top TV channel.

For Online News Websites the Press Institutes ranking is based on popularity according to qualitative opinion polls and the percentage of people that used a particular news website “Today / Yesterday”. (See D-1) The data available allows only an estimation based on data from the Press Institute. According to this estimation the four most popular news websites and their respective owners are:

biggest owners (company or group) in Online News sector

Popularity / share of people that used the website “today / yesterday”

Gogo.mn / Mongol Content LLC

18 %

News.mn / News Agency LLC

18 %

Ollo.mn / Ollo LLC

9 %

Ikon.mn / Benecraft LLC

7 %

TOTAL

52 %

Of the most important news website owners none also owns another MOM top media.

So none of the major owners have significant presence in all sectors of media, few are present in two media sectors. These results are not indicators for economic strength but rather indicators for the potential influence on public opinion when considering all media types.

MOM indicator definition ranks the concentration of ownership in the different sectors of the media industry (cross-media) as low, if the major 8 owners have an audience share below 50% across the different media sectors.

So the cross-media concentration of ownership is assessed as Low.

Regulatory Safeguards: Cross-media Ownership Concentration

This indicator aims to assess the existence and effective implementation of regulatory safeguards (sector-specific and/or competition law) against a high degree of cross-ownership between media types (press, TV, radio, internet). Given the diversity of thresholds or limits that exist among different countries with regard to ownership and/or control, 'high' should be assessed according to the standards of the specific country and in the light of the thresholds or limits imposed by domestic laws.

Cross-Media ownership legal regulation does not exist in Mongolia. As a result, there is no authority monitoring cross-media ownership. In addition, effective merger control in Mongolia’s media market is missing, as it is mentioned in the comments to Indicator 3: Regulatory Safeguards Ownership Concentration horizontal.

So this indicator is assessed as High Risk for media pluralism in Mongolia.

Table Regulatory safeguards against high degree of cross-ownership
See Legal Assessment (english)(mongolian)

Ownership Transparency

This indicator assesses the existence and effective implementation of transparency and disclosure provisions with regard to media ownership and/or control.

Given the fact, that print media and online news media only need to be registered but are not obliged to state the owner or shares in the company (see Indicator 7 and Context Law) in particular print media owners were very difficult to assess. Not one print media is actively transparent, and for 8 out of 12 print media ownership data is unavailable. For online news media at least one out of 10 is actively transparent but still for 5 out of 10 investigated news websites data is unavailable.   

Only for TV and radio media the government appointed regulatory commission CRC demands transparency of license owners. However, it requires certain efforts to find ownership information from the CRC website. It needs advanced research skills and thus is not made easy for the general public to access. And as of October 2016 the CRC did not take any measures with regard to non-fulfilment of ownership disclosure requirements. (See Context Law)

In principal, MOM assed the level of transparency in borderline cases rather positive, for example the assessment “Passive transparency” was also given to media outlets and companies that needed to be contacted by phone numerous time and also visited in person to provide at least some information.

Results:
In any case, information on political affiliations of media outlets and their owners can only be found through research. The CRC transparency law does not oblige companies to describe interests of their related parties, i.e. family members, or political affiliations.

Almost always, members of the political party governing at a time were involved in new registration or take over or sale of media outlets. The details of such sales are generally not available publicly.

In fact, 29 out of a total of 39 investigated media outlets have political affiliations through their founders and / or owners.

Especially, the traditional media print and TV were founded and / or are still owned by people with political affiliations: All print media except one, Uls Turiin Toim newspaper owned by NShM LLC, have political affiliations in their records. Eleven out of 12 investigated print outlets are 91, 67 %.

Likewise, all but one TV station were founded and / or are still owned by people with political affiliations, the exception being Mongol HD TV owned by Gatsuurt Company Group. 10 out of 11 TV stations investigated are 90, 91 %.

Only radio breaks at least even, with 3 out of 6 stations having no political affiliations. The ones without political influences are: Family Radio 104.5 owned by Salkhi Entertainment LLC; Elgen Nutag FM 96.9 owned by Ekh Elgen Nutag LLC; and Arga Bileg 95.7 owned by Children Future Culture Education Foundation. 3 out of 6 investigated stations are 50 %.

But even the majority of new media is not truly independent: 7 out of 10 news websites investigated by MOM have political affiliations with their founder and / or their owners. For example the technically avant-garde news website itoim.mn, whose co-founder and co-owner is head of the communication department of Parliament. The independent news websites are: ikon.mn owned by Benecraft LLC; eagle.mn owned via a daughter company by Mongol Mass Media Group; and shuud.mn owned by Interactive Media LLC. So 70 % of websites have political affiliations in one form or another.   

Results for the most crucial media ownership transparency are: For 33 media outlets and owners (out of a total of 73) “Data is Unavailable” (45, 21 percent), though the professional MOM research team in quite a lot of cases managed to get some information from other than official sources.

In sum, out of 39 media outlets these were rated:
“Active Transparency”: 4 media outlets (none print (0 percent), 2 TV (5,13 percent), 1 radio (2,56 percent), 1 news website (2,56 percent)
= total 10, 26 percent
“Passive Transparency”: 18 media outlets (4 print (10,26 percent), 5 TV (12,82 percent), 5 radio (12,82 percent), 4 news websites (10,26 percent)
=  46,15  percent
“Data Unavailable”: 17 media outlets (8 print, 4 TV, none radio, 5 news websites)
=  total 43,59 percent

In sum, out of 34 media owner companies these were rated:
“Active Transparency”: 3 = 8, 82 percent
Passive Transparency”: 15 = 44, 12 percent
Data Unavailable”: 16 = 47, 06 percent

So, out of a total of 73 investigated media outlets and owners for 33 ownership data is unavailable, that is 45, 21 percent.

Thus, with a very narrow margin the Risk to Ownership Transparency is for media outlets as well as for media owners assessed as Medium.

Criteria:

LOW (1)

MEDIUM (2)

HIGH (3)

TRANSPARENCY

6.1

How do you assess the transparency and accessibility of data about media ownership?

Data on media owners as well as their political affiliations is publicly available and transparent.
(Active Transparency)

Data of media owners and their political affiliations are disclosed based on investigations of journalists and media activists or upon request.
(Passive Transparency, Data Publicly Available)

Data on ownership of media companies are not easily accessible by the public and investigative journalists or activists are not successful in disclosing these data.
(Data Unavailable, Active Disguise)

Code if that applies to >75 % of the sample.

Code if that applies to >50% of the sample.

Code if data is available for < 50% of the sample.

Regulatory Safeguards: Ownership Transparency

This indicator aims to assess the existence and effective implementation of transparency and disclosure provisions with regard to media ownership and/or control. 

Results:
In Mongolia the print media do not have to state their owners, shares in the company or media market and the size of income according to the Law on registration of legal entities. More specific laws that would oblige print media companies to disclose information about their ownership structures don’t exist.

Likewise, online news media only need to be registered with the government appointed “Communications Regulatory Committee” (CRC), but there are no ownership disclosure requirements for these media, according to the General terms and requirements for digital content service.

Only for TV, radio and (general) internet media the “General Terms and Conditions of Broadcasting Regulation” approved by the CRC demands transparency of license owners, “in order to ensure independence, openness and responsibility of broadcasting.” According to this rule, license holders are obliged to submit to the CRC a written statement with names and ownership shares of owners and investors, address and contact information of license holders, management structure, names and citizenship of executive staff.

As of October 2016 the CRC website listed the names of companies, founders and executive staff of 16 national broadcasters, 25 FM radios covering Ulaanbaatar, 73 local televisions and 56 cable operators. Even though the General Terms require disclosure of ownership shares, this information is not published on the CRC’s website. Citizens can freely access the CRC’s website but the above mentioned list is published on the page for license holders (and not on the page designed for citizens) and it requires certain efforts to find ownership information from the website.

In January 2015 the Registration Law was revised and now all information relating to state registration, save for that which is confidential, is to be made publicly available on the official website of the Legal Entity Registration Office. However, searches require the unique registration numbers of the relevant legal entities in order to obtain a limited amount of information. Detailed information, such as information in relation to company shareholders and copies of company charters, is not available electronically.

In case of non-fulfilment or violation of the General Terms the CRC has the right to assign tasks to eliminate violations or meet standards, take administrative measures, reprimand, hold back or suspend licenses. As of October 2016 the CRC did not take any measures with regard to non-fulfilment of ownership disclosure requirements. (See Context Law)

Mongolia’s limited legal ownership transparency is further reduced by two practical factors:
1) Data on the ultimate beneficiaries of many legal media entities is in fact not published in the CRC registry;
2) When a media outlet is a separate legal entity or a branch of another legal entity like a company holding the ultimate owner / beneficiary would not be disclosed due to the absence of such an obligation (loophole).

Furthermore, Mongolia’s limited regulatory safeguards are overshadowed by timid implementation of regulations. In addition, online news media with its growing importance is not regulated at all in terms of ownership disclosure – which can lead to a high risk to media pluralism.

The Regulatory Safeguard Score is 18 “No” out of 24 indicators that are 75 %.

So the indicator Regulatory safeguards Ownership Transparency is assessed as HIGH Risk.

Table Regulatory safeguards for transparency of ownership and/or control see Legal assessment, (english), (mongolian).

(Political) Control Over Media Outlets and Distribution Networks

This indicator assesses the risk of political affiliations and control over media and distribution networks. It examines the transparency of data about the political affiliations of media owners, the proportion of specific political affiliation of media owners across the media market in terms of audience share.  It also assesses the level of discrimination by politically affiliated media distribution networks.
Leading distribution network is defined as a network covering more than 15% of the national market. 
Political affiliation means that the network belongs to a party, a partisan group, a party leader or a clearly partisan person.
Discriminatory actions include unfavourable pricing and posing barriers to media accessing the distribution channel.

Results:
MOM Mongolia does not give specified calculations, just highlights the findings / assessment in the respective aspects. Summary:

The regulatory safeguards against political control over media and distribution networks ownership are assessed High Risk.
The politication of media outlets is assed as high for Print, TV and online news. Only for radio politication is with a very narrow margin medium risk to media pluralism.
The level of (political) control or at least influence over distribution networks is assessed as a high risk to media pluralism.

Details:

In Mongolia, there are no Regulatory Safeguards against political control over media and distribution networks ownership. (See Indicator 7 and Context Law

Thus, the regulatory safeguards against political control over media and distribution networks ownership are assessed High Risk.

Regarding the overall level of political control over or at least influence on media outlets information can only be found through research. The CRC transparency law does not oblige companies to describe interests of their related parties, i.e. family members, or political affiliations. Almost always, members of the political party governing at a time were involved in new registration or take over or sale of media outlets. The details of such sales are generally not available publicly.

The vast majority of media outlets investigated by MOM have direct or indirect links to a political party or to politicians. In fact, 29 out of a total of 39 investigated media outlets have political affiliations through their founders and / or owners, that are 74, 36 %.

Especially, the traditional media print and TV were founded and / or are still owned by people with political affiliations: All print media except one, Uls Turiin Toim newspaper owned by NShM LLC, have political affiliations in their records. Eleven out of 12 investigated print outlets are 91, 67 %. 

Likewise, all but one TV station were founded and / or are still owned by people with political affiliations, the exception being Mongol HD TV owned by Gatsuurt Company Group. 10 out of 11 TV stations investigated are 90, 91 %.

Only radio breaks at least even, with 3 out of 6 stations having no political affiliations. The ones without political influences are: Family Radio 104.5 owned by Salkhi Entertainment LLC; Elgen Nutag FM 96.9 owned by Ekh Elgen Nutag LLC; and Arga Bileg 95.7 owned by Children Future Culture Education Foundation. 3 out of 6 investigated radio stations are 50 %.

Also the majority of new media is not truly independent: 7 out of 10 news websites investigated by MOM have political affiliations with their founder and / or their owners. For example the technically avant-garde news website itoim.mn (M-3118), whose co-founder and co-owner is head of the communication department of Parliament. The independent news websites are: ikon.mn owned by Benecraft LLC; eagle.mn owned via adaughter company by Mongol Mass Media Group; and shuud.mn owned by Interactive Media LLC. So 70 % of websites have political affiliations in one form or another.  

Details and further information see indicator 6, Context “Politics & Friends”, Context “Big Business & Washed News”.

Thus, the politication of media outlets is assed as high for Print, TV and online news. Only for radio politication is with a very narrow margin medium risk to media pluralism.

Regarding the level of political control over licensing and registration authorities, in Mongolia, the head and members of the regulatory commission CRC are appointed by the prime minister for 6 years. CRC is the only authority for regulation and supervision and has sanctioning and enforcement powers. So all regulatory bodies are part of the government structure and the decisions made by these bodies can directly be influenced by the government. Via nominating the CRC executive staff, the political party in power will have a strong influence over the licensing process.

A recent example is the case of the news website Amjilt.com. In July 2014, Amjilt.com published a story about a prime minister owning a tourist camp which is shedding sewage into Tuul river. The story was documented by a photo taken from the spot. The CRC accused the website of ‘violating the law’ and registered it on its black list, closing access to the website from Mongolia. The website appealed to court and in November 2015 the website was re-opened. However, decision making processes concerning licensing are in-transparent and lack public participation. Information is available on the CRC’s website only once the decisions are already made.

However, the Competition law and the CRC’s regulations contain some provisions to measure dominating positions on the market and restrict mergers and consolidations that might negatively affect conditions for competition. These provisions cover distribution networks, broadcast and online media only. Ownership and concentration of print media remains unaddressed.

As for TV and Radio Distribution, the government allocates about US$1.2 million annually to support satellite distribution for ten channels in order to provide quality and sustainable services to rural populations. The service is operated by the private company DDish, which holds a monopoly on satellite broadcasting in Mongolia (D-9). Furthermore, Article 4 of the Law on Radio Waves states that “the State shall, as an owner of radio wave, issue the right to use radio frequency and radio frequency band to other persons with the terms and conditions specified in his Law.” The organization entitled to allocate radio frequencies on the behalf of the state is the CRC.

The newspaper distribution market is almost monopolized by the Mongol Post Company, a government-owned enterprise. Some private companies such as Ulaanbaatar Post, Skypost and Tugeemel Shuurkhai Post also provide subscription and delivery services.

In Mongolia, 66 Internet Service Providers are in the market, the biggest ones being Univision, Sky Net, Mobi Net. Nothing is known about possible political affiliations of those.  

So the level of (political) control or at least influence over distribution networks is assessed as a high risk to media pluralism.

Details and further information see Indicator 3 and Context Law.

(Political) Control Over Media Funding

This indicator assesses the influence of the state on the functioning of the media market, focusing particularly on the risk of discrimination in the distribution of state advertisements. The discrimination can be reflected in favouritism towards political parties or affiliates of political parties in the government, or in penalisation of media criticising the government.
State advertising is understood as any advertising paid by governments (national, regional, local) and state-owned institutions and companies.

In Mongolia, there are no rules as to how to distribute funds allocated for advertisement and public communication. Information about state advertising is not public. Thus, there is no transparency on how much state advertising individual media outlets receive.

Public communication specialists at government organizations state that they use their ‘common sense’ to judge which media outlet might be ‘the biggest one” or choose the cheapest one, or the executive management simply orders to use the media outlet of his/her friend or affiliated person. There are no practices of public tender announcement for selection of channels for state advertisement. (See Context Law and Context Media Market)

Even though there are no legal grounds for direct state interference into editorial decision making, government organizations use advertisement distribution as a tool to influence media content by concluding “contracts of collaboration” to restrict criticism or negative coverage.  Systems to monitor allocation of state advertisement do not exist.

Voluntarily, in answering the MOM questionnaire, 3 out of 12 print outlets gave information on their advertising revenue from public and private sources. Also 4 out of 6 radio stations, 2 out of 11 TV channels, and 2 out of 10 online news websites. Also 10 out of 34 companies gave information on their advertising revenue, but this was entirely voluntarily. (See Media and Companies

Because there are no rules regarding distribution of state advertising to media outlets the risk of political control over media funding is assessed HIGH.  

(Political) Control Over News Agencies

This indicator assesses the range and independence of competing news agencies, including the assessment of the level of state ownership and level of independence of state owned news agencies.

Results:
In Mongolia there is only one company that calls itself news agency but does not function like a professional news agency. Montsame agency is still state-runned and its director is appointed by the Prime Minister, even though the 1998 Media Freedom Law states that the agency shall be transformed into a public service entity and the State should not own media.

Under socialist rule Montsame was the only official source of information. Now, Montsame Agency publishes 6 weekly print newspapers in foreign languages like English, Russian, Mandarin and Japanese. In addition, they claimed in a telephone interview to have some subscribers, mostly online media, for their news, but did not specify. No market share of Montsame agency is available, but it is certainly small.

Both, the non-existence of a professional news agency as well as the obviously small influence on opinion building that the so called news agency has, do not pose a threat to media pluralism. So, this indicator is assessed as Low Risk. 

Several media outlets being interviewed agreed that the absence of a professional news agency is a lack of professionalism and, in addition, “makes covering Mongolian news very expansive for all media because every outlet has to do its own research”, commented one chief editor. This also opens doors to copy and paste even more press releases and one party statements being disseminated to Mongolian media.

  • Project by
    Press Institute of Mongolia
  •  
    Reporters without borders
  • Funded by
    BMZ