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Indicators of Risks to Media Pluralism

Explanation

Media Audience Concentration

This indicator is based on audience-related data and media consumption. It assesses the horizontal concentration of audience and readership across media platforms. Concentration is measured by using the Top 4 largest audience share for each media type. In Turkey, this indicator was calculated based on respected audience share numbers received from the TV Audience Measurement - Joint Industry Committee (TİAK), Press Advertisement Institution (BİK), Radio Listening Services Organization Promotion and Publishing Inc. (RİAK), and Gemius (Audience) Turkey. 

The yearly circulation numbers shared by CİMER for 2020 were used for print media audience data. TİAK’s yearly data for 2020 and RİAK’s December 2020 research results were used for TV and radio audience share data respectively. GEMIUS Turkey’s last quarter data for 2020 research results were used for the top ten list for online visitors. We do not have reliable data for the audience share.

Television:

The TV market has a medium concentration level, as the major 4 companies (Kalyon, Demirören, state-owned TRT and Doğuş) represent an audience share of 41 percent. Pro-government Kalyon Group reaches the largest audience share in this market (13.09%).  State-run TRT follows it with 12.37 percent of audience share. Demirören comes third with 9.3 percent of the audience. Doğuş Media Group, the management of which is considered to be intervened by top government officials, holds 6.21 percent of the TV audience in Turkey.

biggest owner (company or group) in this sector sum of audience share of media outlets by company
TURKUVAZ 13.09%

ATV: 10.47%

A Haber: 1.84%

DEMİRÖREN 9.3%

Kanal D: 6.29%

CNN Türk: 1.57%

TV2: 1.44%
STATE 12.37%

TRT Kurdî: 0.06%

TRT Müzik: 0.34%

TRT Belgesel: 1.43%

TRT Spor: 0.95%

TRT Çocuk: 2.78%

TRT 1: 4.02%

TRT Haber: 2.79%

DOĞUŞ 6.21%

Star: 4.97%

NTV: 1.24%

TOTAL 41%

2.1 Audience concentration in television (horizontal): MEDIUM (41%)

 

LOW (1) If within one country the major 4 owners (Top4) have an audience share below 25%.

MEDIUM (2) If within one country the major 4 owners (Top4) have an audience share between 25% and 49%.

HIGH (3) If within one country the major 4 owners (Top4) have an audience share above 50%.

 

Radio:

The radio sector in Turkey shows a medium concentration in terms of audience, with the major four companies reaching 42 percent of the audience. A large part (22.5%) of the radio audience in Turkey is held by Doğuş Media Group. TRT stations hold 11.3 percent of radio listeners. Hayat Görsel Yayıncılık holds 6.4 percent of radio listeners. Demirören is fourth with 2.8 percent.

biggest owner (company or group) in this sectorsum of audience share of media outlets by company (weighted)
DOĞUŞ22.5%

Kral FM: 15.4%

NTV Radyo: 1.2%

Kral Pop: 5.9%

STATE11.3%

Radyo 1: 1.7%

TRT FM: 8.2%

Hayat Görsel Yayıncılık6.4%Radyo 7: 6.4%
Demiören 2.8%

 

TOTAL42%

2.2 Audience concentration in radio (horizontal): MEDIUM (42%)

LOW (1) If within one country the major 4 owners (Top4) have an audience share below 25%.

MEDIUM (2) If within one country the major 4 owners (Top4) have an audience share between 25% and 49%.

HIGH (3) If within one country the major 4 owners (Top4) have an audience share above 50%.

Print:

The distribution data of print media in Turkey is an issue of large debate. As the circulation shares of most print outlets were found to be unreliable, the MOM team in Turkey finally had to “make do” with the official numbers. According to these numbers, print media circulations are highly concentrated with four major owners holding 58 percent of readership. These are Demirören (23.47%), Kalyon Group (Turkuvaz) (15.57%), BEME Media (Estetik Yayıncılık) (13.44%) and Türk Medya Group (5.35%).

biggest owner (company or group) in this sectorsum of audience share of media outlets by company (weighted)
DEMİRÖREN23.47%

Hürriyet: 10.18%

Posta: 6.86%

Milliyet: 6.43%

TURKUVAZ15.57%

Sabah : 10.67%

Takvim: 4.80%

Estetik13.44%

Sözcü: 10.51%

Korkusuz: 2.93%

Türk Medya Group5.35%Akşam: 5.35%
TOTAL58%

2.3 Audience concentration in print media (horizontal): HIGH (58%)

 

LOW (1) If within one country the major 4 owners (Top4) have an audience share below 25%.

MEDIUM (2) If within one country the major 4 owners (Top4) have an audience share between 25% and 49%.

HIGH (3) If within one country the major 4 owners (Top4) have an audience share above 50%.

Online:

No numeric data is available for online media audience share but we can indicate that it has a high concentration rate as more than half of the top 10 online media organisations belong to groups that have close ties with the government.

Online news media largely coincide with major print outlets in Turkey. 10 out of 15 online news portals with a high audience are websites of newspapers or TV outlets. The MOM team was unable to provide reliable access to the average Internet news portal follower data rates for 2020. However, we were able to reach Gemius Audience's list of the top ten news sites most accessed in the last quarter of 2020. This list has a total of 4 web portals from the two big pro-government groups (Kalyon and Demirören). There are only three web portals (sozcu.com.tr, onedio.com and mynet.com) known for not publishing pro-government news in the top ten list. Therefore, we can say that online audience data indicate a very high concentration rate.

2.4 Audience concentration in online media (horizontal): NO DATA

LOW (1) If within one country the major 4 owners (Top4) have an audience share below 25%.

MEDIUM (2) If within one country the major 4 owners (Top4) have an audience share between 25% and 49%.

HIGH (3) If within one country the major 4 owners (Top4) have an audience share above 50%.

Media Market Concentration

This indicator assesses the horizontal concentration within the media sector. Concentration is measured by using the top 4 owners. Top 4 are obtained by summing the market shares of the major 4 owners within the market.

Since financial information on market share was not available in Turkey, this indicator could not be assessed. Only two media outlets have responded to MOM inquiry regarding their financial information. 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.

Score: Unknown

 

LOW (1) MEDIUM (2) HIGH (3)
1.1 Media market concentration in television (horizontal): This indicator aims to assess the concentration of ownership within the TV media sector.
Percentage: MD
If within one country the major 4 owners (Top4) have a market share below 25%. If within one country the major 4 owners (Top4) have a market share between 25% and 49%. If within one country the major 4 owners (Top4) have a market share above 50%.
1.2 Media market concentration in radio (horizontal) : This indicator aims to assess the concentration of ownership within the Radio media sector.
Percentage: MD
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%.
1.3 Media market concentration in newspapers (horizontal) : This indicator aims to assess the concentration of ownership within the print sector.
Percentage: MD
If within one country the major 4 owners (Top4) have a market share below 25%. If within one country the major 4 owners (Top4) have a market share between 25% and 49%. If within one country the major 4 owners (Top4) have a market share above 50%.
1.4 Media market concentration in Internet Content Providers :
Percentage: MD
If within one country the major 4 owners (Top4) have a market share below 25%. If within one country the major 4 owners (Top4) have a market share between 25% and 49%. If within one country the major 4 owners (Top4) have a market share above 50%.

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: Media concentration is regulated under the Law on Establishment of Radio and Television Enterprises and their Media Services, for audio-visual media, and the Competition Authority is entitled to take action against distortion of competition according to the Law on the Protection of Competition.

The media legislation contains specific limits. The same company can only provide one radio, one television and one on-demand broadcast service, and a real person or a legal entity can directly or indirectly hold shares in a maximum of four media service providers. However, in the event that a real person or legal entity holds shares in more than one media service provider, the annual total commercial communication income of media service providers in which a real person or a legal entity is a direct or indirect shareholder cannot exceed thirty percent of the total commercial communication income of the media sector.

There is no specific regulation on digital media, and Press Law regulates printed press; therefore, these mediums' concentration is subject to the Competition Authority. The law grants both authorities sanctioning and enforcement powers in case of a breach. The Competition Authority regularly shares its decisions as well as the knowledge and experience accumulated with the public. However, Supreme Council of the Competition Authorityl  decisions on concentration of media service providers are not public; therefore, monitoring whether media service providers notified the Supreme Council for a share transfer or not is not possible to determine.

Television Description Yes No NA MD
4.1 Does the media legislation contain specific thresholds or limits, based on objective criteria (e.g. number of licenses, audience share, circulation, distribution of share capital or voting rights, turnover/revenue) to prevent a high level of horizontal concentration of ownerhship and/or control in this sector? This question aims to assess the existence of regulatory safeguards (sector-specific) against a high horizontal concentration of ownerhship and/or control in the sector. X Existence (E) of safeguards
4.2 Is there an administrative authority or judicial body actively monitoring compliance with the thresholds in the audiovisual sector and/or hearing complaints? (e.g. media and/or competition authority)? This variable aims to assess if the law/regulation provides a due monitoring and sanctioning system for the regulation on audiovisual media concentration. X
4.3 Does the law grant this body sanctioning/enforcement powers in order to impose proportionate remedies (behavioural and/or structural) in case of non-respect of the thresholds? The variable aims at assessing if the law is providing a due system of sanctions to sector-specific regulation, such as:
• Refusal of additional licences;
• Blocking of a merger or acquisition;
• Blocking of a merger or acquisition;
• Obligation to allocate windows for third party programming;
• Obligation to give up licences/activities in other media sectors;
• Divestiture.
X
4.4 Are these sanctioning/enforcement powers effectively used? This indicator aims to assess the effective implementation of sector-specific remedies against a high horizontal concentration of ownership and/or control in the television media. Medium risk: the authority's powers are not always used in all the relevant Effective Implementation (I)
TOTAL 3
Radio Description Yes No NA MD
4.1 Does the media legislation contain specific thresholds or limits, based on objective criteria (e.g. number of licenses, audience share, circulation, distribution of share capital or voting rights, turnover/revenue) to prevent a high level of horizontal concentration of ownerhship and/or control in this sector? This question aims to assess the existence of regulatory safeguards (sector-specific) against a high horizontal concentration of ownerhship and/or control in the sector. X Existence (E) of safeguards
4.2 Is there an administrative authority or judicial body actively monitoring compliance with the thresholds in the audiovisual sector and/or hearing complaints? (e.g. media and/or competition authority)? This variable aims to assess if the law/regulation provides a due monitoring and sanctioning system for the regulation on audiovisual media concentration. X
4.3 Does the law grant this body sanctioning/enforcement powers in order to impose proportionate remedies (behavioural and/or structural) in case of non-respect of the thresholds? The variable aims at assessing if the law is providing a due system of sanctions to sector-specific regulation, such as:
• Refusal of additional licences;
• Blocking of a merger or acquisition;
• Blocking of a merger or acquisition;
• Obligation to allocate windows for third party programming;
• Obligation to give up licences/activities in other media sectors;
• Divestiture.
X
4.4 Are these sanctioning/enforcement powers effectively used? This indicator aims to assess the effective implementation of sector-specific remedies against a high horizontal concentration of ownership and/or control in the television media. Medium risk: the authority's powers are not always used in all the relevant Effective Implementation (I)
TOTAL 3
Print Description Yes No NA MD
4.1 Does the media legislation contain specific thresholds or limits, based on objective criteria (e.g. number of licenses, audience share, circulation, distribution of share capital or voting rights, turnover/revenue) to prevent a high level of horizontal concentration of ownerhship and/or control in this sector? This question aims to assess the existence of regulatory safeguards (sector-specific) against a high horizontal concentration of ownerhship and/or control in the sector. X Existence (E) of safeguards
4.2 Is there an administrative authority or judicial body actively monitoring compliance with the thresholds in the audiovisual sector and/or hearing complaints? (e.g. media and/or competition authority)? This variable aims to assess if the law/regulation provides a due monitoring and sanctioning system for the regulation on audiovisual media concentration. X
4.3 Does the law grant this body sanctioning/enforcement powers in order to impose proportionate remedies (behavioural and/or structural) in case of non-respect of the thresholds? The variable aims at assessing if the law is providing a due system of sanctions to sector-specific regulation, such as:
• Refusal of additional licences;
• Blocking of a merger or acquisition;
• Blocking of a merger or acquisition;
• Obligation to allocate windows for third party programming;
• Obligation to give up licences/activities in other media sectors;
• Divestiture.
X
4.4 Are these sanctioning/enforcement powers effectively used? This indicator aims to assess the effective implementation of sector-specific remedies against a high horizontal concentration of ownership and/or control in the television media. High risk: the relevant authority never uses its sanctioning powers X Effective Implementation (I)
TOTAL 2 2
Online Description Yes No NA MD
4.1 Does the media legislation contain specific thresholds or limits, based on objective criteria (e.g. number of licenses, audience share, circulation, distribution of share capital or voting rights, turnover/revenue) to prevent a high level of horizontal concentration of ownerhship and/or control in this sector? This question aims to assess the existence of regulatory safeguards (sector-specific) against a high horizontal concentration of ownerhship and/or control in the sector. X Existence (E) of safeguards
4.2 Is there an administrative authority or judicial body actively monitoring compliance with the thresholds in the audiovisual sector and/or hearing complaints? (e.g. media and/or competition authority)? This variable aims to assess if the law/regulation provides a due monitoring and sanctioning system for the regulation on audiovisual media concentration. X
4.3 Does the law grant this body sanctioning/enforcement powers in order to impose proportionate remedies (behavioural and/or structural) in case of non-respect of the thresholds? The variable aims at assessing if the law is providing a due system of sanctions to sector-specific regulation, such as:
• Refusal of additional licences;
• Blocking of a merger or acquisition;
• Blocking of a merger or acquisition;
• Obligation to allocate windows for third party programming;
• Obligation to give up licences/activities in other media sectors;
• Divestiture.
X
4.4 Are these sanctioning/enforcement powers effectively used? This indicator aims to assess the effective implementation of sector-specific remedies against a high horizontal concentration of ownership and/or control in the television media. High risk: the relevant authority never uses its sanctioning powers X Effective Implementation (I)
TOTAL 2 2

Cross-Media Ownership Concentration

This indicator, originally, assesses the concentration of ownership in different sectors (across TV – Print – Radio – Online). Concentration is measured by adding and weighing the market shares of the Top 8 owners across all sectors in which they are operating. However, as the market shares were not available for the media market in Turkey, Cross-Media Audience Ownership was normally being calculated according to the audience shares instead. 

The results presented here are not indicators for economic strength in different media sectors but rather indicators for the potential influence on public opinion when considering all media types. The cross-media audience shares was being calculated according to the influence of different media sectors on the public in Turkey.

The Turkish Statistical Institute (TurkSat) has not updated the media consumption data in 2020 and the samples of some research are limited. We thus do not provide cross-media audience shares for 2020 as we need media consumption rates in the calculation. 

Also, since there is no reliable data on the visits of web-portals for 2020, we conclude the ratios by evaluating the rates of TV viewing, radio-listening and newspaper-readings. Demirören (35.57%) is the largest media group with the highest viewer/listener/reader ratios. Kalyon/Turkuvaz follows Demirören (30.76%) and Doğuş has 28.71 percent of total audience. Although there is no data on the rate of digital media followers/visits, when we look at the follower rates based on newspapers, radio and TV channels, it is seen that 95.04 percent of the followers are shared by three media groups.

Demirören and Kalyon are the only groups that invest in four areas such as radio, television, newspaper and website. The state broadcaster TRT has an audience rate of 18.81 percent with its channels on TV and radio. Estetik Publishing, transferred to Beme Media AG in 2020, known for its anti-government broadcasting, has a follower rate of 13.44 percent (excluding the data of sozcu.com.tr, which ranks second in the top ten news portals list). Hayat Görsel Publishing, which has investments in all three sections such as TV, radio and Internet news portals, has a 10.21 percent and Ciner Group, which only invested in the TV and digital news industry after closing Habertürk newspaper in 2018, has 7.74 percent of followers.

MEDIA CONSUMPTION
Internet 79.2% (2020 data)
Print 25% (2020 data)
Television 89.6% (2019 data)
Radio 25.3% (2019 data - listening to music)

Percentage: NO DATA

Source: KONDA Research and Consultancy 2019-2020 Data

LOW (1) If within one country the major 8 owners (Top8) have an audience share below 50% across the different media sectors.

MEDIUM (2) If within one country the major 8 owners (Top8) have an audience share between 50% and 69% across the different media sectors.

HIGH (3) If within one country the major 8 owners (Top8) have an audience share above 70% across the different media sectors.

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 related country and in the light of the thresholds or limits imposed by domestic laws.

The media legislation contains specific limits. The same company can only provide one radio, one television and one on-demand broadcast service, and a real person or a legal entity can directly or indirectly hold shares in a maximum of four media service providers. However, in the event that a real person or legal entity holds shares in more than one media service provider, the annual total commercial communication income of media service providers in which a real person or a legal entity is a direct or indirect shareholder cannot exceed thirty percent of the total commercial communication income of the media sector.

There is no specific regulation on digital media and printed press; therefore, these mediums' concentration is subject to the Competition Authority. The law grants both authorities sanctioning and enforcement powers in case of a breach.

The Competition Authority regularly shares its decisions as well as the knowledge and experience accumulated with the public. However, Supreme Council's decisions on concentration of media service providers are not public; therefore, monitoring whether media service providers notified the Supreme Council for a share transfer or not is not possible to determine.

The Radio and Television Supreme Council (RTÜK) is the authority for the regulation and supervision of radio, television and on demand media services, and has sanctioning and enforcement powers. According to the Law, the same company can only provide one radio, one television and one on-demand broadcast service, and a real person or a legal entity can directly or indirectly hold shares in a maximum of four media service providers. Though there is not a specific regulation on digital media and printed press, both are subject to the Law on the Protection of Competition.

Cross-Media Ownership Description Yes No NA MD
5.1 Does the media legislation contain specific thresholds, based on objective criteria, such as number of licences, audience share, circulation, distribution of share capital or voting rights, turnover/revenue, to prevent a high degree of cross-ownership between the different media? This indicator aims to assess the existence of regulatory safeguards (sector-specific and/or competition law) against a high degree of cross-ownership in different media sectors. X
5.2 Is there an administrative authority or judicial body actively monitoring compliance with these thresholds and/or hearing complaints? (e.g. media authority) This variable aims to assess if the law/regulation provides a due monitoring and sanctioning system for the regulation on audiovisual media concentration. X
5.3 Does the law grant body sanctioning/enforcement powers in order to impose proportionate remedies (behavioural and/or structural) in case of non-respect of the thresholds? The variable aims at assessing if the law is providing a due system of sanctions to sector-specific regulation, such as:
· Refusal of additional licences;
· Blocking of a merger or acquisition;
· Obligation to allocate windows for third party programming;
· Obligation to give up licences/activities in other media sectors;
· Divestiture.
X
5.4 Are these sanctioning/enforcement powers effectively used? the relevant authority never uses its sanctioning powers Low risk: the relevant authority effectively uses its sanctioning powers in all the relevant cases
The question aims at assessing the effectiveness of the remedies provided by the regulation. Medium risk: the authority's powers are not always used in all the relevant
High risk: the relevant authority never uses its sanctioning powers
5.5 Can a high degree of cross-ownership between different media be prevented via merger control/competition rules that take into account the specificities of the media sector? For instance, cross-ownership can be prevented by the competition law:
- by the mandatory intervention of a media authority in M&A cases (for instance, the obligation for the competition authority to ask the advice of the media authority);
- by the possibility to overrule the approval of a concentration by the competition authority for reasons of media pluralism (or Public interest in general);
Even though the law does not contain media-specific provisions - it,does not exclude the media sector from its scope of application
X
5.6 Is there an administrative authority or judicial body actively monitoring compliance with these rules and/or hearing complaints? (e.g. media and/or competition authority) This variable aims to assess if the law/regulation provides a due monitoring and sanctioning system for the regulation against a high degree of cross-ownership in different media sectors via merger control/competition rules X
5.7 Does the law grant body sanctioning/enforcement powers in order to impose proportionate remedies (behavioural and/or structural) in case of non-respect of the thresholds? Examples sanctioning/enforcement powers and remedies:
- blocking of a merger or acquisition;
- obligation to allocate windows for third party programming;
- must carry obligation to give up licences/activities in other media sectors;
- divestiture.
X
5.8 Are these sanctioning/enforcement powers effectively used? The question aims at assessing the effectiveness of the remedies of the regulation. Low risk: the relevant authority effectively uses its sanctioning powers in all the relevant cases
Medium risk: the authority's powers are not always used in all the relevant cases
High risk: the relevant authority never uses its sanctioning powers
Total (Mean of L-e und L-I sub-indicators)

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.

Media company owners and their shares can be found most of the time in the Trade Registry Gazette archive on ticaretsicil.gov.tr.  

The trade registry search engine does not allow for an individual's name to be searched, however, this can be done (at least for companies registered in İstanbul) by using the İstanbul Chamber Of Commerce (İTO) website on ito.org.tr/wps/portal/bilgi-bankası, if the national ID number is known.  During the MOM Turkey 2018 updates, these records could only be accessed by searching the name and surname information. As of 2020, in accordance with the Law on the Protection of Personal Data, it has become obligatory to search by adding a national ID number to the "Search by Partner / Board of Directors / Authorized Person" function in the aforementioned search engine of İTO. If you do not know the national ID number of the person you want to search, you cannot directly access the information about the companies where the person is a member of the board of directors, and therefore, you cannot access the information of the company via the search engine. National ID numbers of people known to be associated with companies can be found in the old records of the Trade Registry Gazette, but, for this, it is necessary to inspect all old records one by one. In cases where the national ID number is available, İTO's search engine can be used.

In the phone call of the MOM team with the İTO, it was stated that it was “deemed appropriate to require” the national ID number when doing a search.

The name search function in the chamber's search engine only indicates if the person is a member of the Board of Directors and (unless a company is a 'Limited') does not show which companies they own shares in. To track this, the only way is to identify the name of the company and analyse all its records in the Trade Registry Gazette. Some of the old records cannot be opened online using the Trade Registry Gazette, so it is nearly impossible to retrieve information on shareholders if the shares have not been traded for a long time.

Political affiliations of media owners, meanwhile, can usually be reached through research. However, in some cases - such as that of Doğuş Media, internethaber.com - political affiliations of media owners/executives have come to light through wiretaps or leaked correspondence that were claimed to be between owners/executives and government officials. These records showed how media outlets that looked like they had little to do with the government, except for non-media related activities, were actually controlled by the government, through direct conversations/correspondence between government officials and media owners/executives. 

LOW (1) MEDIUM (2) HIGH (3)
TRANSPARENCY
6.1 How would you assess the transparency and accessibility of data about the 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 Publicity Available)
Data on political affiliation of media owners 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

In Turkey, media service providers who have been granted a broadcasting license are obliged to notify the Supreme Council of the information on the names and surnames of the shareholders, its shareholding structure and the vote proportions subsequent to the share transfer within a period of thirty days as of the validation date of such transfer. Additionally, media service providers are obliged to publish information on (i) the name of the company, (ii) its correspondence address, telephone and email address, (iii) its logo/call sign, (iv) their broadcasting license and broadcasting networks, (v) the name, surname and contract information of its accountable manager in an up-to-date manner in their websites and notify such information to the Supreme Council. Even though the information is available in the Trade Registry Gazette, the law does not oblige media service providers to publish their ownership structure on their website.

Transparency Provisions Description Yes No NA MD
7.1 Does national (media, company, tax...) law contain transparency and disclosure provisions obliging media companies to publish their ownership structures on their website or in records/documents that are accessible to the public? The aim of the question is to check regulatory safeguard for transparency towards the citizens, the users and the public in general. X Existence (E)
7.2 Does national (media, company, tax...) law contain transparency and disclosure provisions obliging media companies to report (changes in) ownership structures to public authorities (such as the media authority)? The aim of the question is to check regulatory safeguard for accountability and transparency towards public authorities. X
7.3 Is there an obligation by national law to disclose relevant information after every change in ownership structure? This question aims at assessing if the law provides rules on the public availability of accurate and up-to-date data on media ownership. This is a condition for an effective transparency. X
7.4 Are there any sanctions in case of non-respect of disclosure obligations? This question aims at assessing if the law on media ownership transparency can be enforced through the application of sanctions. X Effective
Implementation (I)
7.5 Do the obligations ensure that the public knows which legal or natural person effectively owns or controls the media company? This question aim at assessing the effectiveness of the laws that deal with media ownership transparency and if they succeed in disclosing the real owners of the media outlets. Low Risk:
All the effective owners are known by the public
Medium Risk:
Some owners are still unknown
High Risk:
Effective owners are still hidden
Total (Mean of L-e und L-I sub-indicators)

(Political) Control Over Media Outlets and Distribution Networks

This indicator aims to assess 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.

Owners of media that support the government have been reported as acquiring rights to build large public projects such as the İstanbul airport (Kalyon Group, which owns Turkuvaz Media) and the Galataport project (Doğuş Group).

Albayrak Holding, which Yeni Şafak newspaper is also affiliated with, has won 437 public tenders valued at nearly 7 billion TRY in the last 11 years.

Ethem Sancak, (owner of the BMC, which manufactures TOMA, the water cannon vehicle, for the General Directorate of Security Affairs, and armored personnel carriers for the Turkish Armed Forces) sold its media assets (known as ES Medya) to Zeki Yeşildağ, whose brother (Hasan Yeşildağ) has close ties with President Erdoğan. ES Medya is now known as Türk Medya (T Medya Yatırım San. ve Tic. A.Ş).

The owner of more than 80% of the media outlets in Turkey has economic or political ties with the ruling party, AKP. (See Business Interests, Political Affiliations and Individual Owners).

Print Distribution:

The two largest print distribution companies in Turkey, Yaysat (owned by Demirören Group) and Turkuvaz (owned by Kalyon), are owned by media groups. There is no inspection into the operations of these companies, which makes the amount of media they print and distribute questionable.

Demirören Group shut down the Yaysat (the Publication Company of Demirören) on October 31, 2018. The print media would only be distributed by Turkuvaz Medya of Kalyon Group. 

TV and Radio Distribution:

On April 8, 2021, the Constitutional Court annulled the Decree Law, which paved the way for the closure of newspapers, television and agencies on the grounds that they "posed a threat to national security" during the state of emergency.

The Radio and Television Supreme Council (RTÜK) is the authority for the regulation and supervision of radio, television and on-demand media services, and has sanctioning and enforcement powers. The first wave of decisions shut down 16 televisions and 23 radios following the coup attempt in July 2016. In September 2016, RTÜK shut down 12 more television channels and 11 radios. The reason was stated as “being members of a terrorist organization”; however, the shutdown included Kurdish cartoon channel Zarok TV and Alevi channel TV 10.

The decrees issued during the state of emergency, brought about the shutdown of 38 TVs on the grounds that they belonged to “the Gülen Media”, “the PKK Media”, “the Leftist Media” (Including the shut down decision announced for 19 television channels by RTÜK)

Digiturk and D-Smart are the largest owners of digital TV distribution networks. Digiturk was taken over by the government from Cukurova Group in 2013 due to "collection of debt," after which it was sold to Qatar-based beIN Media Group. Digiturk removed Gulenist affiliated TV channels from its platform in 2015, after the rift between the Gulenist movement and the AKP government began.

LOW (1) MEDIUM (2) HIGH (3)
POLITICATION OF MEDIA OUTLETS
8.1

What is the share of TV media owned by politically affiliated entities? Result: 41%

The media having <30% audience share is owned (controlled) by a specific political party, politician or political grouping, or by an owner with specific political affiliation. The media having 30% audience share is owned (controlled) by a specific political party, politician or political grouping, or by an owner with specific political affiliation. The media having >50% audience share is owned (controlled) by a specific political party, politician or political grouping, or by an owner with specific political affiliation.
8.2 What is the share of Radio channels owned by politically affiliated entities? Result: 42%
The media having <30% audience share is owned (controlled) by a specific political party, politician or political grouping, or by an owner with specific political affiliation. The media having 30% audience share is owned (controlled) by a specific political party, politician or political grouping, or by an owner with specific political affiliation. The media having >50% audience share is owned (controlled) by a specific political party, politician or political grouping, or by an owner with specific political affiliation.
8.3 What is the share of Newspapers owned by politically affiliated entities? Result: 58%
The media having <30% audience share is owned (controlled) by a specific political party, politician or political grouping, or by an owner with specific political affiliation. The media having 30% audience share is owned (controlled) by a specific political party, politician or political grouping, or by an owner with specific political affiliation. The media having >50% audience share is owned (controlled) by a specific political party, politician or political grouping, or by an owner with specific political affiliation.
8.4 What is the share of Online Media owned by politically affiliated entities? Result: NO DATA
The media having <30% audience share is owned (controlled) by a specific political party, politician or political grouping, or by an owner with specific political affiliation. The media having 30% audience share is owned (controlled) by a specific political party, politician or political grouping, or by an owner with specific political affiliation. The media having >50% audience share is owned (controlled) by a specific political party, politician or political grouping, or by an owner with specific political affiliation.
POLITICATION OF MEDIA DISTRIBUTION NETWORKS
8.5 How would you assess the conduct of the leading distribution networks for print media?
Leading distribution networks are not politically affiliated or do not take discriminatory actions. At least one of the leading distribution networks is politically affiliated or takes occasional discriminatory actions All of the leading distribution networks are politically affiliated and has a record of repeated discriminatory actions
8.6 How would you assess the conduct of the leading radio distribution networks?
Leading distribution networks are not politically affiliated or do not take discriminatory actions. At least one of the leading distribution networks is politically affiliated or takes occasional discriminatory actions All of the leading distribution networks are politically affiliated and has a record of repeated discriminatory actions
8.7 How would you assess the conduct of the leading television distribution networks?
Leading distribution networks are not politically affiliated or,do not take discriminatory actions. At least one of the leading distribution networks is politically affiliated or takes occasional discriminatory actions All of the leading distribution networks are politically affiliated and has a record of repeated discriminatory actions

(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 should be understood as any advertising paid by governments (national, regional, local) and state-owned institutions and companies.

Results: 

There is no transparency on how much state advertising individual media outlets receive. The rules of distribution regarding state advertising are too vague and broad, thus, criticized for not being fair.

An important source of income for newspapers - especially smaller and local papers -  is the public announcements and advertising handed out by the Press Advertisement Institution (BİK). 

BİK has refused to answer a freedom of information request from RSF to disclose advertising handed out to newspapers in the past 12 months, stating that the information was a “trade secret”. Thus, it’s not possible to determine that the state advertising is distributed to media proportionately according to their audience share. 

Public announcements and advertisements distributed by the BİK, which became affiliated with the Presidency’s Directorate of Communications as per the Presidential decree in 2018, constitute a significant part of the newspapers’ revenues. Advertisements in newspapers are determined by circulation. It is widely spoken that newspapers handed out free of charge are also included in the circulation, and the circulation is shown high in order to receive advertisements.

Following the coup attempt, on October 5, 2016, regulations regarding BİK were changed. According to this contested regulation, any news outlet that employs a journalist who is being tried on terrorism related charges will not be given state advertising, unless the employee is fired from the media organization in five days.

LOW (1) MEDIUM (2) HIGH (3)
9.1 Is the state advertising distributed to media proportionately to their audience share? Impossible to assess.
State advertising is distributed to the media relatively proportionately to the audience shares of media. State advertising is distributed disproportionately (in terms of audience share) to the media. State advertising is distributed exclusively to few media outlets, which do not cover all major media outlets in the country.
9.2 How would you assess the rules of distribution of state advertising?
State advertising is distributed to media outlets based on transparent rules. State advertising is distributed to media outlets based on a set of rules but it is unclear whether they are transparent. There are no rules regarding distribution of state advertising to media outlets or these
IMPORTANCE OF STATE ADVERTISING
9.3 What is the share of state advertising as part of the overall TV advertising market?

VALUE: MD
Share of state advertising is <5% of the overall market Share of state advertising is 5%-10% of the overall market Share of state advertising is > 10% of the overall market
9.4 What is the share of state advertising as part of the overall Radio advertising market?

VALUE: MD
Share of state advertising is <5% of the overall market. Share of state advertising is 5%-10% of the overall market. Share of state advertising is > 10% of the overall market.
9.5 What is the share of state advertising as part of the overall Newspaper advertising market?

VALUE: MD
Share of state advertising is <5% of the overall market. Share of state advertising is 5%-10% of the overall market. Share of state advertising is > 10% of the overall market.

(Political) Control Over News Agencies

According to the BİA Media Monitoring Report, in 2020, a total of 215 journalists and media employees were dismissed because of pressure from government circles, forced to resign after disagreements on broadcasts, or after their programs were canceled.

As unemployment heavily affected the sector after the 2016 coup attempt, when 2,708 journalists lost their jobs, 3,436 journalists have lost their jobs in the last five years. 190 media employees became unemployed in 2019, 157 became unemployed in 2018 and 166 became unemployed in 2017.

The questions addressed to news agencies regarding their finances were left unanswered. Anadolu Agency (AA) is a joint stock company which was founded by the state of Turkey. Its shares are owned by the Undersecretariat of Treasury. AA is the largest news agency in Turkey, with its structure both inside and outside the country. The broadcasting of Anadolu Agency, like that of TRT, has been and is being criticized for being pro-government.

Gulenist affiliated Cihan News Agency has been taken over by the government in March of 2016, and shut down after the coup attempt in July 2016.

DIHA, the Kurdish affiliated news agency, has been under government pressure for anti-government reporting especially regarding the clashes in the Southeast. DİHA was also shut down after the coup attempt. 10 DIHA reporters are imprisoned based on charges of support to terrorism or of being members of "terror organisation" PKK.

Based on the decrees 668, 675, 677, the number of news agency shut down reached 6 (Cihan News Agency, Muhabir News Agency, SEM News Agency, Dicle News Agency, Jin News Agency, Dihaber - Dicle Medya News Agency) during the State of Emergency period.

LOW (1) MEDIUM (2) HIGH (3)
10.1 What is the market share of the leading news agency?
VALUE: MD
No news agency dominates the market (occupy >30% of the market of news agencies). One news agency has <50% ≥30% share of the market of news agencies. The leading news agency has ≥50% market share.
10.2 How would you evaluate the political affiliation and/or dependence of the largest news agency?
2 out of 3 leading news agencies are politically affiliated.
None of the largest news agencies is dependent on political groupings in terms of ownership, affiliation of key personnel or editorial policy. At least one of the largest news agencies is dependent on political groupings in terms of ownership, affiliation of key personnel or editorial policy. Most or all of the largest news agencies is dependent on political groupings in terms of ownership, affiliation of key personnel or editorial policy.

Our jaw has dropped in the face of this media freedom!

  • Project by
    Bianet
  •  
    Reporters without borders
  • Funded by
    BMZ