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date: 19 April 2024

Accountability in Journalismfree

Accountability in Journalismfree

  • Susanne FenglerSusanne FenglerErich Brost Institute for International Journalism, Technical University of Dortmund


In the past decade, academic and professional debates about media accountability have spread around the globe – but have done so in a fundamentally different framework. In many Western democracies, trust in media – along with trust in politics and trust in institutions – as eroded dramatically. Fundamental shifts regarding the patterns of media use and the structure of media and revenue markets have made media and journalism more exposed to criticism from various stakeholders, and more vulnerable to the strategic influence of national and international actors. While many “Western” media professionals have reacted to these challenges to its credibility by new initiatives to demonstrate accountability and transparency, policy makers in other countries even in the “Global North” have tightened their grip on independent media and gradually weakened the concept of self-control. At the same time, an ongoing democratization in many parts of the world, along with a de-regulation of media markets, has created a growing demand for self-regulation and media accountability in countries formerly characterized by rigid press control.

Claude-Jean Bertrand defined the development and current structures of accountability in journalism as “any non-State means of making media responsible towards the public.” Key aims of media accountability are “to improve the services of the media to the public; restore the prestige of media in the eyes of the population; diversely protect freedom of speech and press; obtain, for the profession, the autonomy that it needs to play its part in the expansion of democracy and the betterment of the fate of mankind.” Journalists and news outlets have a wide array of responses to professional, public, and political criticisms via press councils, ombudsmen, media criticism, and digital forms of media accountability, while online and offline media accountability instruments have distinct traditions in different media systems and journalism cultures.


  • Journalism Studies
  • Mass Communication

Media Accountability Versus Media Regulation

Societies must have a genuine interest in the quality of information provided by the mass media due to their unique function for democracy: Media create a public sphere, where controversial arguments regarding political (and other) matters are being exchanged. Scholars also assume that the agenda-setting function of the mass media will continue even though the digital transformation has a considerable impact on the traditional gatekeeper role of journalists.

However, journalists and media organizations often do not live up to the expectations, and “media can cause serious harm” even “without violating the law” (Bertrand, 2000, p. 22) During the past few decades, most Western democracies have developed a complex legal framework that is supposed to safeguard a free and pluralistic media landscape (Psychogiopoulou, 2012). But while media laws usually regulate the (infra-)structures of media practices in the respective areas of application, journalistic contents are protected almost entirely from state interference (Puppis, 2009, pp. 57, 61). Therefore, it is even more important that media treat their various stakeholders responsibly, so that journalism can fulfill its manifold social functions without external control (McQuail, 2013). With regard to the prominent role mass media play in modern societies, a growing number of media scholars have emphasized the urgent need to hold the mass media accountable in past decades. McQuail (2003) has pointed out the process-oriented character of media accountabilitya striving for “co-orientation”: “[A]ccountable communication exists where authors (originators, sources, or gatekeepers) take responsibility for the quality and consequences of their publication, orient themselves to audiences and others affected, and respond to their expectations and those of the wider society” (p. 19).

Media Accountability, Media Self-Regulation, Media Transparency, and Coregulation

Media researchers are using different terms in order to describe the processes that journalistic actors trigger in order to ensure responsible behavior. The terms media self-control or media self-regulation (Puppis, 2009) are commonly used to denote those practices which members of the journalistic profession initiate themselves to guarantee the quality of their coverage. The broader concept of media accountability, on the other hand, discusses “any non-State means of making media responsible towards the public” (Bertrand, 2000, p. 108)—and thus not only includes journalists, but also media users and other stakeholders of the media into the process of journalistic quality management. In recent years, the concept of media transparency (Meier & Reimer, 2011) has gained increasing scholarly attention. It focuses on a variety of instruments, particularly on the level of the media organization, that can contribute to preserve or regain trust in journalism by providing information about newsroom processes and the participating actors (e.g., with the help of online profiles of journalists, public mission statements, links to original sources, newsroom blogs, etc.). Media accountability can also be part of concepts of coregulation (Puppis, 2007), implying that media laws require the media industry to implement self-control bodies. For example, several broadcasting laws demand broadcasting organizations to install an ombudsman taking public complaints.

Stakeholders of Media Accountability

Bardoel and d’Haenens (2004) have specified the different stakeholders potentially to be addressed in the accountability process: Besides the public, they mention the journalistic profession and the market, as well as the political sphere—which facilitates a debate about the role of media accountability beyond Western democracies (see the section on “Media Accountability in Restrictive Regimes and Transition Countries”). Von Krogh (2012) has amended their model by pointing toward the impact of the media system and of technology on media accountability.

Figure 1. Media accountability frames (Von Krogh, 2012, p. 21).

Media Accountability Instruments

Given the many externalities produced by the media system itself, various “non-state means” (Bertrand, 2000) have been developed in past decades in many Western democracies to hold the media accountable especially. Press councils, ombudsmen, media criticism in trade journals and mass media—as traditional media accountability instruments (MAI)—all have the task to monitor journalists’ professional performance and follow up on journalistic malpractice in countries that guarantee freedom of the press and thus forbid state interference into journalism (Dennis, Gillmore, & Glasser, 1989). Furthermore, in the past decade, many new MAI have emerged online, offering new forums to discuss journalistic standards and media quality, like social media, journalists’ and newsroom blogs, and online ombudsmen. In addition, new MAI facilitating audience participation in holding the media to account have evolved, among them users’ blogs, comment and complaint functions offered by news outlets, new online applications offered by traditional MAI (such as complaint forms and occasionally webcasts of meetings provided online by press councils and media regulators), and audience media criticism voiced via Twitter and Facebook.

Brief History: The Role of Professionalism for Media Accountability

A prerequisite for the development of MAI has been the development of professionalism in journalism respectively among journalistic actors (Meyers, Wyatt, Borden, & Wasserman, 2012), marked by independent professional associations in journalism (journalists’ unions, publishers’ associations, and the like) as potential actors to hold the media to account (Campbell, 1999, p. 759). Concerned journalists across Europe and the United States started to form press clubs and journalists’ federations in the late 19th century; the earliest known example existed in the United Kingdom. Publishers also started to form their own associations. In an attempt to raise the standards among journalists—who often had little or no formal or professional education and were poorly paid—many of these journalists’ associations (later journalists’ unions) started to pass codes of ethics seeking to make a distinction between acceptable behavior and unacceptable methods in journalism. Hafez (2002, p. 226) stresses that informal discourses are even more relevant for journalism cultures without press freedom, where journalists cannot fix certain values, such as impartiality and independence, from state interference in written form. Indeed, even prior to codes, each journalism culture had developed professional norms, which were communicated and passed on in the newsrooms, in journalism textbooks and in journalism education, and in the context of professional discussions and venues. Serving as the “conscience of journalism” (Limor & Himelboim, 2006, p. 266), codes of ethics specify how journalists are expected to behave professionally. Laitila’s (1995) study found that almost all European codes request of journalists “truthfulness,” “honesty,” “accuracy of information,” and “correction of errors” (p. 538). However, even though professional associations and unions of journalists now exist in many countries, journalism—unlike classic professions such as medicine or law—lacks the characteristics of a profession (see, e.g., Weaver, Beam, Brownlee, Voakes, & Wilhoit, 2007, p. 131), most of all because access to journalism in almost all democratic states is not restricted by a professional body, to ensure its independence.

The “Hutchins Commission”: A Starting Point for Media Accountability

In the years following the Second World War,1 public debates about the quality of the media intensified in many western European countries, and governments threatened to tighten media control and install state-run press councils. At that time, public discontent with a press widely considered in many countries as greedy, sensationalist, and politically imbalanced (McQuail, 1983/2010, p. 170), culminated in the United States in the establishment of the Hutchins Commission. This was a committee of intellectuals set up to investigate the status quo of journalism and develop ideas about how to make the media more accountable to the public. Among other recommendations, this commission suggested

that the members of the press engage in vigorous mutual criticism. Professional standards are not likely to be achieved as long as the mistakes and errors, the frauds and crimes, committed by units of the press are passed over in silence by other members of the profession.

(Leigh, 1947, p. 94)

This was a notion almost shocking to media professionals at that time. However, journalists in many Western countries finally reacted to public criticism—and political pressure—with the establishment of MAI beginning in the 1950s, while the media in eastern Europe fell victim to the Communist regimes that had come into power after World War II. Professional societies of journalists and publishers’ associations, which had formed in many countries by the turn of the 20th century, reacted to political pressure by establishing non-state press councils as a first attempt to exercise systematic self-regulation and thus escape from external regulation.

Press Councils in the United States and Western Europe

Alsius, Rodríguez-Martínez, and de los Rios (2014) define press councils as

collegiate bodies that oversee self-regulatory compliance with the ethical principles of journalism. Generally, these organizations take as a reference those codes that they help to draft or update. Usually, these councils receive complaints from users of the media and, after the necessary consultations with the companies involved, issue a verdict. Since they are not legitimized by universal suffrage and stand outside the judicial system, they often have no sanctioning capacity but merely a moral authority. . . . In addition, these bodies are somewhat constrained by their institutional environments. (p. 101)

In the United States, press councils on the federal or state level came into existence in 1970. A short-lived National Press Council operated in the 1980s but never reached industry-wide acceptance due to lack of support from many of the leading media. All federal- or state-level press councils in the United States have since closed. In Europe, the United Kingdom was the pioneer, with the creation of the General Council of the Press in 1952. Following the British model, the German Press Council was founded in 1956. Press councils in the Netherlands, Austria, and Finland were created in 1960, 1961, and 1968, respectively. The Swiss Press Council was established in 1977. Norway, Sweden, Denmark, Iceland, Belgium, Luxembourg, and Ireland also developed press councils; thus, this most traditional instrument of media self-regulation now exists virtually everywhere in northern and western Europe, with the exception of France. In the United Kingdom, an Independent Press Standards Organisation (IPSO) was installed after the News of the World Scandal and the ensuing Leveson Inquiry, which is, however, only supported by parts of the industry. Altogether, the Alliance of Independent Press Councils of Europe currently includes 34 associations in Europe (including eastern Europe). However, in France, attempts to create both a Press Honor Council (Cour d’Honneur de la presse) in 1946 and a Press Council (Conseil de presse) in 1973 failed. In 2006, an “association anticipating a press council” was founded by journalists; however, no progress has been made so far. In Spain, a national press council was established after the end of the military dictatorship (and thus censorship) in 1993, but only a few regional councils, like the one in Catalonia, are considered effective. In Italy, a journalists’ chamber (Ordine dei Giornalisti), regulated by law, was set up in 1963. In a guild-like way, the Ordine regulates access to the profession.

The weakness or lack of press councils in southern European countries already signals that their culture of media accountability is largely underdeveloped. The key reasons are that political actors still exert considerable influence on the media and journalism and the professional culture of journalism is weak. Frequently, different journalists’ federations compete for legitimacy, and the quality of journalism education is rather poor. Consequently, and in a similar way to their colleagues in central and eastern Europe, journalists in southern Europe—given the absence of a functioning network of self-regulation and accountability structures—are considerably more willing to let the courts settle disputes between journalists and citizens. They are also less supportive of media self-regulation instruments at the professional level compared to their northern European colleagues (see Eberwein, Fengler, & Karmasin, 2017).

Press Councils in Central and Eastern Europe

In central and eastern Europe, the political transformation after the end of the Communist regimes and the ensuing deregulation of the media sector gave media professionals the opportunity to create a new system of self-regulation. However, media practitioners in central and eastern Europe have been skeptic about any form of media “regulation” since the end of Communism; structures of media self-regulation and media accountability are still evolving (see Eberwein et al., 2017). In a similar way to the southern European countries, the status of the profession is disparate, as journalists’ unions and federations in central and eastern Europe were created in a state of political disintegration. Thus, in the media systems of central and eastern Europe, organizations like press or media councils mostly came into existence only in the period after the fall of Communism—if at all. In many cases, their foundation was accompanied by the formulation of new codes of ethics, following the ideals of Western media systems. Often, however, it turned out difficult for these institutions to gain acceptance among industry members. The earliest example of a press council among the central and eastern European (CEE) countries, the Avaliku Sõna Nõukogu, founded in 1991 in Estonia, illustrates this problem quite well: It was organized with the Finnish experience as a role-model—and operated for a while as the only critical institution toward the media in Estonia. However, as the critical discourse of the press council became more and more disliked among media leaders, resistance emerged, and eventually, as a result of a conceptual conflict, the Estonian Newspaper Association withdrew its membership, with the broadcasters (both private and public) following suit, to found their own press council in 2002. As a consequence, two national press councils are now competing for supremacy in Estonia. Because of the lasting tensions between the councils, the Code of Ethics for the Estonian press has not been amended since 1997 (Lauk & Jufereva, 2010). In Poland, the Press Act of 1984 defined a press council as a consultative body for the prime minister, but this council does not yet exist. In recent years media scholars have proposed changing the old legislation and transforming new ideas into media law in order to introduce such an institution in Poland. In Romania, neither a press council nor a similar institution exists at all. However, Romanian media actors are organized in one of the oldest professional associations of journalists in eastern Europe which is functional even today: the Union of Professional Journalists, created in 1919, with its own Code of Ethics. A direct diffusion of western European models can also be observed in other CEE countries. In Lithuania, for example, a system of self-regulation with a press council and an ombudsperson, similar to the Swedish case, was introduced in 1996. Other press councils, for example in Slovakia (since 2002), Bulgaria (since 2005), and Croatia (since 2011) were introduced, but their activities are hardly visible in the public and therefore do not leave much of an impact on practical journalism. Hungary has a media council that is part of the coregulation system that was set up in accordance with the media law of 2010, but members of this media council are recruited by Fidesz-dominated Parliament (see Eberwein et al., 2017).

Ombudsmen: History and Development

Evers, Groenhart, and Van Groesen (2009) have defined media ombudsmen as “mediators between the consumers (readers, viewers, listeners) and the editorial staff of their medium” (p. 5) with a twofold task: on the one hand, they take on user complaints, discuss the user criticism with the responsible reporter or editor, and get back to the complainant afterwards; on the other hand, they are expected to launch general debates about standards in journalism within the newsroom. Some ombudsmen also write about the complaints they receive or about ethical issues in general, or they use the medium’s website or a blog to publish. By doing so, they create “a highly visible public profile for the news organization to readers” (Nemeth, 2003, p. 12). Frequently, ombudsman positions are held by veteran journalists with significant experience in the news business. Since they are usually not members of the newsroom but report solely to the publisher or editor-in-chief, ombudsmen are, in theory, expected to act as independent representatives of the media’s public.

Although the ombudsman concept is much older, the idea of establishing ombudsman positions in media organizations is accredited to Lester Markel and Abe Raskin, two well-known editors of The New York Times, who both published widely debated media-critical articles in their newspaper in 1967. While Markel accused the U.S. press of trivialism and a lack of professionalism, Raskin called on the media to create internal departments of criticism to fight the high-handedness of media institutions and to employ ombudsmen as mediators between journalists and the public (Brown, 1974, p. 52). One week after Raskin’s article was published, Norman I. Isaacs, publisher of the Louisville Courier-Journal and the Louisville Times, hired veteran journalist John Herchenroeder as the first newspaper ombudsman. The Washington Post was the first prominent media organization to follow this example in 1970. Several U.S. newspapers and, later on, broadcasting stations followed in the years afterwards. Since then, ombudsmen have been appointed by many news organizations worldwide (Marzolf, 1991). By 1980, the ombudsman concept had generated sufficient interest to result in the foundation of the international Organization of News Ombudsmen, which now has more than 50 members representing 24 countries. Interestingly, while the number of ombudspersons remains comparatively low in the United Kingdom and northern Europe, there has been a noticeable increase in ombudspersons in some countries in southern Europe (see Eberwein et al., 2017): UK media outlets like The Guardian and The Observer maintain an ombudsman position also due to their critical position to the newly founded IPSO, while the BBC has its own complaints procedures for members of the public. In Germany, the ombudsman concept is not very popular among news organizations to date: no more than half a dozen regional or local papers employ a readers’ representative or a similar actor. The German BILD established an ombudsman in 2017. In Spain, El País pioneered with the creation of an ombudsman office in 1985, and several other newspapers, as well as public and commercial broadcasters, followed this example later on. Similarly, in Portugal, ombudspersons play an important role in several media houses—for example at the quality newspaper Público and the public broadcaster RTP. In France, Le Monde was among the first media to create an ombudsman office in 1994, followed by other newspapers and the public broadcasters France 2 and France 3. However, there are no ombudspersons in Italy. While private media enterprises in central and eastern Europe have been reluctant to establish instruments of media accountability, legislators have obliged public broadcasting stations to implement instruments of media accountability in the political transformation period after 1990. Media law requires public broadcasters to provide an ombudsman or an ethics committee in almost all CEE countries. However, CEE public broadcasting stations are less independent from politics, and political actors have a grip on MAI in several cases (see Eberwein et al., 2017).

The “Fifth Estate”: Media Criticism

Bertrand (2000) defines media criticism as a specialized form of journalism monitoring the news media and reporting critically about them for a mass audience; Hayes (2008) terms press critics the “fifth estate” in the United States. Since the news media “have become one of the nervous systems in the social body, the public needs to be informed about them. Some journalists must specialize in that field so as to cover its news well and investigate uncompromisingly” (Bertrand, 2000, pp. 70, 116, 143).

Even after the creation of press councils in the 1950s and 1960s, the public in Western societies remained largely excluded from the debates about standards in journalism, and trade journals addressed the media professionals—not the wider public. Up to the 1990s, media reporting and media criticism in the mass media were as rare as at the beginning of the 20th century, when Lippmann (1995) first called for more journalists and reporters to specialize on the media:

only rarely do newspapermen take the general public into their confidence. They will have to sooner or later. . . . The philosophy of the work itself needs to be discussed; the news about the news needs to be told. (p. 17)

While new alternative papers started to criticize the “legacy media” in the 1970s, only in the 1990s—in a decade witnessing the continued spread of cable TV, the deregulation of the broadcasting sector, the emergence of commercial television in many European countries, and finally the triumphant growth of the Internet—did media reporting suddenly flourish in the mainstream media as well. Many legacy media started following up on journalism and the media industry, but by about 2000, when there was a deep media crisis, the number of media pages and media programs had decreased considerably in many Western countries (Fengler, 2003). Throughout the past decade, the news media has again increasingly come under attack in many Western countries. Buzzwords such as “fake news” or “lying press” have been used to discredit the work of journalists. In an alleged “post-truth era,” the role of the media as the fourth estate or an indispensable facilitator of public discourse has come under scrutiny. Yet, the attackers have not only been extremists and populists. Quite the contrary, a variety of actors from different societal backgrounds have questioned the performance and credibility of the mass media. At the same time, media organizations and the journalism profession have increasingly been forced to react on a “secular societal trend of citizen participation” (Van der Wurff & Schoenbach, 2011, p. 417).

Media Criticism in the United States and Europe

Today, there is a considerable amount of media criticism in northern European countries like the United Kingdom, Germany, the Netherlands, Switzerland, and Finland, which is provided by quality newspapers and sometimes also public broadcasting stations. While it is still not common for French journalists to publicly discuss problems in journalism, in France, as in many other southern European and CEE countries, media blogs and social media have emerged as new spaces for independent debate about media topics (see Eberwein et al., 2017). Media journalism is not practiced by the mainstream media and remains a domain of alternative, community, and niche media, which is less dependent on market mechanisms and takes on the form of media satire (e.g., Slovenia) or is restricted to public broadcasting (e.g., Latvia). Similarly, only Poland and the Czech Republic report several regularly published trade journals, while initiatives to introduce platforms for professional exchange both offline and online have failed in the smaller countries. Bertrand’s (2000) criticism is still true today, especially in the CEE countries:

With exceptions (usually due to ideological animus or business rivalry), media do not criticize each other: blind eyes are turned on the failings of colleagues. Self-criticism is almost unknown. . . . In this profession, as in others, solidarity sometimes verges on collusion. (p. 143)

Poland now has a rather popular trade magazine called Press, but it lacks media criticism in the mass media. Media criticism is also confined to media blogs in Romania, where there is a rather lively media bloggers’ scene. There is practically no media journalism in the mass media in Estonia, because, as Loit, Lauk, and Harro-Loit (2011) observe, “owners, editors-in-chief and other media leaders are highly allergic towards any criticism addressing their outlets” (p. 44). In sum, the large northern European media markets have a decent amount of media criticism, while this form of holding the media to account is still an exception in central and eastern Europe and often takes the form of satire in southern Europe and France. Besides the degree of professionalism, political parallelism might be a relevant explanatory factor: in countries where politics heavily influence the media, journalists tend to refrain from publicly criticizing other journalistic actors, because it is very likely that this will be understood as political, not professional, criticism. In these countries, journalism still lacks the freedom to report critically on the media (see Eberwein et al., 2017).

Online Media Accountability

Noting that “technological innovations—such as Twitter—trigger changes in the way newsrooms relate to their publics and vice versa,” Heikkilä et al. (2012, p. 11) stress that online media accountability should be understood in terms of practices:

By practices we mean generally accessible and sustained modes of social and public agency designated by institutions or groups of publicly active people. With regard to media accountability, the main actors initiating such practices are media organizations (the online newsrooms of traditional media and net-native news projects) on the one hand, and online content providers from civil society (bloggers, grassroots movements etc.) on the other. (p. 13)

In the digital age, new forms of online media accountability are gaining the attention of media and communication researchers, who hypothesize that their low cost and easy accessibility might compensate for some of the deficits of more traditional and institutionalized instruments of media self-regulation. These include simple transparency instruments, such as bylines, online profiles of journalists, published mission statements, precise links to news sources, and so on but also more complex participatory instruments, like comment functions, buttons to report errors, media blogs, Facebook and Twitter profiles that are used for media criticism, and collaborative story writing or investigation spaces. According to the MediaAcT study (discussed later), many media professionals across countries say that they have observed a notable increase of critical audience feedback online. Especially younger journalists and those journalists who work for online media are open-minded toward these innovative instruments. Among the new digital possibilities, social media are rated as the most important media accountability instrument: journalists state that they are receiving an increasing amount of feedback and critique—but also insults—from their audience via Facebook and Twitter.

Although the scope of media blogs in Europe has been diverse up until recently, differences between countries are still noticeable. The number of media blogs (and other web-based MAI) seems to be mainly dependent on three factors: the national Internet user culture, the legitimacy of the mainstream media, and the existing traditional institutions of media self-regulation. Among the countries with the liveliest forms of online media watching—either from within or outside professional journalism—are the United Kingdom, the German-speaking countries, the Netherlands, France, and Italy. All of them belong to the group of countries with an Internet usage above the average. Some of them also have a large number of active producers who tend to contribute their own content to online discussions, while at the same time at least some of the mainstream media and traditional media accountability institutions are challenged by fierce criticism. This is different, for example, in Finland, where Internet penetration is one of the highest in Europe but the number of active producers is low, and both the established media and the venerable old media council enjoy a high level of public trust. Consequently, online accountability practices are less common in the Finnish media landscape (see Eberwein et al., 2017).

Media Accountability in Restrictive Regimes and Transition Countries

While comprehensive research exists on journalism and accountability for the United States, Canada, Australia, New Zealand, and Europe, research about media accountability in media systems and journalism cultures beyond the Western world is rather rare. Frameworks for media accountability are fundamentally different from those in democratic states in the many countries with restricted press freedom: Here, journalists’ associations and “media councils” have long been government tools to control access to the profession, and the concept of media self-regulation in practice only disguises censorship in some countries. Recent studies emphasize the ambivalent perception of the concept of accountability by members of the journalistic profession and the impact of political restrictions on media accountability in transition countries.

A few studies exist regarding media self-regulation in some African countries such as Ghana, Tanzania, South Africa, and Botswana (Akpabio & Mosanoka, 2018; Berger, 2010; Duncan, 2012; Gadzekpo, 2010; Mfumbusa, 2006; Rioba, 2012; Wasserman et al., 2012), but cross-country comparison is scarce. Somewhat similar, the accountability infrastructure of Asian countries has not been subject to systematic comparative research yet, and research on the national level is rare too. Speck (2017) has explored the development of media accountability infrastructure following the political transition in Myanmar. Within the transitional media system, the Myanmar Press Council (MPC) holds a position quite typical for such institutions in transitional or development countries. Set up by statute and including government representatives, the MPC fights its way between state dominance and demands for more professional autonomy. This leads to an ambivalent situation where the council has a mandate to negotiate with state and military officials on behalf of the industry. Consequently, parts of the industry regard it as government proxy. The council is neither a simple governmental tool to tame the press nor is it capable of effectively promoting journalistic self-regulation and fending off state interference into media affairs. The example of the MPC illustrates why it is so important to consider not only the public as a potential addressee of accountability measures but also other stakeholders such as the political sphere when taking a closer look on the situation beyond liberal democracies.

A comprehensive study on media accountability in Latin America (Bastian, in press) has analyzed the development of media accountability in Brazil, Argentine, and Uruguay after the end of military dictatorship. Bastian’s study has retrieved many similarities between media accountability cultures in these countries and the countries in southern and eastern Europe. As the profession remains rather weak due to precarious working conditions in a monopolized and strongly commercialized media market, political pressure, and also physical assaults, MAI on the professional level like press councils and ethic codes remain less developed. Some quality media engage in media criticism, while the media’s involvement in the military dictatorships has only been started to be discussed recently. Other than in Europe, media observatories—run by universities as well as independent veteran journalists—provide prominent forums for media-critical debates. Small studies exist for Israel, Turkey, and Russia, where journalists and news outlets are faced with different context conditions: With regard to the ongoing military conflict in the Middle East, the Israeli military continues to exercise media censorship, and even though the public sphere and public debate in social media in Israel is described as vibrant, the government has a strong grip on the broadcasting sector. In contrast, governments in Turkey and Russia control large parts of the media and thus hamper the development of effective instruments of media self-regulation. Thus only a minority of Turkish media supports the Turkish Press Council founded in 1988. In 1998, the Journalists’ Association of Turkey passed an code of ethics, but the association has been under political pressure as well, and in 2010, progovernment journalists created a separate association, along with a code. Obviously, there are severe limits to media accountability activities on the professional level, but given the political instrumentalization of many media outlets in Turkey, MAI on the organizational level are fragile as well. As of 2017, four leading newspapers maintained ombudsmen but could not act independently, which might also be assumed for the public’s representatives installed in broadcasting stations. The reader’s editor of the Cumhuriyet, Güray Öz, has been, along with other leading editors of the daily, subject to criminal prosecution.

Media criticism is restrained to social media and the few independent news organs. In the past years, many nongovernmental organizations critical of the mainstream media monitored and analyzed the influence of politics and business on journalists in Turkey. However, attempts to create a more accountable media landscape have faded into the background vis-à-vis the recent developments in the country. Following the failed coup-d’état in 2016 and the subsequent authoritarian turn in Turkish politics, the country turned into the world’s largest prison for journalists (Reporters without Borders, 2018), and most of the news media organizations have come under direct or indirect governmental control. Thus highlighting state dominance and obedience within the news media and following the numerous arrests of and verdicts against journalists has become a key task of media monitoring. In Russia, a Public Board on Press Complaints was created in 2005, but one of its chambers is composed of party members and other political representatives, government officials, and judges. Various ethical codes have been adopted by major journalists’ associations since 1994 but are considered ineffective. Several media with a high national visibility have passed their own organizational codes in the past years and experiment with instruments of media transparency. As in Turkey, media criticism is not common in the Russian mainstream media, and critical issues regarding media are largely restrained to social media. Even though Israeli journalists operate within the framework of a democracy, and a critical debate about the quality of media does take place in Israel—be it on a respected TV program focusing on media, a journalist’s blog, online comments, and or a website maintained by nongovernmental organizations—infrastructures of media accountability are weak and display many resemblances to the status quo of media accountability in southern and eastern European countries. The Press Council is considered as a rather weak instrument, and many disputes about media accountability are taken to court in Israel. For the Arab world, case studies exist for Tunisia and Jordan. While the media remain under tight state control in Jordan after the 2011 uprisings in many Arab countries, uniform content in Tunisia has already diversified, ownership structures have changed, and access to information has been freed from sheer state propaganda to a more open approach. Yet many obstacles remain as well: the public is watching media developments critically and politics is trying to put the media under pressure. Studies (Pies, 2015a, 2015b) clearly show the different notion of media accountability in these countries in comparison to the European states. For the Arab journalists, the audience and the public in general were perceived as the most important actors to which journalists are responsible. Jordanian and Tunisian journalists seem to regard the public as an “ally” for media freedom and journalistic responsibility—they perceive the public more positive than their European colleagues. This can be interpreted in the light of the transitional context: Individual freedoms including freedom of speech and press have been part of the demands by protesters in Tunisia and Jordan since the beginning of the Arab Uprisings. Because of their authoritarian past (and present) and the uprisings, the issue of press freedom is still higher on the agenda than in established democracies of Europe. The role of online journalism as a relatively free space—compared to legacy journalism—in Jordan and the role of online practices during some of the Arab Uprisings may play a role for that perception. Yet, the authoritarian system also still has its marks: Jordanian and Tunisian journalists still feel a higher responsibility toward government and/or political parties than their European counterparts. This is not too surprising given the fact mentioned earlier that media in authoritarian regimes are mostly held accountable by actors from the political accountability sphere through state ownership, direct or indirect censorship, and so on.

Literature Review: Key Studies and Findings

Research on accountability in journalism has focused on theoretical and normative aspects and—to a lesser degree—on empirical studies. Until recently, media accountability has been an academic field still understudied and focused on national discourses; the MediaAcT literature database is available online.2 Laitila (1995) and Bertrand (2000) have pioneered in the comparative analysis of MAI by comparing the content of European press codes. Bertrand (2000) additionally studied the existence of further “media accountability systems,” like press councils and ombudsmen in Europe. Nordenstreng (1999) has analyzed structures and practices of media self-regulation in several European countries. Hafez (2002) has compared press codes in European and Arab countries. The Worlds of Journalism Study (2018) has included four questions on perceptions of ethics in its 67-country survey of journalists. Wiedemann (1992), Bertrand (1978, 2000), Pöttker and Starck (2003), and, most recently, Puppis (2009) and Fielden (2010) have analyzed the structures and functions of (Western) press councils from a comparative perspective. Apart from the studies highlighted here, nearly all other studies in the field of media accountability analyze the issue from a national perspective. They are not all listed here, but a comprehensive overview can be found in Eberwein et al. (2011). Meier (2009) and Karlsson (2010) have studied media transparency instruments comparatively.

Studies focusing on the impact of MAI are rare as well, and mostly reduce themselves to specific aspects. After an analysis of the U.S. media sector, Campbell (1999) concludes that the examples for self-regulation she looked upon “do not provide a great deal of support for the claimed advantages of self-regulation” (p. 755). European scholars come to a similarly skeptical conclusion (Pöttker, 2010). Qualitative studies with media journalists in the United States and European countries (Fengler, 2003; Malik, 2004; Porlezza, 2005) have shown that even journalists who cover media issues for quality media shy away from criticizing their colleagues and supervisors. Content analyses (Krüger & Müller-Sachse, 1998; Weiß, 2005) similarly came to the conclusion that broadcasting stations tend to criticize the print media and vice versa, often with a political bias with regard to specific industry interests regarding media policy. Studies dealing with ombudsmen (Evers et al., 2009) reveal similar self-imposed restrictions. Given the obvious insufficiency of traditional instruments of media self-regulation—which mainly result from the collective or individual self-interest of media professionals—engaging the audience might be a promising option to strengthen media accountability, but only very few small-scale studies on innovative instruments of media accountability exist so far (Eberwein, 2010; Fengler, 2008; Schönherr, 2008; Wied & Schmidt, 2008). Among the various MAI online, the genre of media-related weblogs is of central significance, because it appears both within and outside of professional journalism. As it has also stimulated the broadest scope of research to date, compared to other innovations in media accountability, it may serve as an example to illustrate the potential of participatory media regulation. The different media blogs can be categorized with the help of a typology developed by Domingo and Heinonen (2008) who distinguish between citizen blogs (written by the public outside of professional journalism), audience blogs (written by media users and other non-journalistic actors within professional journalism), journalist blogs (written by journalists outside of journalistic organizations), and newsroom blogs (written by journalists within journalistic organizations). The hope that media blogs may have a positive influence on journalistic performance is also reflected in the few empirical studies on this topic. Although systematic comparative analyses are rare (e.g., Spiller, Degen, Kronewald, & Guertler, 2016), there are signs that some media watchblogs may in fact have a higher journalistic quality than traditional journalism (e.g., with regard to timeliness, variety, comprehensibility, entertainment, interactivity, and hypermediality; Hutter, 2009). Other studies point out that media criticism in blogs can be a potent means for monitoring the contents and form of journalistic coverage, especially in the area of tabloid journalism (Schönherr, 2008) and that users of media watchblogs may be motivated to reflect on criteria for “good journalism” (Mayer, Mehling, Raabe, Schmidt, & Wied, 2008). In addition, journalist and media blogs can apparently serve as tools for reflecting editorial decisions and generating user feedback (Theis-Berglmair, 2009; Wied & Schmidt, 2008). However, a comparison with the United States shows that even the German media blogosphere is still underdeveloped, particularly with regard to the lack of sustainable business models and possible schemes for self-regulation (Fengler, 2008). This critical assessment is backed by a content analysis (Eberwein, 2010), which demonstrates that a key feature of many German-language media blogs is a lack of continuity in their reporting. A large number of their posts directly relate to news gathered by mainstream media journalists, while the range of topics that they cover is even more limited than that of the media pages in the daily press. Beyond the potentials of media blogs, research on participatory media regulation is much less versatile: A few researchers have fathomed the use of Twitter as a vehicle for TV criticism (e.g., Buschow, Schneider, Carstensen, Heuer, & Schoft, 2013; Wohn & Na, 2011). A group of international researchers has provided several qualitative case studies that investigated further examples of online MAIs in order to find out whether they can correct some of the well-documented deficits of traditional media self-regulation (Heikkilä et al., 2012). Mayer et al. (2008) have surveyed motives and attitudes of 20,000 users of a media blog; Spiller et al. (2016) have explored the professional values of watchblog operators in Germany, Switzerland, Austria, and the United Kingdom. Baldi and Hasebrink (2007) have studied viewer participation in public broadcasting across Europe.

The MediaAcT project (Fengler, Eberwein, Mazzoleni, Porlezza, & Russ-Mohl, 2014) was the first study to provide comprehensive empirical data on the status quo and impact of MA in 14 countries with different media systems and journalism cultures. The project included an analysis of the status quo of media self-regulation and media accountability in Europe and two exemplary Arab states and interviews with 100 international experts in the field of online media accountability. A quantitative survey of 1,762 journalists in 14 countries studied journalists’ attitudes toward media accountability as well as the impact of established and innovative MAI in different media systems (Fengler et al., 2014). The follow-up project European Handbook of Media Accountability (Eberwein et al., 2017) contains country reports on the status quo of media accountability in all 33 states. The qualitative analysis is supplemented by the European Index of Media Accountability, created to measure and monitor national media accountability structures based on the judgments of national experts in the fields of media self-regulation and communication research. A Global Handbook of Media Accountability is currently being edited by the same team of authors.

The MediaAcT journalists’ survey in 12 European Union member states as well as two exemplary Arab countries (Tunisia and Jordan) has revealed sharp contradictions: Even though journalists across countries unanimously support the statement “Journalistic responsibility is a prerequisite for press freedom,” journalists’ actual support for the concept of media self-regulation is mediocre at best in most countries. Journalists only ascribe a medium or even rather weak impact to press councils, media criticism in the mass media, ombudsmen, media blogs, and the other MAI. Obviously, European journalists in many countries question the effectiveness of the existing media self-regulation practices. The survey results also reveal another telling fact: Journalists perceive those MAI that indeed have the potential to endanger their personal professional lives as much more powerful than all the instruments on the professional level. In almost all of the 14 countries involved in the study, journalists see ethical guidelines established by their newsroom and media laws as the most influential instruments of media accountability. In comparison, traditional instruments of media self-control, such as press councils and press codes, are perceived as considerably less influential. In contrast, new instruments of media accountability that have emerged online—such as blogs run by journalists, online ombudsmen, media users’ blogs, and media criticism via Twitter and Facebook—already have an impact on the journalists. Many media professionals across countries observe a notable increase of critical audience feedback online. Especially for journalists in the two Arab countries—affected by their experiences with governmental censorship—the social media dialogue with their audience is important. But while digital MAI obviously have gained prominence, they still lag behind the (limited) relevance of the traditional MAI. Moreover, in many countries there is hardly any culture of criticism within newsrooms: Just a third of all surveyed journalists said they criticized their colleagues often or frequently. Only in a few countries like Finland, where newsrooms are less hierarchically organized, journalists are criticized more often by their colleagues. External criticism by politicians, scientists, or media users is even less appreciated—and often perceived as unfair by journalists.

In central and eastern as well as southern Europe journalists are even more skeptical toward the concept of accountability: Many Spanish and Italian journalists as well as their colleagues from Romania and Poland believe that publishing corrections or making newsroom processes transparent online will damage the bond of trust between journalism and the audience. Journalists from these four countries as well as from Jordan and Tunisia told us with higher than average frequency that they worked for distinctly political-orientated media and therefore felt constrained to support a specific political idea or felt pressured by the government. In those countries journalists as well as media users probably have different expectations of credibility of journalism and an efficient media self-regulation system. While the MediaAcT data clearly show that journalists do not want state intervention—the statement “formal systems of media regulation are open to political abuse” was widely supported by the almost 1,700 journalists who responded to our survey—they perceive the existing instruments as insufficient as well. By contrast industry representatives, in reaction to the U.K. High-Level Group report, claimed that the existing systems of media self-regulation work properly and well. For example, while U.K. industry representatives fired sharply against any form of coregulation, journalists in the United Kingdom gave highest support to the statement “to be effective media self-regulation needs more sanctions.” Obviously, the newsroom makes the difference. Journalists from news outlets who report being praised when they uphold standards even under difficult circumstances, and who report that they would be called in by their supervisors when media users challenge the integrity of their work, value the impact of the different MAI more than their peers who work in newsrooms without such a “culture of accountability.” This means that the newsroom management plays a considerable role when it comes to the ethical awareness of journalists. A series of additional 100 interviews with international experts on media accountability conducted by MediaAcT has confirmed this: “Only enacting the instruments through practices, media accountability actually exists. Instruments, therefore, cannot be taken for granted, and for them to become established practices depends on actors’ attitudes and positions in the field” (Domingo, 2011, p. 10). One can also observe the strong influence of the organization on other issues: Journalists from public broadcasting stations rate the impact of MAI higher than their colleagues from commercial TV and radio. Across hierarchies, freelancers are most reluctant to support the MAI. Media organizations who have pushed toward outsourcing in many European countries now carry a huge responsibility: They have to make sure (in their own interest) that they do not grow a “journalistic precariat” without any ethical awareness. It takes proactive media management to establish a culture of accountability in the newsroom, but it also requires a certain amount of financial stability both on the individual and on the organizational level to be able to “afford” accountable behavior. This is quite a challenge in a time when journalists from many countries consider economic pressure to be the greatest threat to standards in journalism. The responsibility of media companies is even greater in southern and central Europe, where journalists’ unions and federations are less influential than in western and northern Europe. Here, journalists rate the (potential) impact of company code especially high. If media managers actively implement accountability and transparency mechanisms, they could clearly demonstrate that they care for media accountability and thus make any form of state intervention superfluous. Finally, the survey data also points out to the crucial role journalism education plays for responsible journalism. Journalists across countries consider journalism education as more relevant for upholding standards in journalism than any media accountability instrument. Thus investing in journalism education itself is an investment in an accountable press.

Accountability Debates in Media Policy and Media Practice

In recent years, the potential role of media self-regulation and media accountability in preserving press freedom and media plurality has been increasingly discussed among media professionals worldwide and stressed by key political institutions as well. In 2013, the EU High-Level Group on Media Freedom and Pluralism published its final report. The committee was set up in 2011, when the European Parliament was for the first time concerned about a tightening of the media law in Hungary under the Orbán government. Among other recommendations, the High-Level Group suggested drastically expanding the sanctioning potential of existing press councils. It also demanded mandatory media councils in EU states that do not have press councils yet, like France and Romania. Among media practitioners, the Ethical Journalism Network seeks to encourage accountability in newsrooms across the globe. With the ongoing debate in many countries about “fake news” as well as quality and objectivity in journalism, several organizations representing editors, journalists, and media companies initiated a Global Council to Build Trust in Media and Fight Misinformation in 2018. Another international initiative by newsrooms, The Trust Project, was set up in late 2017 to promote media transparency.


This article is based on the author’s numerous prior publications on media accountability. The author wishes to thank Dominik Speck for a critical review of the manuscript.

Further Reading

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  • 1. Excellent overviews over the history of media accountability before World War II are provided by Brown (1974) and Marzolf (1991).

  • 2. MediaAct.