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Building News Sustainability

How can public policy addressing economic support for news enable independent, competitive journalism without creating political or legacy bias?

LAST UPDATED: December 01, 2023

CNTI's Summary

Independent journalism is critical to functioning democracies. As the global news industry largely continues to face financial struggles, governments have responded with a range of policy initiatives to provide economic support to commercial, public and local news media. Among these, recent media bargaining legislation in Australia and Canada has become the starting point for policy debates in many parts of the world. These policy debates bring several challenges to light, including tensions between the news as a public good versus a market product, the role of public policy in compensating for market forces and the risk of increasing media dependence on, and undue influence from, governments and platforms. Policy aiming to support the economic sustainability of news media cannot be one-size-fits-all; it must be context-sensitive and protect media independence, free expression and an open internet.

The Issue

For decades, the commercial business model of bundled news with embedded advertising generated high profitability for publishers. The internet gave rise to new structures for news consumption as well as new and more targeted ways for advertisers to reach people. As the digital landscape evolved and more of the public moved online, the traditional news business model became obsolete and the news industry plunged into financial crisis.

Simultaneously, the role of news publishers began to change, particularly when it came to distribution of news. While the advent of digital platforms (primarily social media and search engines) broadened news publishers’ access to potential audiences, it also left publishers more dependent on these intermediaries.

Amid these changes, the news industry has made efforts to develop new business models such as building digital subscribers, donations, grants, membership events and other means of funding. While there have been some successes, the news industry has not been able to generate the levels of revenue it had previously enjoyed. Because news is critical to functioning democracies, governments and civil society have responded to economic challenges in the news industry with a range of policy initiatives aimed at providing financial support.

When it comes to commercial news media, a range of proposals to provide financial support exist, but most notable are recent media bargaining legislation in Australia and Canada, which have inspired policy debates in many parts of the world. Earlier attempts to provide financial support for news were often based on copyright law, but these policies are based on competition (antitrust) law, requiring digital platforms to negotiate payment to news publishers on the grounds that platforms have financially benefited from digital advertising by providing links to publisher content without due compensation. Other efforts, such as in the U.S., aim to create exemptions to antitrust law to bring technology companies to the bargaining table.

In response to some of this legislation, technology companies such as Meta and Google have begun to shift away from news altogether, calling the legislation unworkable for a number of reasons, including concerns over their own financial liabilities. This shift away from news would almost certainly harm publishers’ (and particularly smaller publishers’) ability to reach audiences and inhibit the public’s ability to access legitimate news sources and information.

There are also ongoing policy debates surrounding what is perhaps the most substantial form of direct government intervention in the news industry: support for public service media. In many democracies, public media sit at the center of the news ecosystem, making them key players in debates around public policy aimed at enabling independent, competitive journalism. However, public media also continue to face many of the same threats as the commercial news industry, including challenges with digital transitions, decades of budget cuts and, in some cases, political attacks. As we address later in this primer, policy discussions surrounding public versus commercial news media support are often siloed or considered at odds with one another (despite little to no evidence to date supporting the theory that public media support ‘crowds out’ or shrinks commercial news audiences).

Attempts to regulate economic support for the news industry introduce difficult but critical questions about the balance between news as a public good versus a market product, the role of public or local media and freelance journalists in the news ecosystem, the tension between content neutrality and curbing mis- and disinformation, the challenge of making complex and proprietary platform infrastructures publicly governable and accountable, the potential implications of government involvement in news media revenue structures and the role of public policy in compensating for market forces (versus changing them) in the public interest.

It is critical to address the economic sustainability of the news industry, which includes promoting a pluralistic, diverse and innovative media ecosystem, local and public news, and broader public access to news. However, these multistakeholder conversations must be guided by evidence-based practices that reflect strengths and weaknesses of policy-driven news support, with an eye toward media independence, plurality and transparency.

What Makes It Complex

These debates raise the broader question of whether, or to what extent, governments can and should save independent journalism from financial crisis.

Democratic governments are obligated to protect fundamental rights, including the basic freedom to access and share information. However, protecting free expression alone is not enough to sustain the news media. Strong legal protections of the press in countries like South Africa and the U.S. have not protected their news industries from financial struggles. Policymakers can help to enable an environment supportive of an independent, competitive press – if they are willing to commit resources to these efforts, prioritize strong governance and protect editorial independence.

Legislation must be sensitive to a country’s context and media environment, which makes replicable or one-size-fits-all approaches ineffective.

While early efforts to address the economic sustainability of news media can help inform approaches in other parts of the world, there are also lessons to be learned beyond these narrow (i.e., largely Global North) contexts. Approaches to developing domestic policy must consider the specific country’s media environment and history. For example, histories of governmental press control or low levels of institutional trust may influence some countries’ approaches to or perceptions of government involvement in funding or supporting news media. Other challenges, particularly for emerging democracies, may include less instructive experience, limited support and resources, weakened civil society, and government control of media associations or press councils that would shepherd such changes or existing legal structures (e.g., laws preventing tax revenue from going toward news media).

Holistic solutions for media sustainability may not be possible, or even preferred, but piecemeal responses may make it more difficult to create lasting solutions or to measure success.

For instance, despite evidence that countries with well-funded, independent public media consistently have stronger democratic outcomes, public media (as well as local media) are often dealt with in separate policy initiatives from commercial news media. Public service media are, in theory, meant to serve the whole public, meaning that – when truly independent – they can play a key role in providing free public access to information and making attempts to combat disinformation. Countries that address commercial media sustainability but do not address public or local media sustainability risk perpetuating existing inequalities in news access and diversity and continuing to serve audiences who are already better-served.

If a primary concern driving legislation is to address news publishers’ increased dependence on digital platforms, it is especially critical to ensure that legislation does not inadvertently create more dependence on, provide more power to or constrain scrutiny of these companies.

Legislative policy that puts platforms in charge of negotiating with news organizations risks decisions made based on commercial interests. Further, if news publishers rely financially on payments from major technology companies, it would be reasonable to worry that publishers may not scrutinize these companies through news coverage as much as they would absent their financial relationships. There is also a question of how sustainable some policies may be if they create financial dependence on digital platforms that may or may not last, as digital habits and interests shift, both among the public and among platform companies who may simply choose to shift away from news content at any time.

It is important that these policy decisions do not jeopardize media independence or introduce new opportunities for undue political influence on publishers.

Legislation that puts governments in charge of determining who qualifies as a news organization and how news revenue is structured risks politically motivated decisions and loss of journalistic independence. These risks must be considered even in countries where the current government supports an independent news media, as ruling parties can – and indeed do – change, such as in Nicaragua and Serbia. Policymakers must consider the risks of media capture, including how to prevent political influence from determining which publishers succeed in the media market as well as how to ensure media plurality.

It is unclear to what degree certain policies will actually bolster news reporting or support news innovation and a diverse, competitive news environment.

Current policy approaches largely benefit legacy and large news publishers at the expense of smaller independent or local ones. The policies often lack full transparency, equal collective bargaining rights for smaller or independent publishers and other mechanisms that would ensure diverse distribution of funding. While policymakers in some countries have attempted to resolve these issues by allowing for collective bargaining, these policies usually leave smaller or independent publishers and freelancers unequally served. These smaller, typically digital-first startups are often paving the way for news innovation, thus, policies that are destructive to these smaller independent publishers suppress the emergence of new business models which are essential to the success of the news industry as a whole. Further, even among those who agree that technology companies should pay for facilitating access to news on their platforms, there remains a lack of consensus over how or where that money should be spent by publishers.

Content-neutral funding initiatives can undermine efforts to curb mis- and disinformation.

Some media bargaining codes risk funding purveyors of disinformation due to a) efforts to maintain neutrality in who qualifies for funding, and b) using publisher reach or traffic as a key criteria for bargaining structures. This challenge is exacerbated by the difficulty of defining or measuring news “quality” (see more discussion of this in a separate issue primer). It is critical that considerations of content neutrality in policy-driven economic support for news weigh the opportunities of promoting a diverse media environment against the threats of potentially incentivizing or directly funding disinformation or clickbait.

State of Research

As CNTI notes in other issue primers, a breadth of research in recent years has emphasized both the global news industry’s continued struggle with the transition to a digital and mobile media environment and publishers’ evolving relationship with, and dependency on, platform companies.

One segment of this research is specifically concentrated around policy-driven economic support for news. Much of this recent work centers on three key areas:

  • Systematic evidence of the impact of platforms (and platform changes) on publishers and the public.
  • Evaluations of existing cases of media sustainability legislation, including Australia’s News Media Bargaining Code and Canada’s tax credits.
  • Evaluations of a broader set of initiatives with the aim of supporting an independent, pluralistic news media environment, including funding public service media or local news publishers.

It is clear across this work that no policy response addressing economic support for news is perfect. However, experts in this field have noted the strengths and weaknesses of various legislative efforts, consistently calling for measures of transparency and public accountability, the protection of editorial independence from undue commercial and political influence and the need to tailor solutions to a country’s specific needs. Further, this work reflects the broad range of tested and broadly supported policy initiatives that exist outside of media bargaining codes, including those that promote media pluralism and support public or local media.

As new policy initiatives aimed at media sustainability – and responses from major platform companies – unfold in real time, future work in this area can uniquely examine the impact of such legislation on media sustainability and independence as well as an informed public. One major obstacle to research in this area is limited independent researcher access to publishers’ closely held internal data (or smaller and local publishers simply lacking such data) as well as to platforms’ increasingly restrictive APIs, which CNTI explores in more detail in a separate issue primer. Related to this is a lack of, and at times conflicting, data on and research into news publishers’ advertising revenue and traffic. Collaboration among publishers, platforms, academics and civil society organizations will be critical to evaluating the success of policy models for media sustainability.


Notable Studies

  • Rescuing local news through tax credits: A review of policy in the U.S. and Canada

    UNC Center on Technology Policy (2023)

    Summary: This U.S.-focused, largely qualitative report offers an overview of tax incentive legislation proposed in the U.S. and enacted in Canada and analyzes its impact and shortcomings in supporting local news.

    CNTI’s Takeaway: Although indirect aid such as tax credits risks being used by governments to compromise editorial integrity, this report notes six useful recommendations for policymakers pursuing tax credit legislation, including establishing clear measures of transparency and public accountability as well as prioritizing support for local over national news.

  • Platformization and media capture: A framework for regulatory analysis of media-related platform regulations

    UCLA Journal of Law & Technology (2023)

    Summary: This paper explores the differing risks of media capture (by the state or the private sector) inherent in various policy proposals aimed at regulating the relationship between digital platforms and publishers. The author argues for the necessity of transparency approaches in conjunction with others to inform evidence-based policymaking.

    CNTI’s Takeaway: The author concludes that “these approaches raise fundamental questions about how to define news media beneficiaries, how to distribute benefits and how these decisions are made.” While countries appear to define ‘news’ similarly in recent policy proposals, the specifics around who actually qualifies as a news outlet – such as size, level of original reporting – vary greatly. These differences end up shaping legislation’s objectives in important ways.

  • Australia’s News Media Bargaining Code and the global turn towards platform regulation

    Policy & Internet (2022)

    Summary: Using a case study of Australia’s News Media Bargaining Code, this paper analyzes platform, government and public response to the legislation to evaluate the opportunities and challenges of this form of legislation, the protection of public news access on social media and the broader governance of platforms.

    CNTI’s Takeaway: Australia’s code secured a record number of large payments from major platforms to large news publishers, but there is no indication (or legal requirement) that this funding has been used to directly fund journalism. As this paper notes, this legislation may fuel different forms of platform dependency as publishers fail to find sustainable business models for public interest journalism.

  • Finding the funds for journalism to thrive

    UNESCO (2022)

    Summary: This UNESCO policy brief offers typologies of global responses to policy-driven economic support for news and assesses their strengths and weaknesses, ending with actionable recommendations for policymakers.

    CNTI’s Takeaway: This report, noting the impossibility of a one-size-fits-all solution to media sustainability legislation, usefully outlines how multi-stakeholder commissions can be developed to tailor solutions to a country’s specific needs.

  • Working group on the sustainability of Journalism: A New Deal for journalism

    Forum on Information & Democracy (2021)

    Summary: This working group recommends five tested and broadly supported means of direct and indirect subsidy to publishers – including direct governmental (domestic or international) and independent funding body subsidies, direct funding for public service media and indirect tax subsidies – but also notes the critical risk of media capture if not properly implemented.

    CNTI’s Takeaway: No policy solution is perfect, but the best policy solutions for enabling independent journalism (1) prioritize the protection of free expression and media freedom and (2) avoid “the uncertainty of betting on opaque arrangements that can entrench dominant players and risk primarily benefiting a few large publishers who are often already doing relatively well.”

  • Funding democracy: Public media and democratic health in 33 countries

    The International Journal of Press/Politics (2021)

    Summary: Analyzing correlations between strength of democracy indices and typologies of media systems, this study finds that governmental investment in nonprofit and public media have strong societal benefits for informed societies, including more diverse news coverage, increased public knowledge about politics and public affairs and lower levels of extremist views.

    CNTI’s Takeaway: Based on a robust study of 33 countries and relying on a wide range of country-level media and economic data, this research offers clear evidence that countries with well-funded, independent public service media consistently have stronger democracies.

  • Mandating digital platform support for quality journalism

    Harvard Journal of Law and Technology (2021)

    Summary: This article offers critiques of existing antitrust legislation and proposes alternative initiatives to require digital platform support for independent journalism, setting out blueprints for funding, prominent placement in news feed and search results and transparency requirements.

    CNTI’s Takeaway: While the range of proposed policy initiatives here are untested, this article makes clear that the key objective when considering policy-driven economic support for news should be to support and enable quality, independent journalism, not merely to prop up a struggling industry.

  • The Australian News Media Bargaining Code: Lessons for the UK, EU and beyond

    Journal of Media Law (2021)

    Summary: This article analyzes key provisions within Australia’s News Media Bargaining Code and potential implications for other markets considering similar legislation. The authors argue that policymakers can and should study the shortcomings of Australia’s law to strengthen future legislation.

    CNTI’s Takeaway: More comprehensive policy initiatives are needed in order to support smaller publishers, public interest journalism and news innovation.

  • The impact of aggregators on internet news consumption

    U.S. National Bureau of Economic Research (2021)

    Summary: Based on a natural experiment of Google News’ shutdown in Spain in 2014, this report found that the shutdown reduced news consumption (particularly breaking and hard news) by about 20% among users and page views on (primarily small) publishers by about 10%.

    CNTI’s Takeaway: As threats of Google News shutdowns ramp up in countries enacting media bargaining legislation, this work documents the large, positive effect of Google News on small publishers and on users’ ability to access breaking and hard news.

  • Digital news consumption and copyright intervention: Evidence from Spain before and after the 2015 “link tax”

    Journal of Computer-Mediated Communication (2017)

    Summary: Analysis of data tracking digital news behaviors in Spain before and after copyright legislation (2014-2015) was implemented finds that while restrictions did not appear to affect the reach of news sites, audiences’ news consumption became notably more fragmented.

    CNTI’s Takeaway: This paper offers useful evidence to help evaluate the actual impact of interventions such as so-called “link taxes” on audience news consumption.

State of Legislation

Globally, policymakers and civil society have tried a wide range of approaches to enable a sustainable and pluralistic media environment with varying success. These approaches have included but are not limited to:

  • Funding for public service media via license fees (e.g., the UK), media taxes (e.g., Germany) or from the state budget (e.g., Denmark).
  • Direct domestic subsidies (e.g., Denmark, France, Canada) to news organizations or independent funding bodies.
  • Indirect domestic subsidies, including Value-Added Tax (VAT) exemptions and tax rebates (e.g., Ghana) or credits (e.g., Canada) for publishers, editorial roles, freelance journalists or digital subscriptions.
  • Media subscription vouchers (e.g., France).
  • Competitive or selective funds (e.g., formerly New Zealand).
  • Emergency relief funds (e.g., during COVID-19).
  • International subsidies for public interest journalism.
  • Government advertising, though this can become a method of indirect censorship.
  • Extended copyright or copyright-like protections (e.g., Germany, Spain, EU).
  • Non-legislative approaches such as direct civil society or private-sector funding.

More recently, as we note earlier in this primer, adopted and proposed legislation in countries such as Australia, Canada, Brazil and the U.S. has required large platform companies to negotiate commercial deals with news publishers for their content, largely on the basis of antitrust or competition law. To proponents of these initiatives, they represent a much-needed rebalancing of power between digital platforms and the publishers whose content they distribute and monetize. As Australia’s News Media Bargaining Code in particular becomes a popular model for other governments, experts continue to note concerns, evidenced by research cited above, about issues of transparency, a lack of definitional clarity, long-term sustainability and further media dependence on major platforms. Additionally, media bargaining structures, which often primarily benefit legacy and larger publishers, risk becoming the arbiter of what news and information appears online, as well as whether news is carried there at all.

As we discuss in a separate issue primer, in many cases it is unclear how to assess what “quality” news – or even “news” more broadly – is. While some work indicates a certain degree of consensus around how to define ‘news’ across existing legislation in countries like Canada and the U.S., the provisions that structure these definitions (including publisher reach, size, geographic orientation, originality of reporting, etc.) vary and shape the outcomes of these laws.

Notable Legislation


Australia’s News Media Bargaining Code (NMBC), passed into law in February 2021, was the first regulation of its kind and has since served as a model for other countries. While the code faced strong resistance from platform companies, dozens of commercial agreements have been made (though deals are far from transparent). Concerns include that the law primarily benefits large publishers, lacks transparency requirements and does not set clear requirements for how funds are spent.

Read more here.


Brazil’s proposed media bargaining code, recognizing publishers’ rights to be paid for news content as part of a larger set of platform regulations (PL 2630), stalled in May 2023. The bill did not include transparency requirements, and private sector concerns included its potential to compensate creators of disinformation. Aggressive platform responses to shape public debate received international criticism, and experts noted concerns with the overall escalation of responses.

Read more here.


Canada’s Online News Act, Bill C-18, goes into effect in December 2023. Building on Australia’s NMBC, C-18 narrowed the platform exemption process and added transparency requirements, though experts have concerns that the ambiguity of inclusion criteria may harm smaller publishers. Google has agreed to pay $100M CAD annually in financial support to the Canadian news industry, whereas platforms like Meta have blocked Canadian news links in response to the legislation.

Read more here.


In early 2023, Indonesia’s government began drafting regulations to be issued under the Publisher Rights Presidential Decree allowing publishers to obtain payments from digital platforms, representing a first step toward antitrust regulation enforced via executive decree. Provisions of the bargaining structure would be overseen by Indonesia’s Press Council. Major platform companies have noted their opposition to the draft decree.

South Africa

In March 2023, South Africa’s Competition Authority announced an inquiry into news distribution by digital platforms, representing a first step toward antitrust regulation modeled after Australia’s and Canada’s.

United Kingdom

It is expected that a bargaining code similar to Australia’s and Canada’s will be revealed by Parliament by the end of 2023 as part of a larger legislative package, the Digital Markets, Competition and Consumer (DMCC) Bill, aimed at regulating digital platforms.

United States

The Journalism Competition & Preservation Act (JCPA), revived in June 2023, would create an exemption to antitrust law allowing news publishers to band together to negotiate for payments from digital platforms. Concerns include that the bill primarily benefits large publishers, does not set clear requirements for how funds are spent, and may threaten platforms’ content moderation efforts and violate copyright law.

Related bills have been proposed at the state and federal levels. Read more here.


Taiwan’s Ministry of Digital Affairs (MODA) is currently developing a model that may serve as the basis for a news media bargaining law. In March 2023, Google launched its Taiwan News Digital Co-Prosperity Fund, pledging to spend NT$300 million over three years to support the Taiwanese news industry.

Resources & Events

Notable Articles & Statements

Key Institutions & Resources

Ads for News: Initiative of non-profit coalition United for News and led by Internews enabling brands to advertise with trusted, local news media.

Center for International Media Assistance (CIMA): Initiative of the U.S. National Endowment for Democracy dedicated to improving U.S. efforts to promote independent media in developing countries around the world.

Endowment Fund for Independent Journalism (NFNZ): Czech non-governmental organization supporting editors and individuals who are engaged in serious journalism and honor the principles of liberal democracy.

Institute for Nonprofit News: Supports independent, non-profit news organizations.

Internews: Independent, nonprofit media development and support organization.

InternetLab: Independent Brazilian research center that aims to foster academic debate around issues involving law and technology, especially internet policy.

International Fund for Public Interest Media: Supports media organizations and ecosystem-level interventions across four focus regions (Africa/Middle East, Asia/Pacific, Latin America/Caribbean and Eastern Europe).

John S. and James L. Knight Foundation: Promotes research around building the future of local news in U.S. communities.

Lenfest Institute for Journalism: Supports local journalism through its focus on diversified revenue models, digital product development, and equity and representation.

Media Development Investment Fund (MDIF): Non-profit investment fund for independent media in countries where access to free and independent media is under threat.

News Sustainability Project – Industry research effort, led by the Google News Initiative and FT Strategies, to more deeply understand, measure and enable the drivers of publisher sustainability across the world.

SembraMedia: Non-profit organization helping independent digital media leaders build stronger organizations and develop sustainable business models.

Tow Center for Digital Journalism: Institute within Columbia University’s Graduate School of Journalism serving as a research and development center for the profession as a whole.

UNC Center for Innovation & Sustainability in Local Media: UNC research center aiming to grow a more equitable and sustainable future for local news, the journalists who make it and the communities that need it.

Notable Voices

Ramiro Álvarez Ugarte, Vice Director, Centro de Estudios en Libertad de Expresion y Acceso a la Informacion

Emily Bell, Founding Director, Tow Center for Digital Journalism

Colette Brin, Director, Centre d’études sur les médias

Francisco Brito Cruz, Executive Director, INTERNETLAB

Patrícia Campos Mello, Editor-at-Large and Reporter, Folha de São Paulo

Wahyu Dhyatmika, CEO, Tempo Digital

Marius Dragomir, Director, Center for Media, Data and Society

Sue Gardner, Former Executive Director, Wikimedia Foundation

Jodie Ginsberg, President, Committee to Protect Journalists

Jonathan Heawood, Founder and Executive Director, Public Interest News Foundation

Mijal Iastrebner, Co-Founder and Executive Director, SembraMedia

Mathew Ingram, Chief Digital Writer, Columbia Journalism Review

Beatriz Kira, Research Fellow, University College London

Amy Kovac-Ashley, Head of National Programs, Lenfest Institute

Irene Jay Liu, Regional Director for Asia & the Pacific, International Fund for Public Interest Media

Gaven Morris, Managing Director, Bastion Transform & Former News Director, ABC News

Rasmus Kleis Nielsen, Director, Reuters Institute for the Study of Journalism

Khadija Patel, Journalist-in-Residence, International Fund for Public Interest Media

Courtney Radsch, Senior Fellow, Center for International Governance Innovation

Anya Schiffrin, Director of Technology, Media, and Communications, Columbia University

Meera Selva, CEO, Internews Europe

Recent & Upcoming Events

Knight Media Forum 2023
John S. and James L. Knight Foundation
February 21–23, 2023 – Virtual

World News Media Congress
June 28–30, 2023 – Taipei, Taiwan

Abraji International Congress of Investigative Journalism
Brazilian Association of Investigative Journalism (Abraji)
June 29–July 2, 2023 – São Paulo, Brazil

International Journalism Festival
April 17–21, 2024 – Perugia, Italy

Issue primers have been reviewed at multiple stages by more than 20 global research and industry expert partners, including CNTI advisory committee members, representing five regions. We invite you to send us research, legislation and other resources. Read more about CNTI’s issue primer and other research quality standards.

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