State and other impacts

A media system typology

Written by Michael Meyen

As outlined in the about us section, Mapping Media Freedom asks for major principles that could explain different mass media structures around the globe. To put it another way: What or who actually decides on national media structures and, therefore, on journalists’ working conditions and the quality of media content in a certain society? As also mentioned in the background section, the way to the target is, not particularly surprising, a media system typology based on two dimensions: formal expectations and the gateways to mass media used by the state.


Getting the two typology dimensions
The advantage of using only two dimensions instead of four (Hallin & Mancini, 2004), six (Brüggemann et al., 2014) or even eleven (Blum, 2014) is obvious. In contrast to the other studies mentioned, the media system typology is an analytical tool here. Of course, its first aim is, similar to Blum, Siebert et al. (1956) or Hallin and Mancini, to bring order to the plentitude of national media systems. A type represents a group of states sharing certain media characteristics. This definition leads directly to the main objection to using typologies at all. With the specification of the dimensions, the researcher decides on the order he or she gets. To put it differently again, every typology contains an element of arbitrariness.


The two dimensions used on this website are closely linked to both the study’s basic assumptions and the research design. We assume that all nation states are interested in steering the public information and opinion-forming stage. However, there are differences in how they implement that interest in legislation and mass media structures such as, for example, ownership, financing or media related authorities. On the one hand, as the data shows, some states constitutionally define a media mission and some states do not. In the states examined here, there are various kinds of formal expectations towards the mass media including the promotion of ideology (communism), religion, and national harmony. On the other hand, again based on the review of all of the research material, even in countries without such a mission defined in the constitution or in common law and practice, the state has numerous opportunities to restrict media freedom by acting


 as media owner, advertiser, subscriber and purchaser,
 as customer of infrastructure measures (via conglomeration),
 as accomplice of the military and security forces as well as
 by defining taboos (such as national security or pornography).


In the typology presented here, these gateways to media content used by the state are grouped from direct (state ownership of mass media or transmitters, license requirements) to indirect (state-sponsored journalism training, government PR, license fees, rules on advertising and so on).


In order to achieve the greatest possible intersubjective comprehensibility, it is important to know how we analyzed the data from both sources (documents, experts). In this process, we followed a theory-driven approach that is different from any classical grounded theory (Glaser & Strauss, 2008) and different from hermeneutics too. The procedure could best be described as a ‘theoretical coding’, using our category system based on Giddens to interpret the research material (Creswell, 2007, pp. 156-7). The initial finding was a portrait of each country. All of the portraits that can be read on this website, then, formed the basis for the media system typology. We used the concept of attributed space (Lazarsfeld & Barton, 1951) to gain an overview of all the potential combinations of our dimensions and started sorting the countries. With each new portrait, we decided whether the media system was similar to any of the others sorted previously or whether it represented a completely new case in the attributed space.


However, as mentioned above, arranging the plentitude of national media systems was just the first step of the analysis. To obtain the second and, at least from our point of view, more important aim of the study (i.e., identifying influencing factors), we looked for further characteristics shared by the different types. To be more concrete, the major principles that could explain different mass media structures around the globe are those characteristics of a certain type that go beyond the two dimensions the typology is based on. As for any typology, one could argue about the type names. The six names proposed here, are the result of our discussions on the research material and certainly open to criticism.

Idealism and Patriotism
To start on the level of formal expectations, even in the Soviet Union and the German Democratic Republic that disappeared with the Berlin wall, press freedom was granted by constitution. However, ideology defined what the media were all about back then (Fiedler, 2014). Today, it is quite similar in North Korea and Cuba (communism) belonging to the idealism type as well as in the patriotism states, Iran (theocracy), Egypt (religion, too) or Singapore with its five shared values introduced by the government in 1991. Aiming at national identity, Singaporeans are encouraged to value nation above community and society above self. The other four “shared values” are “family as the basic unit of society”, “community support and respect for the individual”, “consensus not conflict”, and “racial and religious harmony” (Singapore, 1991).


The expert interviews establish that these requirements are not just on paper. “I think Singaporeans in general do practice the shared values,” said Aaron Ng from the National University of Singapore. “It is pretty much in the cultural make-up of Singaporeans, especially the parts on religious and racial harmony and family as the basic unit of society.” Journalists are no exception at all. This is because with the shared values background, the regime legitimizes rigid media laws. To quote Aaron Ng again, “I think local journalists are usually very careful about reporting on race and religion. Of course, one of the main reasons is that we have very tough laws on anyone who cause or can potentially cause racial unrest through words. I suggest looking at the way our Sedition Act is phrased. The government does not need to prove sedition in order to charge people for sedition; all it needs to prove is that there’s a ‘seditious tendency’, which is a likelihood or chance. This is a very low bar to clear, so those who have been charged under the Sedition Act have almost zero chance of escaping a guilty verdict. Hence, journalists and Singaporeans in general are generally quite careful about issues of race and religion.” The guiding principle of the five values has a major impact on journalists’ social position and their role perceptions. “Singapore’s journalists are circumspect about where the press stands in relation to the state and society. Most do not see their profession as the Fourth Estate or adversary of government“ (George & Xiaoming, 2012, p. 101).


In the constitution of the Islamic Republic of Iran, to illustrate the patriotism type with a second example, the basic elements of Islam limit the freedom of opinion in press and other publications. This approach is already clear from the preamble where it is specifically stated that the media have to disseminate Islamic culture. The significance of the constitution’s wording can be appreciated when reading the Iranian press law. Although the country has ratified the social and civil pacts of the United Nations stressing that freedom of expression throughout the world is a universal right (Wojcieszak et al., 2012), the press law requires journalists, for example, to support politics and state and to fight luxury, immorality, and lavishness (Toulany, 2008, p. 52). “Some subject-matters such as criticism of the Revolutionary Leader or insulting the Prophet Muhammad are certainly taboo,” said the Islam scholar Marcus Michaelsen. Similar to Singapore, the compliance with the guiding principle determining the media’s work is monitored by a range of authoritative bodies legitimized through the constitution (Danesh & Ansari, 2011).


The focus on religious, national, and communist ideologies steering mass media content, however, should not mislead into thinking that there is absolutely no guiding principle in all countries listed in the upper part of the typology figure. If constitution and law contain no specific restrictions on the media or certain goals to achieve, the legal framework is obviously linked to the ideology of liberalism.


Looking at the typology of mass media systems as presented above, state influences that go beyond formal expectations are plotted on the x-axis. In a nutshell, the more on the right, the more direct the state’s influence. To start with the most obvious, even countries with a predefined constitutional or common law principle that determines the functions which mass media should fulfill, can be distinguished in this way. In Iran, Egypt and Singapore, there are private media outlets. In addition, citizens in these countries theoretically and in most parts even practically receive foreign media even though there are license and many other kinds of restrictions. Despite everything, the countries assigned to the patriotism type are different from Cuba and North Korea (Idealism) where the ruling communist parties and their subordinates own all the media. According to a documentary filmmaker who travelled North Korea professionally in 2014, the inhabitants of the country do not even have a clue of how the world beyond the borders may look like. “In TV, they just get homegrown military movies, political news praising the dynasty founded by Kim Il-Sung, domestic sports, and soap operas.”

Etatism and Clientelism
Going to the figure’s upper part and looking at countries without any formal attachment of the press to guiding principles, there are also media systems where the state and its associates are the prime contractors. From the sample, this is especially true for Belarus where state and foreign media from Russia (mainly also state-owned) dominate the landscape, Russia itself, Myanmar and Malta where the church and the two major parties run most of the press and TV companies. With just 400,000 inhabitants, the mini state does not allow for successful independent commercial outlets. Taking into account the European newspaper crisis caused by the rise of the Internet, it is not surprising that political and religious influences on media content are increasing at the moment and should be seen as “a blemish on the standard of freedom of expression” (Vella, 2014). According to the interviewed experts, in Malta, journalists are rather party officials than researchers and critics. “When hiring new staff, party affiliation is more important than journalistic skills,” said Malcolm Naudi from the Institute of Maltese Journalists.


In Belarus, there are commercial media but all influential outlets are owned by the state. Jekaterina Tkatschenko working for a TV station based in Warsaw, Poland, named the respective programs propaganda. “They just justify the government’s decisions.” The major state-owned media holding profits from tax exemption and authorities have to subscribe to state-owned papers. In addition, the main press deliverer and the TV transmitters are state-owned.


However, going left in the typology figure, introducing commercial media does not automatically mean decreasing state influence. Although there is a vivid media market in Venezuela, for example, the most important client-advertiser is the Venezuelan state since the oil-industry is 100 percent state-owned. Uganda is a second prime example of the clientelism type where the states have numerous possibilities to influence media content (as owner, as major advertiser, as employer of police and courts). At first glance, in the matter of press freedom, president Museveni who came to power in 1986 has been one of the Western world’s prize pupils for quite a long time. Under Museveni’s leadership, Uganda was quick to sign the Windhoek Declaration on Press Freedom, which was formulated in 1991 (Tabaire, 2007, p. 204). International observers as well as local journalists and activists (IREX, 2012, p. 425) praise the constitution adopted in 1995 rather highly to this very day. Article 41 “gives all citizens the right of access to information in the possession of the state, unless the information is likely to interfere with state security or individual privacy” (Lowry, 2013, p. 26). Uganda’s broadcast sector was liberalized as early as in 1993. Today, besides officially public but state-controlled media, there are numerous privately owned radio stations, commercial television, two English language dailies operating independent from the state (Daily Monitor and Red Pepper), and media regulation authorities, which arguably ensure that the media are held accountable for their actions (Tettey, 2006, p. 237). Consistent with these structures of constellations is the considerable appreciation for Western journalism concepts (cf. Mwesige, 2004). However, there are many reports on interference in journalists’ autonomy. The IREX Media Sustainability Index 2012, for example, named the temporary closure of radio stations in 2009, difficulties with licensing for government critics, cases of harassing journalists and damaging their equipment, the questioning of journalists at police headquarters over stories the government deemed critical, taboos such as security issues and terrorism, biased coverage on homosexuality, corruption, and pressure from advertising clients, of which the government is by far the biggest one (IREX, 2012, pp. 422-431; Meyen et al., 2016).

Cartelism and Liberalism
Unlike clientelism media systems such as Venezuela, Iraq, Pakistan, Uganda, Ghana, and probably most other sub-Saharan African countries, though there are networks of elites in politics, administration, military, police and the media, in cartelism media systems the state is not involved as principal owner, major advertiser, subscriber or purchaser. This is mainly because of the economic power of the countries belonging to this type. In Turkey or in Mexico, for example, there are plenty of potential ad clients, which on the surface may not be part of the state’s sphere of influence.


However, taking a closer look at the market structures, it becomes apparent that in both countries two affiliated groups dominate the media. These companies, and this is even more important, do more than just media. Similar to the clientelism countries, in cartelism countries such as Italy, France, Japan, and Israel informal structures of expectations encourage the state’s encroachment into media freedom. In Mexico where government ads are more important than in Turkey, people think of journalists as corrupt and servants of who paid them. “When journalists disappear or have been assassinated, there is no public outrage”, said Eileen Truax who works as a freelancer and author. “People think these journalists deserve it.” According to the culture journalist Conceptión Morena (The Economist), the perception of the trusts TV Azteca and Televisa as government mouthpiece persists to this day.


In liberal media systems, located in the upper left part of the typology figure, state influence is even more indirect than in countries belonging to the clientelism and cartelism types. As a rule, the liberal type is located in the prosperous Western world appreciating liberal values, looking back at a long media freedom tradition and hosting strong commercial and public service media, which concentrate on content production primarily. This is not the place for discussing the literature on “manufacturing consent” in market-driven media systems promoting democracy as the system of rule (Herman & Chomsky, 1988), but it should be clear how elites, under these circumstances, infiltrate mass media content through think tanks, PR-campaigns, journalism training or background discussions and informal meetings.


Unlike all other media system types discussed before, however, in countries, belonging to the liberal type direct state intervention would be discussed and combated in public. Outside the Western hemisphere, liberal mass media systems are likely to be extremely rare; in our sample, there are only India, South Africa, and Namibia. Both prosperous urban elites expecting information from independent sources and the British role model can explain this. “The media in Namibia play a very important role in terms of checks and balances and the watchdog role“, said Robin Tyson, lecturer in communication studies at the University of Namibia and former manager of the Namibian Broadcasting Corporation (NBC). “We haven’t any intimidation. We don’t have situations where journalists get arrested. Also we are self-regulatory. We have a media ombudsman who is an independent person. People who have complaints can contact him“. Nevertheless, both Namibia’s media market structures and its political culture are different from other liberal countries. NBC’s major funding source is an annual state subsidy and the company’s leadership is a council appointed by the information minister. The Namibian Broadcasting Act from 1991 and the broadcaster’s mandate have prevented the abuse of these structures of constellations until this moment but, first, NBC is the major source of information particularly for those in rural and peripheral areas. Secondly, it is the very same party easily winning all elections since independence. “There is some backlash”, said Robin Tyson in December 2014. “The ruling party SWAPO has mentioned for instance that they want to ban Facebook which is going to be virtually impossible. But you can see that they are worried about the influence that Facebook has, they are worried maybe about the free open conversation that people have on Facebook“. In this respect, it is important to remember that media freedom is contested even in liberal countries.

What decides on national media structures?
First and most obvious, media freedom requires the waiving of a guiding principle in the constitution or in media law as well as a state’s monopoly on the use of force. Besides a healthy advertising market and low media concentration, a further condition is a strong national identity and a socially shared conviction that media autonomy is important (tradition, cf. Voltmer, 2013), as well as international observation and journalistic professionalization. Comparing liberal media systems with the five other types and summarizing the characteristics shared by the countries assigned to a certain type, this result replies to the question about major principles that could explain different mass media structures around the globe.


In patriotism and idealism systems, first, state ideology strongly restricts media’s autonomy. Laws ensuring media freedom exist, second, only on paper until the state can exercise its monopoly of power and the rule of law. That is not or only with major reservation, the case in some countries belonging to the cartelism and clientelism types. In Pakistan, for example, military and secret service define taboos, block whole regions for reporting and even kill defiant journalists, without being punished. In both media system types, third, media financing and, closely related to it, market structures are the main gateways for state influence on media content. That is also true for the etatism type where the state or major political actors even own the most important outlets. The example of Pakistan illustrates that, fourth, weak national identities, wars, and disputed borders facilitate restrictions on media freedom. Again, this is not the place for discussing the current political situation and the state of nation building in Turkey, Russia, Belarus, Malta, or Singapore but it becomes obvious that ruling and fighting powers legitimize taboos, editorial sanctions and interventions, and even attacks on journalists in the name of national security and national interests. Knowing that the police or the secret service are able to harass them with impunity, journalists will be very carefully, especially, fifth, if there is no awareness of the importance of journalism in the specific country. Especially in clientelism and cartelism media systems, the lack of public pressure against media freedom violations strengthens the ruling powers.


At this point, it seems important to highlight the link between society’s expectations, media laws, media regulation authorities, and influence possibilities of politics and economy. In Uganda, to take up this example, many of the interviewed journalists and media activists complained about the ownership structure. The vast majority of commercial and state-independent outlets would belong to politicians closely tied to the ruling party NRM or religious leadership. Some journalists are even on the payrolls of politicians. In this African country, a second type of ownership is just commercial oriented. “Those people are not interested in informing the people”, said a rural radio journalist. “For them, it’s just a business opportunity. That’s why the ad industry is affecting us.” Consequences are self-censorship (IREX, 2012, p. 426), a media landscape which is “neither diverse nor independent” (Maractho, 2015, p. 21), and authorities which feel encouraged to extend their competence.


Again, seen through Giddens’ lens, the main reasons are informal rules and the social context. To be more concrete, in countries outside the liberal, the patriotism and the idealism types, both journalists’ working conditions and, related to this and even more important, their perception among the ruling elites, public administrations, and those governed limit media freedom and journalists’ autonomy. Particularly in clientelism and cartelism media systems, it is precisely the media’s relative societal position and its related ressources, which allows ruling elites to implement systems of media laws, and media regulation authorities, which create arbitrariness and, therefore, a feeling of insecurity within the profession. In addition, people in charge also know about Western expectations of the media. They may pay lip service to freedom principles and even sign respective laws and international declarations, but without public pressure, deriving from press freedom tradition, personal experience and media literacy journalists criticizing those in power will still face serious threats. This not only applies to opposition journalists in countries assigned to the patriotism and idealism types, but to their colleagues working without a constitutional principle that determines functions beyond critique and control of those in power. Media freedom, that is the website’s main message, does not only depend on the particular governmental system, media laws, journalism education or the existence of commercial media but also, to a significant extent, on economic realities, press freedom tradition, and various other factors, partly historical, religious or geographic.


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Recommended citation form
Michael Meyen: State and other impacts. A media system typology. In: Michael Meyen (ed.), Mapping Media Freedom. LMU Munich: Department of Communication Studies and Media Research 2017. (access date)