Indicators of Risks to Media Pluralism

Why?

Television: The TV market shows the highest audience concentration with the four major companies reaching 80% of the audience in 2024. The outlets include MTV, owned primarily by the Murr Family, LBC, majority owned by Pierre Daher, Al-Manar, owned exclusively by Hezbollah, and Al-Jadeed, majority owned by the Khayat family. The first three outlets alone gather almost 69% of the audience.

Radio: Compared to other sectors, radio outlets demonstrate relatively more dispersion and spread. Nevertheless, the most noteworthy aspect of this form of market-audience concentration, as opposed to the case of TV stations, is that all of these radio stations, with the exception of VDTL, are very explicitly affiliated with political parties or figures. These include but aren’t restricted to Al-Nour, owned exclusively by Hezbollah, Radio Liban Libre, owned exclusively by the Lebanese Forces, Sawt El Shaab, owned primarily by the Lebanese Communist Party, Radio Orient, owned almost exclusively by the Hariri family. In other words, while the market is more diverse, there are not many windows of opportunity on the level of access and licensing for alternative outlets. It is important to take note that most participants (65%) mentioned that they do not listen to the radio. If we take this out of the sample, we are left with the top 4 radio companies (Radio Liban Libre, Al-Nour, Sawt El Shaab, and Radio Orient) occupying around 54% of the audience share. 

Print: Given the decrease in print readership and prevalence over the years (72% of the participants do not read paper/print newspapers whatsoever), a very select number of outlets were able to retain their presence. These include but are not restricted to Annahar, owned primarily by the Tuéni family and Hariri family, Al-Akhbar, owned primarily by Ibrahim Al-Amine and Youssef Wehbi, Addiyar, owned primarily by Charles Ayoub, and L’Orient-Le Jour, owned primarily by the Eddé family, the Choueiri group, and the Pharaon family, all together dominating almost the entirety of print readers (with only 3% for retained for alternatives). It is important to note that all of these outlets now have online presence too.

Online: 

ELKA did not measure the audience data for particular online outlets, and so this data is unavailable, which in of itself is suggestive of a high risk issue. 

Source: ELKA Lebanon.

Why?

In Lebanon companies, despite particular regulations officially ensuring some level of financial transparency, regulations are not applied consistently. Hence, no financial information is available on specific horizontal markets, such as television, online, print and radio. Therefore, ownership concentration in horizontal markets cannot be computed. In accordance with our 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 - the revenue data is considered optional.

Why?

Generally, monopolistic practices are regulated by the Lebanese commercial legislation (mainly article 14 of Legislative decree No. 73 of 1983), but there is nothing specific to the media sector. There is no administrative authority or judicial body monitoring compliance with the threshold in the broadcast, online or print sector. Criminal courts theoretically enforce the articles against monopolistic practices of the commercial legislation.

Media ownership concentration is largely addressed through the 1962 Press Law and the 1994 Audiovisual Media Law. According to the 1962 Press Law, the owner and all shareholders of a media company must be Lebanese citizens. Article 31 also states that one person is allowed own a newspaper. According to the 1994 Audiovisual Media Law, any person or entity cannot own, directly or indirectly, more than 10% of the total shareholding of a single broadcast media station. However, this provision is circumvented in several instances.

In the broadcast sector (TV and Radio), the National Media Council studies licensing requests. It monitors the performance of media bodies, submits reports to the Ministry of Information on the TV and radio programs and news content, submits recommendations to the Council of Ministers, and works on drafting laws and regulations.

The print sector is formally organized into two bodies: the Lebanese Press Order for owners and the Lebanese Press Editors Syndicate for editors and journalists. There is, however, no administrative authority or judicial body actively monitoring compliance with the media concentration regulations. The 1962 Press Law requires that any newspaper or periodical that wants to publish news on political events must first obtain a legislative decree granting it a Category 1 licence.

Ownership concentration in the online sector is not regulated. The Telecommunications Regulatory Agency (TRA) is the only agency regulating the spectrum and attributing licences to Internet Service Providers (ISPs), but in fact the TRA has been suspended and its powers transferred to the Ministry of Telecommunications.

Score: 8 out of 20 (25%)

 Source: Legal Assessment 

Why?


We are unable to identify the top 8 firms with the highest revenue across all media sectors (TV, radio, newspapers, and online content providers) due to lack of financial data. Instead, this indicator is calculated based on audience shares and as such, the results presented are not an indicator of economic strength in different media sectors but rather for the potential influence on public opinion. The MOM team identified five major owners holding shares in media outlets across television, radio, and print sectors based on audience share. Almost all of the selected media outlets have online editions. However, as of now, due to the lack of online audience data, we are unable to calculate their reach through online platforms. Therefore, the actual cross-media audience share would exceed the findings whenever media owners also run online outlets. Therefore, the data provided might not show the full picture or could even be an underestimation of the real audience reach and potential influence on public opinion these owners might have. No audience share has been used since we lack this data in the online sector, but the media specific audience share was used when calculating in comparison to the overall media market. However, from observation, we can identify certain owners who have activities in more than one media sector and outlet. Media consumption is much different in Lebanon than other developing countries; people tend to watch TV much more than listen to radio or read newspapers. Different media sectors have different relevance and therefore weight and influence in Lebanese society.

These entities and/or families include the Hariri family, Mikati family, who own major shares in media outlets in the TV and online sector, the Lebanese State, which owns a TV station and a radio station (in addition to the National News Agency), Hezbollah, which owns media outlets in the radio and TV sectors through the Lebanese Communication Group L.C.G. SAL, and the Lebanese Forces, which own media outlets in the radio and online sector.

The Hariri Family; their audience combines:
16% of the print audience through Annahar, and 3% of the radio audience through Radio Orient.

The Mikati family, who own major shares in media outlets in the TV. Their audience combines: 13% of the TV audience through LBC.

The Lebanese State, which owns a TV station and a radio station (in addition to the National News Agency). Their audience combines: 1% of TV audience through Télé Liban, and 3% of radio audience through Radio Liban.

Hezbollah, which owns media outlets in the radio and TV sectors through the Lebanese Communication Group L.C.G. SAL, in addition to Al Ahed news website. Their audience combines: 5% of the radio audience through Al-Nour, and 11% of the TV audience through Al-Manar, in addition to the audience reached through the online platforms associated with the media outlets, which cannot be identified in numbers.

The Lebanese Forces, which own media outlets in the radio, print (Al-Massira magazine) and online sector. Their audience combines: 7% of the radio audience through Radio Liban Libre, in addition to the audience reached through the online platforms associated with the media outlets, which cannot be identified in numbers.

Summation: 59% 

Source: ELKA Lebanon.

There is no authority actively monitoring cross-media ownership. Generally, monopolistic practices are regulated by the Lebanese commercial legislation (mainly article 14 of Legislative Decree No. 73 of 1983). However, no regulation deals specifically with media concentration. Media ownership concentration is largely addressed through the 1962 Press Law and the 1994 Audiovisual Media Law. According to article 12 of the 1994 Audiovisual Media Law, a company is allowed to own a maximum of two broadcast companies simultaneously: one TV and one radio station. It cannot own two TV stations or two radio stations. This restriction applies only to TV and radio and there is no mention related to ownership of cable, internet, and newspapers. There is no mention either of a limitation of market share. As such, it is on paper possible for a company to own a license for a TV and a radio that can cover 99% of the market. It would also be possible for this company to own all newspapers and internet service providers (ISPs) in the country.

The 1962 Press Law does not deal with any form of cross-media ownership concentration. Generally, the commercial law is enforced based on the political and/or financial power of the respondent but there has not been any judicial case related to media mergers and cross-ownership. Nevertheless, the National Audiovisual Media Council does claim to ensure the compliance of companies that own media outlets with legal requirements, including ownership conditions. The council is relatively effective.

Score: 1 out of 8 (12.5%)
 

Source: Legal Assessment

Why?

There is no obligation for media companies to disclose their ownership structures on their respective websites or printed publications. Most of the data related to ownership was obtained through the Commercial Register at the Ministry of Justice. There is currently no legal instrument in Lebanon that mandates for political actors to disclose their affiliation with media companies. Similarly, there is no legislation that prohibits conflict of interest to prevent political actors from holding political office while owning a media outlet. However, like all companies and businesses in Lebanon, media companies have to be registered at the Commercial Register. Each company profile, which includes the list of owners and the shares they hold, is available for a price of LBP 300,000 ($3.35 US - May 2024).

In order to complete missing data, which was available neither online nor offline, all media outlets included in this study (35) were contacted – through the media outlet and through the company – with a questionnaire. Four Lebanese media outlets out of the total sampled were actively transparent (11.4%). This means four media outlets published financial and/or ownership information on their websites or in publicly accessible reports: the state-owned Radio Liban, the print and online paper L’Orient-Le Jour, and two online independent media outlets: Daraj Media and Megaphone News. Passive transparency was also low (8.6%). Passive transparency refers to outlets that provide information in response to our request. The list includes Al-Liwaa, Voix du Liban 100.3, and Lebanon Debate.

For the majority of media outlets (68.5%), data was publicly available (24 outlets out of 35) at the Commercial Register. However, the quality of the official company profiles was poor and data was often obviously outdated, with changes in ownership not recorded, despite the efforts of researchers in SKF and our partners in SEEDS for Legal Initiatives. Data was assessed unavailable for 4 media outlets (Fajr Radio, Sawt Beirut International, Ya Sour, and Saida Online). Although names of the shareholders were registered, a lot of names were not available at the Commercial Register, despite this being required by law. No company actively disguised the ownership structure, e.g. through bogus companies. However, the MOM team found various ownership set-ups/patterns which demonstrate family links and party affiliations, rather than individual ownership, even when this is officially concealed.

MOM information requests were sent out by email and were followed up with further emails during the course of the research. However, only eight outlets have provided detailed replies to our requests in written form, via email or through phone calls. These outlets are: L’Orient-Le Jour, Nidaa Al Watan, Voix de Tout le Liban 93.3, Al-Nour, Al-Manar, MTV, Megaphone, and Daraj. 

Active Transparency – 11.4% of outlets in the sample

Passive Transparency – 8.6% of outlets in the sample

Data Publicly Available – 68.5% of outlets in the sample

Data Unavailable – 11.4% of outlets in the sample

Why?

All Lebanese companies are required to register their minutes of meetings with the Commercial Register with no specific requirements for media companies. Companies that do not register their minutes are fined for each month and/or year of delay by the Ministry of Finance and the Commercial Register, operating under the Ministry of Justice. For transfers of shares and new members, registration is not immediately required, and if a change in the management of the company (director, board of directors, chairman) is not recorded, companies are not fined. However, they cannot move on with any other procedure requiring registration before the minutes of the meeting related to the change in the management are registered.

Audiovisual Media Law No. 382 of 1994 requires broadcast corporations (TV and radio) to submit their financial accounts every six months to the Ministry of Information. These accounts include the amounts or revenues arising from the corporation’s activity. Directors who refrain from submitting the company’s said reports are liable to prosecution (three to six-month prison sentence and/or LBP 10 to 30 million fine) Law of the Right to Information of 2017. It enables anyone, being an individual or an entity, to obtain information and documents held by government services. The scope of the law excludes private life and military secret matters, and judicial decisions related to minors and personal status. Implementation decrees are still on hold.

Score: 4 out of 5 (80%)

Source: Legal Assessment 

Why?

In Lebanon, politics and media have very close ties as the licenses were often attributed in a way that reflects the diversity of political views in the country. Most of the media owners are directly or indirectly politically affiliated and allegiances and indirect affiliations shift with financial needs. This is the reason why the risk of political control of media outlets and distribution networks is assessed as high for media pluralism. For example, most of the outlets that are not directly controlled by a political party adopt editorial lines that support a political group or a strong political leader. You can read more information about the political affiliations here.

Out of the owners listed, 69% are politically affiliated. This also involves more than 80% of the outlets surveyed. The TV sector is the most politically affiliated, as all eight outlets have direct connections with the State, political parties, and currently active or aspiring politicians. One channel is state-owned. Four are owned or co-owned by currently active politicians, and while three TV channels do not have a direct affiliation to a political party, they are co-owned by business figures who have sought political office. As a whole, politically affiliated owners reach 100% of the audience.

The print sector’s dailies are almost all linked to political players. Al Mustaqbal (discontinued), Annahar, Al Joumhouria, L’Orient Le Jour, and Al-Akhbar have among their owners current and former Members of Parliament and the executive; Al-Binaa is owned by a political party, and Addiyar and Al-Liwaa are owned by individuals who have run for office. This represents at least 99% of the readership.

The radio sector is also very politicized with eight stations out of 9 stations owned/controlled by a specific political party, politician or political grouping, or by an owner with a specific political affiliation. While online news is a sector where political affiliations are also very clear, as all political parties represented in Parliament have their own political website serving as a news platform, it also has allowed for more diversity, providing a space for alternative media to flourish.  Five out of the 11 selected outlets have politically affiliated owners.

Political affiliations of media owners

• The Lebanese State (Radio Liban, Télé Liban): the State’s legal monopoly on broadcasting ended in 1994 with the implementation of the Audiovisual Media Law, making Lebanon the first country in the Middle East to establish a regulatory system for permitting private radio and television broadcasting to be both produced and distributed within its borders. 

• The Phalange Party (Voix du Liban): ten co-owners, including eight high-ranking officials of the party, formally own the company on behalf of the actual party.

• The Lebanese Forces (Radio Liban Libre, Lebanese-forces.com): among the 17 co-owners of the company owning Radio Liban Libre, 11 are officials of the party. The Lebanese Forces party is also the official owner and editor of the party’s website.

• The Lebanese Communist Party (Sawt El Shaab): while the legal set-up of the radio and the licensed company does not indicate direct ownership by the Lebanese Communist Party, most shareholders and administrators are affiliated with the party and do not hide the link between the radio and the party.

• Hezbollah (Al Nour, Al Manar): members of the board of the Lebanese Communication Group L.C.G SAL are all high-ranking Hezbollah officials, including two former Members of Parliament, Abdallah Kassir and Mohammad Haidar.

• The Hariri Family (Radio Orient, Future TV (discontinued), Al Mustaqbal (discontinued), The Daily Star (discontinued), and Annahar), led by Prime Minister Saad Hariri, president of the Future Movement. In these different outlets, additional shareholders are close allies of the family and/or belong to the same political party. The administrations of the outlets do not have links with the party structure but with the Hariri family directly.

• Aoun Family (OTV):  the family of the former President of the Lebanese Republic Michel Aoun, founder of the Free Patriotic Movement (FPM), owns 12.8% of the OTV Holding shares, and 50% of Alubnaniah lil Ilam, which owns OTV’s broadcasting license. OTV Holding is the only media company that opened shares to the public and most of the public owners are FPM affiliated.

• Elias Bou Saab (Sawt El Mada) is an MP of the FPM and current Deputy Speaker of Parliament, and owns 99% of the radio’s shares.

• The influence of FPM is reinforced through Tayyar.org, which is the official party website, however not officially registered as a separate company.

• The Berri Family (NBN): members of the family of Parliament Speaker and Amal Movement leader Nabih Berri appear in the ownership structure of the TV station (19.2%), alongside members of the Hamdan Family, which include close political allies of Nabih Berri, among whom his media advisor Ali Hamdan.

• The Tuéni Family (Annahar): The family established Annahar and today holds around 20% of the shares. The Tuéni family has been historically involved in Lebanese politics, and is also connected to current Education Minister Marwan Hamadé (affiliated to the Progressive Socialist Party), the brother-in-law of late Annahar CEO Ghassan Tuéni.

• Michel Elias Murr Family (Al Joumhouria), which is also connected to the Tuéni family (Michel Elias Murr being the grandfather of current Annahar CEO Nayla Tuéni), and to the other branches of the Murr family (owning respectively MTV and El-Nashra).

• The Eddé Family (L’Orient Le Jour): former Minister Michel Eddé served in several cabinets, the latest were led by former Prime Minister Rafik Hariri in the 1990s.

• The Pharaon Family (L’Orient Le Jour): former Minister of State for Planning Michel Pharaon is a close ally of the Lebanese Forces.

• The Mikati Family (Lebanon24, LBCI): Najib Mikati is the current Prime Minister of Lebanon. He also served twice as Lebanon Prime Minister in 2005 and from 2011 to 2013.

• The Gabriel Murr Family (MTV): Gabriel Murr ran for Parliament in 2002, and is the brother of Michel Elias Murr.

• Abdallah Zakhem (Al Jadeed): ran for Parliament in 2018. He is known to be close to the Marada Movement.

• Nizar Younes (Al Jadeed): ran for the 2000 elections and his brother for the 2005 elections. 

• Issam Fares (LBCI) is a former Deputy Prime Minister.

• William Mjalli (NBN) is the Director of former Deputy Prime Minister Issam Fares’ charity foundation.

• Hani Hammoud (Future TV) is a member of former Prime Minister’s Saad Hariri staff and is affiliated with the Future Movement.

• Kassem Soueid (NBN) is affiliated to the Amal Movement.

• Mustapha El Husseini (Al-Akhbar) was a Member of Parliament, who owns with his children Sun Press S.A.L, controlling 18.8% of the shares of Akhbar Beirut S.A.L.

And while the main owners of Al-Akhbar (Ibrahim Al Amine) and Al Jadeed (Tahseen Khayat) are not formally members of any party, they are very active political players and commentators, with strong and public political leanings.

8.1 - 3 (Audience share controlled by political parties/politically-affiliated persons: 100%)

8.2 - 3 (Audience share controlled by political parties/politically-affiliated persons: 100%)

8.3 - 3 (Audience share controlled by political parties/politically-affiliated persons: 100%)
8.5 - 3 (Very few outlets have open databases which clarify their ownership sources)
8.6 - 3 (Official regulation mechanisms are ineffective and not applied)
8.7 - 3 (Editorial directions are determined and motivated by the interests and considerations of political sponsors)
8.8 - 3 (The vast majority of outlets do not claim, systematically, or based in any criteria, editorial independence) 

Score: 3 + 3 + 3 + 3 + 3 + 3 + 3 = 21 -> 21/7= 3

Wannous, S. (2023). Changing the narrative: alternative media bias and its ties to political economy.
MEGAPHONE: SOCIAL-MEDIA-NATIVE OUTLETS BETWEEN EDITORIAL INDEPENDENCE AND ALGORITHMIC CONSTRAINTS

Why?

The distribution network for print publications consists of a number of independent newspaper agencies (and sub agencies) located throughout the country that have been functioning for several years. These agencies are not exclusive to specific newspaper publications, instead they are shared among several, and often unrelated, newspaper companies, and work on a commission or subscription basis.

Radio networks distribution rely on the frequencies that are allocated by the Telecommunications Regulatory Authority (TRA) which is an independent public institution.

TV networks distribution rely on the frequencies that are allocated by the Council of Ministers. But given that the vast majority of households receive TV through legal or clandestine cable subscription, some cases of political discrimination have been reported. Al Jadeed was banned in the southern suburb of Beirut, a region broadly loyal to Hezbollah and the Amal Movement, after the TV channel mocked Parliament Speaker Nabih Berri in a comedy program called “Doma Karasi”. Cases of TV stations being cut off in some regions because of political disagreements are not rare.

Internet Service Providers are the distribution networks behind the internet. Most of the internet distribution is controlled by the State through its contractor Ogero, which has by the most conservative estimates, over 60% of the market for Internet service provision - naturally, Ogero has always had an inherent competitive advantage over the private sector. Private operators are allowed to compete with Ogero. Score: 1.83

Why?

There  is  no  culture  and  practice  of  state  advertising  in  Lebanon,  hence  no  specific  rule  of  distribution  of  state  advertising. Government  institutions  have  their  public  service  announcements  aired  for  free  on  all  private  and  public  TV  stations.  Official  announcements  of  legal  and  regulatory  matters  are  also  published  in  all  newspapers,  without  discrimination.  Meanwhile,  state-owned  institutions  (Middle  East  Airlines,  Casino  du  Liban,  Ogero,  the  National  Lottery...)  have  their  advertisements  aired  for  a  fee,  but  go  through  the  advertising  agencies  similarly  to  any  private-sector  enterprise  that  wants to  advertise  in  the  media. Although  the  MOM  team  wasn’t  able  to  reach  any  data  on  the  share  of  State  advertising  in  the  market,  the  risk  of  control  of  the  state  over  media  funding  should  be  assessed  as  low. The  MOM  team,  however,  assessed  the  political  control  over  media  funding  as  a  high  risk  for  media  pluralism. There  are  no  rules  or  guidelines  to  ensure  that  State  advertising  is  fairly  distributed  based  on  circulation  figures,  nor  are  there  any  mechanisms  in  place  to  monitor  the  distribution  of  State  advertising. Political  funding  of  media  outlets  is  rather  linked  to  the  political  affiliations  of  their  owners.  Their  funding  shifts  as  their  allegiance  changes.  Almost  the  entirety  of  the  covered  media  outlets  (with the exception of some online outlets) is  politically  affiliated. Lebanese  media  have  been  receiving  funding  from  foreign  investors,  who  pursue  their  interest  in  the  country’s  politics  –  especially  in  the  print  sector   –  putting  them  at  risk  and  even  shutting  them  down  when  foreign  powers  don’t  fund  them  anymore.  Open  calls  have  been  made  to  request  foreign  funding.

Why?

Although the scoring indicates a risk for net neutrality, it mainly reflects the fact that the concept of net neutrality is not defined in the Lebanese law, and as such is not addressed at all. There is no policy or bill pending on the issue in order to protect it. In the absence of a formal law or any other form of regulation explicitly protecting net neutrality, we focus on examining how net neutrality principles are addressed. The risk is therefore assessed as medium for the following reasons:

While net neutrality is not protected, the Telecommunications Law of 2002 deals with telecommunication service distribution and Internet Service Providers’ (ISP) licensing procedures:

• Article 19 (1) provides that licenses for basic telecom, international and mobile services are granted by decree issued by the Council of Ministers, upon recommendation of the Minister of Telecommunications, after an international public auction organized by the Telecommunications Regulatory Authority (TRA).

• Article 26 requires public telecom services to comply with universal service obligations that ensure a minimum level of comprehensive geographic coverage in the provision of telecommunication services.

• Article 25 guarantees certain minimum standards of quality, including call completion rates and dial tone delays.

However, the TRA has been suspended in 2015 by then-Minister of Telecommunications Boutros Harb following a 2011 decision from the State Shura Council, the country’s highest administrative court. As such, the Ministry of Telecommunications controls and manages the Internet services directly by licensing ISPs, granting them access to Internet capacity, and by acting as an ISP through Ogero in parallel to the private sector. As the main operator of the fixed telecommunications network in Lebanon, Ogero has to follow some international standards and should therefore apply net neutrality as voted by the FCC.

In terms of blocking content, the Lebanese legislation is very loose in this field. While there is no prohibition of blocking access to online content as a principle, blocking access to a website requires a motivated judiciary decision, after request from official authorities and security agencies to the Ministry of Telecommunications. Only online gambling sites are blocked in Lebanon in order to preserve the monopoly granted to the National Lottery (La Libanaise des Jeux) and to Casino du Liban.  

Score: 2.86

Why?

Over the years, the Samir Kassir Foundation has conducted a number of studies and reports which concern the socio-economic and bodily autonomy and protection of women journalists in the workforce. More recently, a report released in late February of 2024 outlines the professional and personal challenges faced by women journalists in Lebanon, shedding light on their labor rights, such as salaries, promotions, and vacations, as well as the various discomforts they encounter within the field. Based on the investigative and in-depth interview process conducted by our researchers, we conclude: “The situation for female journalists in Lebanon reveals a complex landscape marked by numerous challenges and deficiencies within institutions.

Despite efforts to address issues such as sexual harassment and unequal treatment, there remains a pervasive lack of accountability and support mechanisms. Female journalists face obstacles such as limited access to paid leave, concerns about confidentiality and safety, and a lack of effective recourse for addressing harassment and abuse of power. While there may be some recognition of the need to improve conditions for female journalists, tangible progress is hindered by systemic issues and entrenched power dynamics.

Moving forward, concerted efforts are needed to enact meaningful reforms, promote gender equality, and create a safer and more supportive environment for female journalists in Lebanon.” As for the women in positions of power or authority in media outlets, there are only a very few model examples, particularly present amongst some of the pioneering alternative online media outlets, such as Megaphone News and Daraj Media. They are accompanied by some exceptions of traditional outlets such as Annahar, managed by Nayla Tuéni, and Al-Jadeed, whose Editor-in-Chief is Mariam Al-Bassam.

The Struggles of Women Journalists in Lebanon
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