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Frequently Asked Questions



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 Mongolia, RSF worked with Press Institute of Mongolia. The project was funded by the German Federal Ministry of Economic Development and Cooperation (BMZ).

3. Where can I download this report?

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”.

4. 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.

5. 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.

6. How is data collected and validated?

a) Official data sources, and/or sources with a high level of reliability and trust are prioritised.

b) In cases when information was not publicly available, it was directly requested from media companies, political representatives and research institutes.

c) In order to guarantee and verify the objective evaluation, MOM works with an advisory group that provides comments and consultations throughout the research process. It is composed of national specialists with a substantial knowledge and experience in media and communications. MOM advisers in Mongolia included Bat-Erdene.G, Mongol TV, Vice director of Strategic and Planning division, Lhagva.E, Chief editor Mongol TV and member of Media Council Mongolia, Enhbayar, Head of the regulation policy department at the regulatory committee CRC, and Tserenjav.D, director of the NGO “Transparency”.

d) All decisions on how data is selected, which sources are used - and which are not - are clearly indicated on the website of MOM Mongolia for each media outlet, each owner and also generally under the FAQs for Mongolia.

e)  All sources are thoroughly documented and archived. Most of them can be found in the library. Other documents are available upon request.

7. 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, and Online). 

The media were selected according to the following criteria:

MOM focuses on media with the highest reach, measured by audience / circulation share. The selection for the Monitor is based on recent media consumption surveys and audience research studies.

For MOM we select media with socio-political and economic content that has impact on public opinion. Content should have a national focus; however, world-wide broadcasting news outlets are excluded, as they do not target the national audience specifically (e.g. Al Jazeera). Media with specific thematic focus (music, sport), social networks, search engines and advertisement are also excluded. 

8. How are the media outlets selected?

The media were selected according to the following criteria:

MOM focuses on media with the highest reach, measured by audience share. The selection for the Monitor is usually based on recent media consumption surveys and audience research studies. But in Mongolia in-depth audience surveys are only available for the TV market, so we used this data compiled by the private company Maxima LLCC. For print media the circulation numbers compiled by the Press Institutes yearly report “Mongolian Media Today 2016” were used for ranking. For radio and online news media the same source was used this time based on PIM opinion polls on popularity and most used access to information.  

9. Why Mongolia?

MOM was developed as a generic methodology which can be universally applied. Although media concentration trends are observable worldwide, implementation and analysis will first take place in developing countries. Besides, the Media Pluralism Monitor delivers complementary results for European member states.

In the selection process, the country ranking in the World Press Freedom Index published by Reporters without Borders is the first important indicator for a problematic relation to media pluralism, media independence and transparency. A low ranking highlights which country being worth looking in depth into the risk of media ownership concentration.

The political context is also a condition for a successful implementation: on the one hand civil society organizations such as our local partners need to be able to operate relatively freely. On the other hand, the media landscape needs to be open to a certain extent: in a country where the state exercises absolute control over media, media ownership research would be irrelevant.

10. Does the MOM only exist for Mongolia?

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.

11. What are the limitations of MOM?

The Mongolian research team was confronted with diverse obstacles at the data-collecting stage to measure media concentration. The most common problems include:

 Audience data is not consistent:  information on audience share is not standardized and there is no obligation to publish those data. It is commercial information that is usually collected by private companies upon request, and sold to media companies that base their advertising rates on it. In small markets like Mongolia it is usually not worthwhile economically to collect the data, so in-depth audience surveys exist only for the TV market. (Read more: How is media selected?

  No economic data: Market concentration based on market share cannot or can only partially be calculated since complete and credible numbers are not publicly available. In Mongolia such information is typically not disclosed and considered a “commercial secret”.

   No legal obligations to make ownership transparent: In Mongolia, print media and online news media have no legal obligations to make their ownership structures known to the public. Consequently, it was most difficult to find out through other sources who own the print media. For TV and radio channels, who are obliged to give ownership information to the official regulatory body CRC, the official data was incomplete and/or outdated.

12. Who do we target?

The data base of MOM in Mongolia

- allows each citizen to get informed on the media system in general and in Mongolia in particular;

- creates a fact base for civil society’s advocacy efforts to further promote public consciousness on media ownership and concentration in Mongolia and possibly give an example to neighboring countries;is a point of reference for consulting competition authorities or governmental bodies when establishing suitable regulatory measures to safeguard media pluralism;

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



13. What happens next?

The database is a snapshot of the current situation in Mongolia, contextualized by historical facts of the country. It is designed with the goal to be updated further by the Press Institute for Mongolia and Mongolian civil society in general.

14. 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. 



Acess Info 

A Spanish NGO that works in the field of media ownership transparency in several European countries.

Article 19

An NGO which works in the field of press freedom. It implements media concentration projects.

Deutsche Welle

The Media Freedom Navigator of Deutsche Welle provides an overview of different media freedom indices.

European Audiovisual Observatory

A database of television and audiovisual services in Europe.

European Journalism Center


The Website provides a summary and analysis of the state of the media in Europe and neighbouring countries.


European University Institute in Florence

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.

Pew Research Center

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.

The Columbia Institute for Tele-Information at Columbia Business School

A research that works with authors from 30 countries in the world about media concentration using a common methodology.

The Institute for Media and Communication Policy

A database of international corporations of the world´s biggest media.


Media Development Indicators - A framework for assessing media development.

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    Press Institute of Mongolia
    Global Media Registry
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