Abstract
Drawing on critical capitalism theory and the social responsibility theory of media, this paper explores the role of the state as a news media owner in contemporary European media systems and the capitalist context. It focuses on accountability and the relationships between the state, state-owned media outlets, and the public. Academic research to date has predominantly examined public service media (PSM) and the dichotomy of private versus public media, thereby overlooking other models of state ownership. The lack of clear regulations on the state's accountability as a media owner outside PSM at the EU level, along with uncertainties in national regulatory frameworks (such as those seen in Slovenia, and the recent reinstatement of state ownership of media in Serbia) raise concerns about the potential for abuse of power. These issues are particularly relevant in the current context of illiberal and authoritarian tendencies within modern European capitalist societies.
Introduction
In contemporary late-modern capitalism, media ownership has been analysed primarily through the lens of private property, or in the context of public institutions such as public service media (PSM) (e.g. Freedman, 2008; Green, 1995). These discussions typically view the role of the state as either unnecessary, consistent with the ‘laissez-faire’ approach in private media (Gray, 2000), or concerning, reflecting the ‘media capture’ approach in PSM (Dragomir and Söderström, 2021). The recent resurgence of political capitalism and illiberal authoritarian democracies in Europe and the European Union (Vojtěchovská, 2017), however, has re-established the state as a significant political-economic actor, including as a media owner.
Most modern media theories that acknowledge the influential role of the state – such as the theory of media capture (e.g. Mungiu-Pippidi, 2008) – approach state ownership from a predominantly negative perspective. Moreover, many authors on media ownership (e.g. Congdon, 1995; Freedman, 2008; Green, 1995) have largely neglected the potential role of the state as a media owner. Academic research has primarily focused on PSM, particularly public broadcasting, as ‘the most important form of state ownership of media’ (Hallin and Mancini, 2004: 44), even though some state ownership models (see Dragomir and Söderström, 2021) vary significantly from the PSM model. Unlike other types of state-owned media, PSM are bound to serve the public good by a remit and held accountable to this mission by supervisory bodies, which are to guarantee that PSM adhere to their obligations (Holtz-Bacha, 2015: 37). Decisions made by PSM are to be independent both from the state and private corporations (Fuchs, 2021: 19).
Although media ownership in Europe encompasses a variety of forms, including state, public, party, family/private, and corporate ownership (Papathanassopoulos et al., 2023: 58), the recently adopted European Media Freedom Act (European Parliament, 2024) does not provide for the possibility of different media ownership models. Rather, it explicitly assumes that national media environments are solely ‘characterised by a co-existence of public and private media service providers’ (Introductory Statement no. 29).
This article presents conceptual arguments regarding the classification of private versus public media ownership, by addressing the role of the state as a media owner within contemporary European media systems and the capitalist context. It focuses on accountability as reflected in the relationships between the state as a media owner, state-owned media outlets, and the public. The paper argues that the state's role as a media owner should not be considered solely in relation to PSM. Instead, the state should be recognised as an increasingly relevant player with the power to instrumentalise the media it owns. This argument is illustrated by the case of EU candidate country Serbia, where state ownership of media was reinstated in 2023 through amendments to media laws, which now allow the state to own media outlets indirectly. The new laws enabled state-owned telecommunications provider Telekom Srbija to create legal entities that can establish media outlets (CRTA, 2023; Media Ownership Monitor, 2023).
The paper draws on the tradition of critical capitalism theory as a conceptual framework, stemming from the Frankfurt School, particularly regarding its approach to capitalism and the potential of capitalist societies to foster authoritarian tendencies. This is augmented by a broader critical approach to the political economy of communication (e.g. Garnham, 1979; Mosco, 1996; Murdock and Golding, 1973) and critical capitalism theory as applied in media scholarship, which highlights the potential risks posed by state involvement in media systems (e.g. Fuchs, 2020; Pickard, 2019). These critical perspectives are then integrated with social responsibility theory – one of the normative theories of media (Peterson, 1956) – which underscores the importance of responsible media ownership.
State ownership of news media
In recent decades, academic literature has largely classified media as either private or public, with little attention paid to intersections or alternative options. On one side, the pressure of state censorship and media control via regulation, political influence, or financing have been persistent issues. On the other, authors have highlighted the ‘self-contradictory and self-paralyzing tendencies of market-based communications media’ (Keane, 1991: 116) as a result of mechanisms of private ownership and advertisers. The Frankfurt School recognised these mechanisms as the ‘absolute master’, because of the ‘triumph of invested capital’ (Adorno and Horkheimer, 1979: 123).
One perspective from the political economy of communication argues for a ‘critical political-economic analysis of capitalism and commercial media’ (Corrigan et al., 2024: 1–2), pointing to the ‘the exercise of political, and ideological domination through the economic’ (Garnham, 1979: 133). This view suggests that mass media are ‘ideological apparatuses’ (Murdock and Golding, 1973: 203) that should be examined as large-scale commercial enterprises within a capitalist economic system, where there is a tendency for capital accumulation and a political inclination to control the space through which it flows (Mosco, 1996: 200).
Such interaction between the market and the political sphere traps news media between constant threats from both private (advertisers and owners) and political interests (as in the case of PSM). This interplay between media and power, whether commercial or political, has been extensively analysed from various perspectives over the years (e.g. Bagdikian, 1983; Chomsky and Herman, 1988; Hallin and Mancini, 2004). The possibility of news media outlets being neither private nor public, but state-owned under a model other than PSM, has often been overlooked.
Research into state media ownership has predominantly examined PSM and their relationship with the state, particularly in terms of media capture. Iosifidis and Papathanassopoulos (2019) analysed government control over state broadcasting media in Greece, where the country's complex political history led to the formation of a state broadcaster rather than a truly public one. As Dragomir and Aslama Horowitz (2024: 161) note, most PSM across Central and Eastern Europe ‘never managed to shed the legacy of state-controlled media from before 1989’.
Outside studies on captured PSM, state media ownership has been relatively underexplored, and is often considered within the frameworks of public interest (Pigouvian) theory or public choice theory. The former views state media ownership as beneficial because of its potential to address market failures, while the latter contends that it can undermine political and economic freedoms and compromise democracy (e.g. Begoyan, 2009; Djankov et al., 2003).
Advantages and risks of state involvement in news media
Modern critical media approaches acknowledge the potential benefits of state involvement in news media, such as preserving local journalism and curbing the emergence of news deserts (Pickard, 2020). An advantage of state support is ‘the contribution it may make to the economic viability of diverse and pluralistic press’ (Humphreys, 1996: 107). Various state aid schemes for journalism should ideally promote independent journalism in the public interest, though there are doubts about their efficacy (Murschetz, 2020).
The potentially beneficial effects of state involvement are particularly important in the current circumstances, which are marked by the proliferation of information platforms, the decline of the advertising-based funding model, and the economic vulnerability of journalism, where newsrooms that are unprofitable or fail to meet profit expectations are closed down or severely downsized (Waisbord, 2019: 211).
State ownership, however, can also lead to highly problematic and concerning consequences. A study examining media ownership patterns in 97 countries supported public choice theory (Djankov et al., 2003) by demonstrating that the state often seeks to influence or even directly control the media in various ways. In recent years, research has increasingly revealed how illiberal, non-democratic, or authoritarian regimes exhibit these same tendencies within the media sector (Finkel, 2015; Schiffrin, 2017).
Public service versus state media outlets
Media ownership is not classified uniformly. While the division between private and public media is detailed in the European Media Freedom Act (European Parliament, 2024) and frequently examined in academic research, some scholars also define other types of ownership. Hanitzsch and Mellado (2011) list three general categories: private, public, and state ownership. Similarly, Cushion (2017) identifies state, public, and market-driven media models.
In the concept of PSM as ‘a service of the public, by the public, and for the public’ (Splichal, 2007: 255), independence is essential, as it is the principal rationale that justifies the specific status of PSM and minimises the twin influences of state and market (Arriaza Ibarra and Nord, 2014: 72–73). Independent bodies should therefore be established within PSM, ‘to act as a buffer between government and news production’ (Nelson, 2017: 152–153).
In a typology proposed by Dragomir and Söderström (2021), the independent public media model is at one end of a spectrum of seven state and public media models, defined by various degrees of independence. At the other end are state-controlled media. The PSM model is rooted in financial and governance mechanisms that shield these media as much as possible from government interference and other pressures, and allow them an editorial autonomy that is typically protected by codes and regulations, or accountability and oversight instruments (Dragomir and Söderström, 2021: 10). These mechanisms and instruments are what sets PSM apart from other types of state-owned media, and highlights why the private versus public media dichotomy is insufficient.
In other models, the state as a media owner can, both legally and in practice, engage in the political instrumentalisation of the media it owns. This may involve using a media outlet to promote or attack politicians, social movements, or issues of particular interest to the owners (Benson et al., 2018: 276–277). The state's use of its ownership power to instrumentalise the media it owns falls under the category of state media. This category should be included in the classification of private versus public media, where it would make a distinction between public and state media as outlined by the State Media Monitor, the ‘world's state and public media database’ (Media and Journalism Research Center, 2023). In brief: the key distinction between public and state media lies in their approach to accountability.
The accountability of state-owned news media and of the state as a news media owner
Accountability attributed to news media owners generally stems from the normative social responsibility theory of media, and is based on the premise that the media ‘is obliged to be responsible to society for carrying out certain essential functions of mass communication’ (Peterson, 1956: 74). The Hutchins Report provides the foundation for this theory, stating that ‘an overall social responsibility for the quality of press service to the citizen cannot be escaped’ (The Commission on the Freedom of the Press, 1947: 126). This assigns media owners an important social role (Bardoel and D’Haenens, 2004: 6), and holds that media ownership ‘is to be viewed as a kind of public stewardship’ (McQuail, 1984: 90). Although the specific historical context in which it was developed means that the theory originally focused solely on private media owners, the state should bear the same responsibilities when acting as a media owner in contemporary democracies, whether in the context of PSM or other state media models.
Under social responsibility theory, news media should be granted ‘maximum independence’ (McQuail, 1984: 90) to fulfil their responsibilities to the public. While responsibility refers to obligations, accountability to citizens and society as a whole entails mechanisms through which media owners and their outlets are held accountable. Independence at various levels – structural, supervisory, managerial, and editorial – has been highlighted a core governance principle for PSM (e.g. EBU, 2021; Psychogiopoulou et al., 2017), as has accountability (e.g. Jakubowicz, 2003). The latter obliges media outlets to establish ‘governance frameworks to determine to whom and on what the organisations are accountable, and how this accountability is effectively achieved’ (Cabrera Blázquez et al., 2022: 6).
While numerous mechanisms have been developed to support the autonomy and accountability of PSM (e.g. Benson et al., 2017), similar measures have not yet been applied to other state-owned media. The ‘inherent obligation [of state-owned media] to defend the interests of society and citizens against perceived wrongdoings carried out by the very same state and its political actors’ (Nissen, 2016: 125) makes this application overdue. To enable state-owned media to meet their social obligations, editorial independence must be ensured, and public accountability established through suitable mechanisms.
Accountability should be assessed at two levels: (1) the state's accountability to state-owned media and the public; and (2) state-owned media's accountability to the public. At the first level, it embraces different ways of coping with actual or potential abuses of power (Schedler, 1999: 14). Key aspects include ensuring ownership transparency as a ‘policy response to both media plurality and trust-based concerns’ (Craufurd Smith et al., 2021: 548), and safeguarding the editorial independence of state-owned media outlets while providing adequate funding. At the second level, it concerns the processes through which state-owned media outlets ‘render an account of their activities to their constituents’ (Pritchard, 2000: 2), and how they balance their obligations to their owner (the state) and society (the public).
The state's role as a media owner within the regulatory framework
The principles of independence and accountability, which have been well-defined for PSM, should be extended to other state-owned media outlets and appropriately governed by the regulatory framework.
In the European Union, no binding document specifically regulates state ownership of news media, nor does EU legislation explicitly prohibit such ownership. The only relevant legislation is the EU State Aid Modernisation (2012), which sets rules on competitiveness with private markets and overcompensation, but also provides exemptions. These rules were further detailed in the Notice on the Notion of Aid (2016), which was extended under the Recovery and Resilience Facility (2020) because of restrictions relating to the COVID-19 pandemic (European Commission, 2022; Harcourt, 2023). Many grants to support the media sector have been approved under these regulations at the European level (ibid.), but none has addressed the issue of state-owned media outlets, or provided them with support. Instead, they focus solely on state support to private media, and do not directly deal with state ownership of news media, or its potential limitations and restrictions. The only aspects of accountability in this context are found in state aid regulations, pertaining to the transparency of acquiring and spending these financial resources.
The European Media Freedom Act (European Parliament, 2024) addresses topics such as ownership transparency, state advertising, and the protection of editorial independence. It overlooks, however, the possibility of state media, and assumes the binary coexistence of public and private media providers. There is a lack of research on how, if at all, EU member states and other European countries regulate state media ownership (beyond PSM) at the national level.
In EU Member State Slovenia, the Mass Media Act (2001) does not specify any particular limitations or obligations for the state or state-owned media companies as potential media owners. Under the 2005 lex specialis Act on Radio and Television Slovenia (2005), however, the Republic of Slovenia is designated as the founder of the public broadcaster RTV Slovenia. The Act outlines the state's responsibility to ensure RTV Slovenia's institutional autonomy and editorial independence, and to provide appropriate funding for the provision of public service. Similarly, the 2011 lex specialis Act on the Slovenian Press Agency (2011) establishes the Republic of Slovenia as the sole founder and owner of the STA, and specifies the state's obligation to provide it adequate funding, and guarantee its institutional autonomy and editorial independence. Yet the positive aspects of this act, which defines several mechanisms for ensuring independence and accountability, are not supported by a broader awareness of the necessity of such measures. The Slovenian state owns the major news website Siol.net through the state-owned and controlled Telekom Slovenija, and in the 2010s it also owned television station Planet TV, which it later sold to a private owner. There were no accountability mechanisms in place in either case, which indicates that state ownership and accountability is not approached systematically.
The proposal for the new Mass Media Act, presented in Slovenia in December 2023, does not include any additional mechanisms or accountability systems for state-controlled media. This confirms the lack of a systematic approach to addressing this issue and preventing state abuse. In this way, the situation in Slovenia, where the state controls specific media through its ownership of Telekom, follows the pattern observed in the Serbian media system, which uses its own Telekom as an indirect path to control such media. In Serbia, the 2023 Law on Public Information and the Media and the 2023 Law on Electronic Media permit the state to legally and officially own media outlets through the state telecommunications operator, Telekom Srbija. This marks a reversal from the 2014 laws, under which the state and state-owned companies were supposed to sell off the media outlets they owned (Media Ownership Monitor, 2023), and raises fear among press freedom advocates that the state has been once again handed greater influence and control over the television market (Petković, 2023).
Conclusion: Concerns about state ownership in today's media and social landscapes
The lack of clear regulations for the accountability of the state as a media owner at the EU level, coupled with perceived ambiguities in national regulatory frameworks (as evident in the example of Slovenia) and the recent reinstatement of state media ownership (as seen in Serbia), creates opportunities for the misuse of state power, and raises significant concerns within the current media and social environments. Dragomir and Söderström’s (2022: 4) analysis shows that state media in Europe face numerous threats, as ‘governments and political groups are stepping up efforts to gain more control of the media’. The 2023 State Media Monitor (Media and Journalism Research Center, 2023) notes that the situation of state and public media remains worrisome, as only 19 outlets can be classified as independent PSM (12 of them in Europe), and even they are not exempt from pressure as they endure attacks particularly from right-wing politicians and parties.
While state involvement in news media can potentially and ideally bring positive outcomes (e.g. Murschetz, 2020; Pickard, 2020), it also opens the door to media capture by governments or vested interests intertwined with politics (Mungiu-Pippidi, 2008). These concerns echo the Frankfurt School's early warnings of the potential of modern capitalism to create repressive tools that lead to authoritarianism. The rise of illiberal democracy, populism, and neo-authoritarianism in Europe (e.g. Benner, 2024; Ernst, 2024; Wodak, 2019) makes this a growing cause for concern. Populist rule has proven links with declines in most measures of media freedom (Kenny, 2020), increased instrumentalisation of news media (e.g. Maurer et al., 2023; Wodak, 2022), and attacks on PSM (e.g. Holtz-Bacha, 2021; Sehl et al., 2022). In recent years Czech PSM have been subjected to persistent attacks from populist politicians (Smejkal et al., 2024: 549), while Hungary has become ‘a perfect laboratory for improving the tools of an illiberal media policy’ (Polyák, 2019: 297).
Walker and Orttung (2014: 81–82) noted that the state-controlled media model is most effective in outright authoritarian contexts, but its features are also appealing to democratically elected governments in countries where democracy is weak or at risk of sliding back into authoritarianism. Sjøvaag and Ohlsson (2024: 12) similarly observed that although direct state ownership of media is considered benevolent within European democratic corporatist media systems, ‘not all forms of state ownership are associated with pluralism, access, free speech, and safeguarding democratic deliberation’.
When state ownership exerts control over news media, it undermines the basic postulates of social responsibility theory (Peterson, 1956), which pertain to the role of news media in democratic societies. As a socially responsible owner, the state is expected to be accountable to state-owned news media and the public, by ensuring ownership transparency and editorial independence while providing adequate funding. Similarly, state-owned media outlets, responsible for providing news content in the public interest while complying with professional standards, should be accountable to the public through mechanisms such as media councils and supervisory bodies.
Future research should explore national regulatory frameworks for the accountability of the state as a media owner systematically and in greater depth. It should aim to create a foundation upon which appropriate regulations can be developed and abuses of state power prevented, amid the troubling rise of populism and neo-authoritarianism in Europe.
Footnotes
Declaration of conflicting interests
The authors declared no potential conflicts of interest with respect to the research, authorship and/or publication of this article.
Funding
The authors disclosed receipt of the following financial support for the research, authorship and/or publication of this article: This work was financially supported by the European Union, under Grant 101094816 – DIACOMET – HORIZON-CL2-2022-DEMOCRACY-01, and by the Slovenian Research Agency, under Grant ARIS P5-0051.
