Media pluralism


Emerging challenges to media pluralism in the digital era
Melinda Rucz

Information is abundant in the digital era as online platforms enable access to an unprecedented amount of media content. While this should be good news from the perspective of information diversity, the digital transformation has brought its own challenges to media pluralism. This blogpost examines two new threats to media pluralism in the digital era: the adverse effects of algorithmic content curation practices of online platforms on the diversity of media content that individuals engage with; and the impact of the dominance of online platforms on the plurality of the media environment. After introducing media pluralism and the evolving media environment, the blogpost analyses these two areas of digital challenges and explores how they transform traditional policy approaches to media pluralism.

Media pluralism as an enduring hallmark of democracy

Media pluralism is vital for the health of democratic societies. A pluralist media environment facilitates the development of well-considered opinions by ensuring “the availability and accessibility of diverse information and views, on the basis of which individuals can form and express their opinions”.[i] A pluralistic media landscape prevents a dominant opinion-forming power from exerting a disproportionate influence on public discourse and stimulates the exchange of a variety of viewpoints. Furthermore, the promotion of media pluralism holds particular relevance for minorities. A media environment that provides expressive opportunities for all sectors of society helps to articulate, explore and sustain diverse cultural identities. By enabling exchange of cultural experiences and perspectives, a plural media environment fosters intercultural understanding, contributing to social cohesion.

Media pluralism, thus, allows discovery and discussion of a variety of potentially competing viewpoints, narratives and information sources, which is considered a precondition to best participate in democratic processes. Media pluralism is a multi-dimensional concept that can manifest in various forms. A traditional approach is to distinguish between its internal and external dimensions. Internal pluralism relates to the diversity of accessible content and the variety of viewpoints reflected within a single media outlet. This dimension of pluralism has particular relevance in the context of public service media, which have a mission to provide content for a wide range of political, social and cultural interests. External pluralism refers to the plurality of the entire media market and manifests through the diversity of available information sources across different media. External pluralism is usually assessed by the level of concentration of media ownership on a media landscape.

In Europe, media pluralism is recognised as a corollary to the right to freedom of expression. In its case law, the European Court of Human Rights (ECtHR) held that pluralism is a prerequisite to democracy. States, as ultimate guarantors of pluralism, have a positive obligation to set up an appropriate legislative and administrative framework to safeguard media pluralism. Given the complex, multi-faceted nature of the concept of media pluralism, the ECtHR recognises that a variety of strategies could be deployed to ensure pluralism. Its internal and external dimensions cannot be considered in isolation, as both are needed to achieve “diversity of overall programme content, reflecting as far as possible the variety of opinions encountered in the society at which the programmes are aimed”.[ii]

While the ECtHR’s jurisprudence on media pluralism mostly relates to traditional media, the standard-setting work of the Council of Europe increasingly engages with the changing media landscape. The Recommendation on Media Pluralism and Transparency of Media Ownership, adopted by the Committee of Ministers in 2018,  advocates for renewed approaches to safeguard media pluralism in the digital age. The European Union also demonstrates increasing attention to media pluralism, for instance through co-funding initiatives such as the Media Pluralism Monitor. In the European Commission’s annual rule of law reports, media pluralism is among the central focuses, demonstrating that the plurality of the media is seen as a key indicator of the wellbeing of European democracies.

Recommendation CM/Rec(2018)1 on Media Pluralism and Transparency of Media Ownership
This standard-setting document operationalises key principles relating to media pluralism and puts forward a comprehensive set of recommendations that State Parties to the Council of Europe should implement in order to protect and promote a pluralist media environment. Key focuses of the recommendation include:

  • A favourable environment for freedom of expression and media freedom: national legal and policy framework to safeguard independence of media and media regulatory authorities;
  • Media pluralism and diversity of media content: availability of a variety of media types, exposure to diverse media content online, independence of public service media, support measures for media;
  • Regulation of media ownership: enforcement of competition law, monitoring media concentration;
  • Transparency of media ownership, organisation and financing: regime of transparency, disclosure obligations for the media, transparency of financing;
  • Media literacy and education: enable the public to access, understand, critically analyse, evaluate, use and create content, digital skills, media literacy education as part of lifelong learning cycles.

Media Pluralism Monitor
The MPM is an instrument co-founded by the European Union that measures levels of risk to media pluralism in European countries. Its results are feeding into various EU initiatives, including the European Democracy Action Plan, the annual rule of law reports, the European Commission Recommendation on the Safety of Journalists, and various legislative proposals.  

The MPM publishes annual reports, analysing risks to media pluralism in four main areas: Fundamental Protection, Market Plurality, Political Independence, and Social Inclusiveness. Since 2020, the MPM has been updated to include more focus on the impacts of the digital transformation on media pluralism within all four areas of assessment.

Shifting media environment

While media pluralism remains a fundamental policy goal, the media environment has undergone seismic shifts since the advent of the Internet (to learn more about this transformation, check out this infographic. The media environment has turned increasingly mobile, digital and platform-dominated. As consistently documented by the Reuters Institute’s annual Digital News Report, social media platforms serve as the primary gateway to news for a growing part of the population. On online platforms, information is plentiful and the communication processes are interactive, participatory and instantaneous. The dissemination of content in the online realm is largely mediated by automated processes. In order to organise the vast scale of information, online platforms curate content with the use of algorithmic recommender systems which seek to optimise content dissemination by delivering personalised content based on extensive analysis of user data (you can learn more about this in this video).

As debate on societal affairs increasingly takes place in the online arena, online platforms have become de facto gatekeepers to public debate. While this opens up unprecedented expressive opportunities for the public, it also undermines the privileged position and financial stability of traditional media. This platform-mediated and information-saturated media environment is fundamentally different from the press- and broadcast-dominated traditional media landscape, raising new challenges to media pluralism.

Algorithmic curation of content and its impact on media pluralism

As recommender systems seek to deliver content that aligns with the pre-existing views of individuals, the opportunities for being served with a balanced menu of news decrease. With abundant content, people tend to navigate towards information that confirms their beliefs. Algorithmic recommenders amplify this by reducing the prominence of information that does not fit the digital profile of individuals. The dissemination of media content based on personalised recommender systems may lead to ‘filter bubbles’, isolating individuals from information that they have not expressed interest in. Personalised news diets narrow the spectrum of views that individuals use to develop opinions on public matters, which may adversely affect informed democratic participation. For instance, according to some researchers the ‘filter bubble’ effect may have contributed to perceived failures of democratic processes such as the presidential election of Donald Trump. The gravity of the filter bubble issue remains contested, however, as empirical research has failed to prove its significance.

Algorithmic content curation may also contribute to polarisation of opinion. As personalised recommenders present a “distorted picture of the climate of opinion”, individuals may become progressively more entrenched in their worldviews. Testifying to this polarising potential, algorithmic personalisation of content has been shown to amplify extremist and radical content. As the public is increasingly exposed to personalised universes of information, the public sphere may become fragmented. There is, furthermore, a concern that algorithmic distribution of content can facilitate the spread of mis- and disinformation. For example, a study conducted by advocacy group Avaaz found that Facebook’s algorithmic recommender system significantly accelerated the spreading of Covid-19 misinformation (if you want to dive deeper into disinformation issues, check out this blogpost, videoscript and infographic). Moreover, there are growing concerns that algorithmic decision making perpetuates bias and discrimination against marginalised groups in society. This way, algorithmic content curation may amplify already dominant voices in public debate and further marginalise minority viewpoints.

As these examples illustrate, algorithmic curation of content adversely affects media pluralism on various levels. In the platform-dominated, information-abundant media ecosystem, an emerging concern for media pluralism is how to facilitate exposure to diverse content. The Council of Europe Committee of Ministers’ Recommendation on Media Pluralism and Transparency of Media Ownership reflects on this emerging dimension of media pluralism and calls on states to “enhance users’ effective exposure to the broadest possible diversity of media content”. In particular, the prominence and discoverability of public interest content become key concerns for media pluralism policy in the digital age. For instance, the Tallinn Guidelines published by the OSCE High Commissioner on National Minorities suggests that in order to foster minority participation in public debate, the “availability, accessibility, prominence and findability of content produced by national minorities” needs to be enhanced.

Dominance of online platforms and its impact on media pluralism

The dominance of online platforms in the information industry has had a disruptive impact on the plurality of the media landscape. A small number of platforms, commonly labelled as GAFAM (Google, Amazon, Facebook, Apple, Microsoft), have established effective dominance in digital markets. Strong network effects, which imply that the value of a good or a service increases as more people use it, have fuelled a “self-reinforcing feedback loop”, cementing the dominant position of incumbent digital platforms and facilitating ‘winner takes all’ dynamics. As some of these tech giants, most importantly Google and Facebook, play a prominent role in the dissemination of information, their significant market power raises pertinent questions from the perspective of media pluralism. By holding a dominant position in the distribution of media content, online platforms have the ability to shape societal debate and steer public narratives. The fact that this “enormous opinion power” is concentrated in only a handful of giant online platforms is a serious concern for media pluralism and ultimately for democracy.

The rise and dominance of online platforms in the media landscape also put the viability of traditional media under pressure. Due to plentiful popular digital alternatives, sales of print media have plummeted. In addition, advertising revenues have largely shifted from traditional media to online platforms. Consequently, the financial sustainability of traditional media has seen exponential deterioration, which leads to weakened abilities to produce high quality, diverse news. In order to adapt to the logic of online platforms, media outlets have an incentive to produce content that enhances user engagement. In the resulting “clickbait culture”, sensationalism is more financially rewarding than nuanced, quality, diverse content, as asserted by the Council of Europe’s Committee of Ministers Declaration on financial sustainability of quality journalism. Challenges to the sustainability of news media also lead to growing concentration in media ownership. As the Council of Europe’s Committee of Ministers emphasised in its Recommendation  on quality journalism in the digital age, this “trend toward greater concentration and convergence in the news media sector and across national markets threatens the diversity of sources and viewpoints”.[iii]

As a result, the dominant role of a few online platforms in communication processes may have adverse effects on both external pluralism (diversity of information sources) and internal pluralism (diversity of available content). Recognising this issue as an emerging threat to a pluralistic media environment, the Media Pluralism Monitor has been measuring online platform concentration as a key indicator of media pluralism since 2020. In light of digital transitions, a central question for media pluralism-related initiatives is how to devise sustainable business models for the production of diverse media content. In order for pluralistic media to thrive in the digital era, special support mechanisms may be needed for regional, local and minority media that have been the hardest hit by the economic downturn elicited by digitalisation. Renewed approaches to competition law enforcement may also be needed to protect against abuses of dominant position, media concentration and other anti-competitive behaviour of online gatekeepers.

Digital dominance in the MPM 2022
In its 2022 report, the MPM found that the indicator ‘Online platforms concentration and competition enforcement’ posed a high risk to media pluralism on average, with 25 examined countries scoring a high risk and 7 countries scoring a medium risk. The main contributing dynamics, according to the MPM’s analysis, are:

– heavy reliance by the public on digital platforms for access to news;
– concentration of digital intermediaries;
– difficulties of competition enforcement in digital markets;
– dominance of a few players in the online advertising market.


As online platforms turn into the primary gateway to media content, their operations have far-reaching implications for the types and variety of information that serve as input for public debate. Media pluralism remains a cornerstone of democracy but the shifting media environment sparks questions about how public debate online can be genuinely pluralistic, serving and reflecting society in its entirety and fostering meaningful exchange of a variety of social, cultural and political viewpoints. Algorithmic curation of content and the dominance of online platforms raise new challenges to media pluralism that call for new policy approaches. Indeed, as the Council of Europe’s Committee of Ministers points out, “fresh appraisals of existing approaches” and “new policy responses” are needed so that media pluralism policy remains resilient to the digital transformation and can effectively safeguard a vibrant and diverse public sphere. 

[i] Committee of Ministers, Council of Europe, ‘Recommendation CM/Rec(2018)1 of the Committee of Ministers to member States on media pluralism and transparency of media ownership’ (7 March 2018), para. 1.
[ii] Nit S.R.L. v. The Republic of Moldova App. No. 28470/12 (ECtHR, 5 April 2022), para. 190.
[iii] Committee of Ministers, Council of Europe, ‘Recommendation CM/Rec(2022)4 of the Committee of Ministers to member States on promoting a favourable environment for quality journalism in the digital age’ (17 March 2022), para. 12.