Frequently Asked Questions

The “Media Ownership Monitor” (MOM) has been developed as a mapping tool in order to create a publicly available, continuously updated database that lists owners of all relevant mass media outlets - press, radio, television, and online media.

MOM aims to shed light on the risks to media pluralism caused by media ownership concentration (for more information: Methodology). In order to grasp the national characteristics and detect risk-enhancing or risk-reducing factors for media concentration, MOM also qualitatively assesses the market conditions and legal environment.

Since 2015, MOM has been incubated by Reporter ohne Grenzen e. V. – the German section of the international human rights organization Reporters Without Borders (Reporters sans frontières, RSF), which aims to defend freedom of the press and the right to inform and be informed anywhere in the world.

In 2019, the project was spun-off to the Global Media Registry (GMR), an independent, non-for profit social enterprise registered under German law.

In the Republic of Armenia, GMR collaborated with Hetq, the Investigative Journalists NGO. MOM Armenia was co-funded by Freedom House Armenia and the German Federal Foreign Office’s Eastern Partnership Programme.

Media pluralism is a key aspect of democratic societies as free, independent, and diverse media reflect divergent viewpoints and allow criticism of people in power. Risks to diversity of ideas are caused by media market concentration, when only a few players exert dominant influence on public opinion and raise entrance barriers for other players and perspectives (media ownership concentration). The biggest obstacle to fight it is lack of transparency of media ownership: How can people evaluate the reliability of information, if they don´t know who provides it? How can journalists work properly, if they don´t know who controls the company they work for? And how can media authorities address excessive media concentration, if they don´t know who is behind the media´s steering wheel?

MOM thus aims to create transparency and to answer the question “who eventually controls media content?” in order to raise public awareness, to create a fact base for advocacy to hold political and economic players accountable for the existing conditions.

MOM doesn’t make normative recommendations – it doesn’t suggest how to regulate media ownership. The form of media concentration regulation that can work depends on the context of the country, the existing legal and market conditions, and the ownership landscape.

Instead, MOM provides a transparency tool to enforce a democratic discussion on that issue as well as good governance: decisions are likely to be of higher quality and to better reflect the needs and wishes of the people if they have access to adequate information and broad consultations, with views and opinions freely shared.

Preferably, official data sources, and/or sources with a high level of reliability and trust are used.

Whenever not publicly available, information was directly requested of media companies, public institutions, political representatives and research institutes.

We used mainly data made available by:

• Media outlets/companies
• Court registries
• Television and Radio Commission 
• State Register of Legal Entities of the Ministry of Justice of the Republic of Armenia
• Arlis, The Armenian Legal Information System
• The State Revenue Committee of the Republic of Armenia
• The Central Electoral Commission of the Republic of Armenia
• Corruption Prevention Commission
• Official website of public notices of the Republic of Armenia 
• The National Assembly of the Republic of Armenia
• The Union of Journalists of Armenia
• Yerevan Press Club
• Committee to Protect Freedom of Expression
• Media Initiative Center
• Competition Protection Commission

The main question is: which media outlets influence the opinion-forming process? In order to scan all relevant media, we included all traditional media types (Print, Radio, TV, Online). 

The media were selected according to the following criteria:

• MOM focused on media with the highest reach, measured by audience share. At most 10 media outlets per media type (TV, radio, print, Online) were selected.The news worthy and opinion content.
• The study focuses on general information with a national focus. As such, media with specific thematic focus (music, sport), social networks, search engines and advertisement were excluded.

According to MOM methodology, 10 media outlets with the highest audience share are selected for study in each media market. To identify all relevant media, MOM Armenia included all traditional media types (print, radio, television, online).

However, Armenia's media market lacks comprehensive audience data for online, radio, and print sectors, making standard methodology application challenging. To address this limitation, an Advisory Board was formed, comprised of experts, seasoned journalists, and researchers, to consult throughout the research process. Data were collected from November 2024 through October 2025.

The study focuses on general information with a national focus. Media with specific thematic focus (music, sports, lifestyle, entertainment), social networks, search engines, and advertising platforms were excluded.

• Television: The selection incorporated audience share data from Admosphere's 2024 research on digital television audiences, identifying programs with the largest audiences. Editorial criteria were applied: channels must broadcast news and socio-political content and be actively operating in Armenia. Russian programs rebroadcast on Armenia's public digital multiplex that do not produce content specifically for the Armenian audience were excluded. Ten television stations were selected, including H2, which lost its terrestrial broadcasting license in 2021 but was included based on advisory group recommendations due to its historical significance and continued cable broadcasting.
• Radio: Armenia has no research agency measuring radio audience shares. In the absence of audience data, MOM Team calculated total social media followers across all platforms (Facebook, Instagram, X, LinkedIn, TikTok, Telegram, YouTube) as a proxy for audience reach. Stations with nationwide coverage or Yerevan-based operations were prioritized, as over one-third of Armenia's population resides in the capital. Radio stations featuring political and analytical programming were prioritized as they contribute significantly to public discourse and political awareness. All stations broadcasting news programs were included, even those with limited five-minute news segments. Nine radio stations were selected.
• Print: Armenia has no research agency measuring print readership, and only eight newspapers currently operate in the market. All eight newspapers were selected for the study. The selection applied editorial criteria: publications must have at least weekly frequency, focus on news and socio-political and economic issues, and be published and actively operating in Armenia. The eight newspapers comprise five dailies, two weeklies, and one publication appearing three times per week.
• Online: Selecting the most influential online media outlets is challenging in any market, particularly in markets without comprehensive audience data. Armenia lacks organizations measuring online audience reach. MOM Team used total followers across seven social media platforms (Facebook, Instagram, YouTube, X, LinkedIn, Telegram, TikTok) as a proxy for audience exposure and influence. Understanding that social media metrics might not accurately capture influence, MOM Team consulted the Advisory Board. Political affiliation was not a selection criterion. MOM Team compiled a preliminary list of 24 online media outlets with the largest social media followings. The Advisory Board reviewed this list and expanded it to 32 outlets. From this pool, the top 10 were selected based on total audience. Five additional media outlets were added based on Advisory Board suggestions to ensure the study comprehensively captured Armenia's media ownership patterns. Although the Advisory Board recommended including Hetq online, MOM Team chose not to include it due to ethical considerations and potential conflicts of interest. Fifteen online media outlets were selected.

Transparency about media ownership helps citizens evaluate the information they consume and identify potential biases. In Armenia, where there are no independent agencies measuring radio, print, or online audiences, it's difficult to know which outlets genuinely influence public opinion. Some media and telecommunications company owners face criminal charges, while political connections and concentrated ownership patterns remain largely hidden from public view. Making these connections visible enables citizens to make informed decisions about which sources to trust in a country where media plays a crucial role in democratic discourse.

Media ownership transparency allows one to understand whether a media outlet serves the public or the interests of political or economic groups. Revealing the actual owners can also contribute to increasing trust in the media.

Although Armenian society generally has an idea of the orientation, stance, and affiliations of different media outlets, there is no comprehensive study that reveals the owners, the various intersecting interests, and interconnections.

The MOM is based on a generic methodology that can be applied universally. The pilot phase was conducted in 2015 in Colombia and Cambodia. By 2025, the MOM was implemented in over 27 countries world wide with fresh updates in the Philippines, Albania, Serbia, Lebanon and Germany. Ireland was the first EU country where MOM was implemented. Germany was the second EU country to feature in the MOM family.

Absence of audience measurement data: Armenia lacks independent audience measurement for radio, print, and online media. For television, Admosphere provides audience data, but these figures are disputed by some media owners and industry experts. This absence of reliable audience data made it impossible to calculate market concentration based on audience share for most media sector.

Financial data limitations: Market concentration based on revenue share could not be calculated for any media sector. Although Armenian law requires all media companies to publish their revenue data, financial information is not available for all companies, making it impossible to calculate total market size and individual market shares. Additionally, when financial statements are available, they are not always outlet-specific, as many media companies generate revenues from multiple business activities. Some outlets are not registered as separate legal entities, making it impossible to isolate their financial performance.

Public spending opacity: Government spending on media through advertising and subsidies is not transparent. Public funds spent on media cannot be accurately identified because they are not consistently labeled as advertising or media support in budget documentation.

Proxy ownership: Several media outlets employ proxy individuals to conceal the identity of actual owners. In certain cases, identifying real owners was not possible using publicly available sources. Armenia's recently introduced beneficial ownership system does not ensure full disclosure, as the State Register of Legal Entities lacks sufficient resources and verification tools to detect potential falsifications.

Incomplete State Register data: Inaccuracies and outdated information in the State Register required extensive additional verification efforts. Some companies that carried out media activities were no longer operating but remained listed in official records without updates.

Limited biographical information: Many media outlets do not maintain an About Us section on their websites with basic organizational information. In numerous cases, obtaining biographical details about owners, founders, or editors was not possible, limiting the completeness of ownership profiles.

Resource constraints: Some research, particularly into diverse local markets and hidden ownership structures, would require more time and resources than available for this study. This is especially true for tracing complex ownership chains and beneficial ownership relationships.

This database presents the current state of the media in Armenia. The project aims to generate a public debate and changes, particularly on the following topics:

• Media transparency
• the economic situation
• Political affiliations

The Media Ownership Monitor is mainly inspired by two similar projects. The indicators for a later ranking rely heavily on the EU-funded Media Pluralism Monitor of the Centre for Media Pluralism and Media Freedom (CMPF) at the European University Institute (EUI, Florence). Similarly, Media Pedia, an ownership database developed by investigative journalists in Macedonia, served as inspiration for the Media Ownership Monitor. You can find an overview of other similar projects in the table below.