Rethinking transparency in public service media: a multidimensional framework for better governance

Van den Bulck, Hilde; Horowitz, Minna; Raats, Tim

doi:10.3389/fcomm.2025.1569363

POLICY BRIEF article

Front. Commun., 01 July 2025

Sec. Media Governance and the Public Sphere

Volume 10 - 2025 | https://doi.org/10.3389/fcomm.2025.1569363

This article is part of the Research TopicUnderstanding Media Policy in the 21st Century: Affirmation, Challenge, Re-ConstitutionView all 8 articles

Rethinking transparency in public service media: a multidimensional framework for better governance

Hilde Van den Bulck¹

Minna Horowitz²^*

Tim Raats³

¹Drexel University, Philadelphia, PA, United States
²University of Helsinki, Helsinki, Finland
³Vrije University Brussels, Brussels, Belgium

Transparency has become a cornerstone of public service media (PSM) governance yet it remains inconsistently understood and applied. Increased scrutiny from various stakeholders has resulted in a need for actionable and meaningful transparency. Scholarly evidence highlights transparency’s benefits and risks, including potential misuse, as illustrated with current examples from Finnish PSM organization Yle and tVRT in Flanders (Belgium). This brief provides a multidimensional framework for actionable transparency efforts that allow PSM to move beyond ad hoc, reactive and partial approaches by elaborating key dimensions of transparency about what, when, how, by whom and to whom, transparency is required. Recommendations include fostering transparency practices that are meaningful and resistant to weaponization and politicization, developing participatory governance models, and leveraging transparency as a tool for organizational resilience.

1 The problem of transparency in PSM

Transparency is widely considered a cornerstone of democratic accountability and, increasingly, the objective of governance initiatives, such as the most recent EU acts related to media and platform governance, the Digital Services Act (2022) and the European Media Freedom Act (EMFA, 2024), both of which include a wide range of transparency measures and reporting requirements. Transparency has been central to PSM’s accountability principle (Groenhart and Bardoel, 2012), the principle of good governance (Van den Bulck, 2015), or PSM’s societal values (European Broadcasting Union, 2023). Yet, it increasingly dominates discussions on PSM’s legitimacy (Herzog et al., 2018; Rivera Otero et al., 2021; Speck, 2023), especially in digitized media ecologies and societies characterized by disruption, instability, and opacity that contribute to distrust toward media and other institutions (Puppis and Ali, 2023). Indeed, transparency is essential to PSM’s legitimacy and sustainability, as it operationalizes core values such as editorial independence, accountability, and public trust. For example, many PSM organizations provide publicly available reports disclosing funding allocations and performance metrics, ensuring financial and pluralistic accountability toward government, tax/license fee payers and other stakeholders. Transparent governance structures further represent democratic legitimacy. Publicly available editorial standards and complaints procedures (e.g., BBC, 2020) exemplify how transparency can safeguard editorial autonomy, while in the digital domain, PSM’s algorithmic transparency ensures that recommendation systems align with editorial values and user empowerment (Sørensen and Hutchinson, 2018). These efforts help build and maintain audience trust.

However, transparency too often functions as a catch-all concept, used by stakeholders in various interpretations and operationalized by PSM organizations in specific but often one-sided ways. Fundamentally, transparency provides information and insight into what decisions are being made, why, by whom, and with what outcome (Ball, 2009). Yet, specific parameters often remain opaque, vague, and volatile (Michener and Bersch, 2013). Moreover, how various stakeholders deal with PSM transparency “reminds us about the fundamentally political nature of transparency: it can easily move from an unmarked taken-for-granted issue to a marked and contentious issue” (Hansen and Flyverbom, 2015, p. 876). In what follows we elaborate on the main problems regarding transparency as an inroad to develop a multidimensional framework for actionable transparency efforts that allow PSM to move beyond ad hoc, reactive and partial approaches. To illustrate the problems, we refer to recent discussions and controversies about a perceived lack of transparency of Finnish Yle (Van den Bulck et al., 2025) and Flemish VRT. For YLE, criticism resounds about financial transparency and broader decision-making, and it is claimed that political biases are embedded. In the case of VRT, continuous discussions on a perceived lack of transparency revolve around particular - considered contentious - expenditures, while private competitors also criticize insufficient reporting of commercial revenues (Horowitz et al., 2025). Criticism of VRT transparency reached a peak amidst discussions regarding third-party financing from government departments for political programmes, perceived to impinge on VRT’s independence.

YLE and VRT are situated in EU Member States, share characteristics of Hallin and Mancini’s (2004) Democratic Corporatist model and operate in media landscapes characterized by fierce competition and politicization of media policy that put PSM organizations under continuous scrutiny from stakeholders (Van den Bulck et al., 2025; Donders et al., 2018). As elaborated below, the recent transparency-related controversies regarding YLE and VRT that result from various internal and external forces highlight how existing PSM transparency efforts can be criticized on various grounds. First, transparency is often narrowly conceived as disclosure of information, neglecting its procedural and relational dimensions. Most PSM, including VRT and Yle, typically must provide detailed reports on financial expenditures, audience metrics, and programming decisions. However, the large volume of disclosed data often obscures rather than illuminates organizational accountability (Van den Bulck, 2015), so-called “opaque transparency” (Gorwa and Ash, 2020).

Information-oriented transparency can also be criticized for overestimating data quality and neutrality, for assuming data will be dealt with rationally (Freedman, 2006), and for instrumental rationality that “erodes the normative basis of policymaking and undermines the capacity for ‘appropriate’ practice” (Sanderson, 2002, p. 36). Data disclosure is often nominal, without actual use, rather than being effective, as the latter requires disciplined action of returning rounds of practical, comprehensive, and adequately processed transparency. So-called “transparency illusion” represents the gap between practical and nominal transparency (Heald, 2006, p. 34). This serves as an important reminder that an apparent increase in transparency (e.g., through more legal obligations or audits) is meaningless if the information is not appropriate to the means and to the intended audience that must understand that information.

Second, Levy and Johns (2016, p. 1) point to the weaponization of transparency either by the organization (PSM) or by stakeholders. PSM can use transparency strategically, drawing stakeholders in detailed but irrelevant information about certain aspects to distract attention from other aspects (Gorwa and Ash, 2020). VRT, for example, provides detailed reports to the Flemish media regulator on the volume of partnership and dialogue initiatives, yet remains opaque about whether these collaborations revolve around external financing or effectively lead to structural and meaningful alliances between players.

However, transparency requirements are weaponized by external stakeholders like governments or commercial competitors to exert undue influence and/or destabilize PSM operations, using transparency as “‘Trojan Horses’ through which other political [or business] goals are pursued” (Levy and Johns, 2016, p. 1). In the past, ex-ante tests for new PSM services, required by the European Commission following criticism and official complaints from commercial competitors, have been criticized for providing competitors with advanced knowledge and opportunities to stifle PSM innovation (Van den Bulck and Moe, 2012). Recently, Finnish commercial competitors and the right-wing government (in place since 2023) deployed a lack of financial and editorial transparency as an argument to limit Yle’s remit and decrease its funding, resulting in significant workforce shrinking and prospective reductions in Yle’s services (Yle, 2025). In 2025, an amendment to the Act on Yle is in process to increase the transparency and oversight of Yle’s operations and finances (Finnish Government, 2024). Ironically, when Finnish commercial media filed an EU complaint about Yle’s supposed unfair competitive advantage, the ensuing discussions between Finnish policymakers and the EU were opaque, further suggesting the strategic nature of the transparency criticism (Ala-Fossi et al., 2024). Importantly, criticism of perceived lack of transparency often is really about the actual topic seen as problematic. For instance, complaints about the lack of transparency in disclosing details of exclusivity deals with television personalities is, really, criticism of the amounts spent on these deals. In that sense, Freedman (2010) “media policy silences” also works for transparency: whereas some issues become “weaponized” in political discussions, other issues, that might justify much more scrutiny, are not considered problematic, as they are either too complex to weaponize politically or may affect other stakeholders too. In the Flemish case, for instance, critics of producers’ and broadcasters’ attempts to walk the tightrope of acceptable product placement are not criticized openly by politicians, as criticism would likely harm commercial broadcasters as much as VRT.

Similarly, Riemer and Sobelman (2023) see coercive information disclosure as the weaponization of transparency if it forces information disclosure that goes against the best interests of an organization’s operations or core values. In some instances, the issue is not transparency as such but a failed (or weaponized) interpretation of whom the organization should be transparent to, as not all information needs to be transparent to all stakeholders. Here, transparency to whom must be weighed against democratic benefits. VRT has been criticized for not disclosing sports rights and personalities’ exclusivity deals while being mandated significant market shares in a highly competitive market. Disclosing market-sensitive information to broader audiences would undeniably affect market negotiations, regardless of whether the criticism of VRT is justified in this particular case. Third, transparency can be negatively affected by multistakeholderism’s shortcomings as not all stakeholders have any or equal say in or impact on PSM policymaking, while specific visible and influential stakeholders capture interpretations of accountability and transparency (Van den Bulck, 2015; Van den Bulck and Moe, 2012; Donders et al., 2018). Typically, in multistakeholder PSM policymaking, commercial competitors are visible and influential stakeholders, while audiences have a significant stake but lack visibility and power.

For Pozen (2018, p. 100), these problems represent transparency’s “ideological drift” as corporate capture and market-based theories of regulation have the effect that “demands for transparency became more and more threatening to the functioning and legitimacy of those institutions and, consequently, to progressive political agendas.” Ongoing weaponization of Yle transparency by Finnish government and commercial competitors illustrates this: Even when Yle’s current reporting about its editorial activities, governance practices and budget spending incorporate many Audiovisual Media Services Directive (AVMSD) and EMFA requirements, transparency debates remain linked to budget cuts and layoffs (Horowitz et al., 2025).

These shortcomings do not negate the importance of transparency in PSM organizations’ contribution to a well-functioning democracy (Cucciniello et al., 2017; Holtz-Bacha, 2023; Thomass, 2016), but suggest the need for a better understanding of various aspects of transparency as a concept and in its implementation. The urgency of addressing these challenges lies in the high stakes for PSM’s sustainability and societal role in the current media ecology, characterized by digital disruption and declining trust in institutions. A failure to address the transparency deficiencies risks undermining public trust, compromising editorial autonomy, and reducing PSM’s efficacy as pillars of democratic society.

For transparency to be a sustainable tool, PSM and their stakeholders must address the shortcomings in transparency practices. To this end, they must better grasp and put to work the multidimensional nature of transparency.

2 Understanding transparency through a multidimensional framework

An organization’s transparency in various dimensions can result from multiple sources and types of intervention, from formal legislation, to informal stakeholder pressure to voluntarily for genuine reasons or “to be seen to be doing it.” Regardless, “effective transparency also includes (a) an organization’s willingness to consistently communicate and make transparent information available to internal or external stakeholders and (b) the stakeholder’s expectations on the visibility and verifiability of information” (Brooks et al., 2021, p. 437). The following key dimensions inform our framework:

2.1 Transparency: about what?

Cucciniello et al. (2017, pp. 32–33) identify four transparency dimensions:

Institutional transparency: “degree of transparency about the mission and functioning of the organization, their mandatory activities, and the information they are legally required to provide.” Effective institutional transparency involves clear communication of organizational objectives and operations, ensuring alignment with public expectations. For PSM, these are captured in media laws and management contracts, and translated to broader audiences on web pages and in annual reports.

Financial transparency entails transparency in “the use of financial resources, financial solvency, and other financial issues.” Financial transparency is often emphasized in PSM governance, yet it overly relies on complex or vague metrics, which could lead to an illusion of transparency.

Service delivery transparency entails the “performance of organizations in delivering services to citizens and other stakeholders.” This dimension is critical to fostering public trust and demonstrating PSM’s value.

Political Transparency: refers to “accessibility of information about political representatives, their political mandate and activities and other aspects such as absenteeism and salaries.” This dimension is particularly significant to ensure editorial independence and safeguard against external manipulation and is relevant in a PSM context in relation to Boards of Governors, the selection and affiliation of CEOs and the appointment and backgrounds of key management executives.

2.2 Transparency: when?

Heald (2006) distinguishes between:

Event transparency vs process transparency: event-oriented transparency involves externally visible and measurable transparency at specific points in time. While “easier,” it only provides snapshots. Process transparency is critical for accountability but complex as it relates to transparency about implementation (e.g., of a policy decision) as it develops.

Retrospective vs. real-time transparency: real-time transparency points to constant monitoring and reporting of actions/events, potentially resulting in continuous surveillance. Retrospective transparency occurs at periodic intervals (reporting cycle) in an ongoing process, allowing an organization to conduct business and provide regular feedback on events and processes.

2.3 Transparency: how?

Transparency can be realized in various ways:

System of control: Lodge (2004) identifies three elements of transparency as control: standard-setting, behavior modification, and information setting. Most transparency interpretations emphasize information accessibility, including financial accountability.

Informational transparency as informed by two conditions: visibility and inferability (Michener and Bersch, 2013). Visibility refers to providing complete, findable information through active or passive transparency. Inferability refers to information that allows third parties to draw verifiable inferences through disaggregation, verifiability, and simplification tailored to stakeholder needs.

Performativity: Brooks et al. (2021) add that transparency is a process that includes performativity, emphasizing social and organizational actions induced by transparency practices, including agreements, conflicts, and negotiations. It recognizes that implementing transparency is “a process with both intended and unintended dynamics” (Brooks et al., 2021, p. 245). Visibility alone does not guarantee usefulness without consideration of how and why information is provided.

2.4 Transparency: by whom to whom?

Starting from the main distinctions between external and internal transparency and between vertical and horizontal transparency, four possible combinations occur (Heald, 2006; see also Cucciniello et al., 2017):

Upward transparency: the hierarchical superior/principal-stakeholder (the government) can observe (control) the behavior and/or outcomes (results) of the agent (PSM), e.g., annual performance report to media minister, financial report to the state comptroller.

Downward transparency: the agent (PSM) accesses information, monitors the principal stakeholders’ conduct, and assesses their needs. For example, the management contract solidifies government expectations and resources for PSM.

Outward transparency: the agent (PSM) can observe/monitor the outside of the organization, i.e., the habitat and conduct of other external organizations, e.g., PSM having access to information about commercial competitors.

Inward transparency: outside observers/stakeholders can monitor what happens inside the agent (PSM); e.g., competitors and audiences can observe/monitor PSM performances in different dimensions of its operations.

2.5 Transparency and other PSM goals

Transparency must be balanced against other values. PSM can have compelling reasons not to be transparent about certain aspects, including privacy and intellectual property. As Levy and Johns (2016, p. 3) put it: “data sharing may not be useful when those requesting data have strong vested interests.” Rodriguez (2020, p. 238) furthermore warns against reducing transparency to “maximum disclosure” as “many public processes and policies are subject to secrecy based on the nature of the action.” Heald (2022) sees transparency as potentially conflicting with other values. When transparency is “treated as an instrumental value (a means to other objectives) rather than as an intrinsic one” (Heald, 2022, p. 38), the organization and its stakeholders must make trade-offs. Moreover, most empirical research suggests mixed benefits of transparency (Bauhr and Carlitz, 2021), showing the advantageous impact of increased transparency on performance and adverse effects like less public trust (cf. Cucciniello et al., 2017).

3 Recommendations for sustainable PSM transparency

Several recommendations for policymakers, academics and PSM organizations can ensure PSM transparency measures enhance sustainability and accountability, thus strengthening trust.

3.1 Adopt a nuanced understanding of transparency

Transparency must be recognized as a multidimensional and context-sensitive concept encompassing institutional, financial, service delivery, and political aspects (Heald, 2006). This includes grappling with the “what,” going beyond information, and “to whom,” ensuring that disclosures are in keeping with the interests and capabilities of different stakeholders and of those with limited visibility and power while protecting organizational integrity (Cucciniello et al., 2017; O’Neill, 2012). Rather than treating transparency as a one-size-fits-all, it should be tailored to specific organizational PSM values and the media and political context in which a PSM organization operates (Herzog et al., 2018; Rivera Otero et al., 2021).

3.2 Prioritize effective transparency over nominal transparency

Transparency efforts must focus on actionable, inferable, and meaningful information rather than merely increasing the volume of disclosed data. Research shows that increasing the volume of information does not necessarily enhance trust or accountability, especially when citizens and stakeholders are unable to interpret or apply it effectively (Grimmelikhuijsen, 2012; Roberts, 2012). Transparency, furthermore, should not be just about the outcome but also about the process (Meijer, 2013). Effective or meaningful transparency further includes reporting mechanisms that fit various stakeholders’ capabilities and capacity to interpret and use information effectively, what Fung et al. (2007) call “targeted transparency.” To be meaningful, transparency as a trust-building exercise must be carefully crafted for different audiences (O’Neill, 2012).

3.3 Leverage transparency for trust-building and resilience

PSM should view transparency not only as a regulatory or compliance obligation but as an opportunity to build trust and demonstrate value. This involves (1) communicating successes and challenges (Dubnick and Frederickson, 2011) in ways that reflect PSM’s public mission; (2) highlighting innovation, collaboration, and societal contributions as part of transparency efforts. PSM organizations must also take ownership of transparency to ensure long-term resilience: not merely responding to stakeholders’ singular criticisms and demands (Meijer, 2013) but developing transparency priorities based on PSM values and good governance; (3) anticipating rather than responding with transparency (Flyverbom and Hansen, 2019). Much politically or publicly disclosed information results from direct criticism or inquiry (like parliamentary questions), whereas this information rarely directly harms PSM operations or legitimacy. Anticipating allows PSM to reduce the risks of politicizing information or insufficiently contextualized information.

3.4 Safeguard against the weaponization of transparency

Policymakers must design checks and balances that protect against misuse of transparency, especially by external actors in politicized and competitive contexts. This includes (1) establishing clear guidelines on the scope and purpose of transparency measures, (2) ensuring transparency requirements do not compromise organizational core values (Levy and Johns, 2016; Pozen, 2018), and (3) promoting balanced multistakeholder governance to counteract disproportionate influence of powerful political and commercial actors (Donders and Raats, 2018).

3.5 Foster participatory and inclusive governance

Transparency is not only about good governance but also about innovation (Kosack and Fung, 2014). As PSM’s remit is challenged in many countries, transparency practices should be embeddedin participatory governance models to make sure transparency serves democratic and PSM values rather than narrow interests (Thomass, 2016; Wittemyer et al., 2014). This requires engaging diverse stakeholders, including civil society and marginalized groups. Since citizens are not just stakeholders but also taxpayers and principal shareholders, their participation should be prioritized.

4 Call to action

Our multidimensional framework, capturing transparency across dimensions of what, when, how, from whom, to whom, offers PSM and policymakers a strategic tool to move beyond checkbox-style disclosure toward value-driven, context-sensitive transparency practices. First, it enables PSM to systematically diagnose where transparency is lacking or misaligned with other values. Second, it allows PSM to tailor transparency practices to core values rather than to political or commercial demands. Third, the framework encourages differentiated, audience-sensitive communication, helping PSM build trust with various stakeholders including citizens, regulators, and civil society. Fourth, it provides a safeguard against weaponization of transparency by clarifying boundaries: what must remain confidential and what should be open. Fifth, it invites participatory governance by making transparency a reciprocal process that allows for public engagement and institutional learning. Finally, it serves as a platform for benchmarking and innovation, enabling PSM organizations to compare practices, anticipate challenges (e.g., algorithmic accountability), and develop robust transparency standards.

Author contributions

HV: Conceptualization, Methodology, Writing – original draft, Writing – review & editing. MH: Writing – original draft, Writing – review & editing. TR: Writing – original draft, Writing – review & editing.

Funding

The author(s) declare that financial support was received for the research and/or publication of this article. This work was partially supported by the Strategic Research Council (SRC) established within the Research Council of Finland (Grant number 352557) and Drexel University- ORI AEO Pilot Award number 284279.

Conflict of interest

The authors declare that the research was conducted in the absence of any commercial or financial relationships that could be construed as a potential conflict of interest.

Generative AI statement

The authors declare that no Gen AI was used in the creation of this manuscript.

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References

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