Transparency, impartiality, inclusivity, proportionality, non-discrimination, comparability and verifiability. These are the principles that the systems and methodology of audience measurement providers must comply with, as stated in Article 24 of the European Regulation on Freedom of the Media, also known as EMFA by its name in English (European Media Freedom Act). However, the different agents in the Spanish market seem to differ as to whether these principles are currently guaranteed in our country.

This was evident in the session “Audience measurement in the digital ecosystem: transparency, comparability and pluralism in the application of article 24 of the EMFA”, organized on Thursday, October 22 by the National Markets and Competition Commission (CNMC), and to which reason.Why had the opportunity to attend. The meeting was attended by representatives of different agents, from media associations, editors and advertisers, to audiovisual groups, agencies and research companies.

All of them recognized the value of the Regulation, which came into force in May 2024 and whose majority of provisions began to be applied in August of last year, but they regret that the regulations are still undergoing parliamentary processing in order to be transposed into the Spanish framework. And in this sense, they make a common call to legislators to advance what they consider a key text to guarantee the freedom and credibility of the media, the trust of citizens and democratic pluralism.

Is a change necessary in audience measurement?

The regulation, in its Article 24, does not intend to replace the self-regulation of the market, nor does it establish specific measures and aspects that the measurement systems must comply with, but it does establish some fundamental principles to which they must adhere. Some that, according to Miguel Ángel Fontán, General Director of the Association for Media Research (AIMC), have traditionally been fulfilled in the Spanish industry.

“I think that, in this sense, the standard does not provide much new, because measurement in Spain has always been faithful to those principles.“, he noted during the round table focused on analyzing whether, precisely, the measurement systems in our country comply with those designated in the aforementioned article. He illustrated this by recalling the establishment of the General Media Study in 1968 or the consolidation of the measurement of television audiences in the 1990s.

In this regard, he added two more principles that, in his opinion, should also be part of the regulations: rigor and sustainability. “The first is rigor, which would really encompass all the others. Because a measurement can be independent and comparable, but not necessarily rigorous, but, on the other hand, a rigorous measurement has to be independent, comparable and verifiable. And I think that, thanks to the entire industry, we are fulfilling this in Spain“, he explained. “What I think is missing is sustainability. Measuring costs money, and companies that dedicate themselves to it have to invest and adapt to technological changes. We must try to reach market standards, but rigor and sustainability are also relevant”.

However, other participants in the session disagreed with this vision, since they consider that the sector is currently operating with old, obsolete structures and procedures, and remains anchored in a status quo that does not really recognize that the ecosystem has changed and that there are new practices and media figures. Thus, Juan Zafra, General Director of the Open Editors Club (CLABE), explained the need to carry out a review and honesty exercise.

“If we do not assume our responsibility, if we continue to deceive ourselves by saying that everything works well, we are doing a disservice to users, to the business, to the sector and to democracy.“, he noted during his speech. “The system is still oriented towards quantity and volume, and should not continue this way in times of segmentation, personalization and the identification of traffic sources”.

Thus, he stressed the need to establish common parameters in the sector and to have independents who monitor that it is complied with and that self-regulation does not mean curtailing competition or the entry and exploitation capacity of the market by new agents.

The demand for a common standard

Along these lines, Julia Sizova, Director of Comscore in Spain and South EMEA and member of the Board of the Audience Measurement Coalition (AMC), expressed her hope that the EMFA does not remain a declaration of intent and that its principles are truly demonstrated. But for this it does not consider it necessary to develop a single technical solution at the European level, since each market must analyze its reality, needs and requirements. Instead, it does advocate for a common standard.

To achieve this, he pointed out three fundamental points: independent measurement, independent audit, and the role of JICs (Joint Industry Committees), the organizations in which all the main actors in an advertising market jointly participate. “The role of the JICs is very important and relevant“, he commented. “They are not here to approve or review the final result; also to make decisions. They are responsible for choosing the models according to the needs of each market, the meters and setting the audit rules and, brilliantly, also owning these strategic assets.”.

During the conversation, the growing prominence of large technology companies, such as Google, Amazon or Meta, was also put on the table; their status as so-called “walled gardens” and their impact on media activity. And in recent years emerging platforms have also joined them, especially those linked to the development of artificial intelligence, such as ChatGPT or Claude.

Irene Lanzaco, Director of the Information Media Association (AMI), pointed out the opacity in its activity, demanded common standards and highlighted the importance of preserving the diversity of the media ecosystem. “We cannot pretend that a two-second impact on social media is the same as a leisurely reading of an article in the press.“, he noted. “And I claim the need for any hearing system to take into consideration the Spanish territorial base. The audiences are not national. Every corner of this country has the interests of a very specific community of people that deserves to be cared for and protected. And measurement systems that only look at big numbers, by definition, are not going to accurately represent the interests of local communities.”.

He also demanded greater transparency in measurement as a guarantor of credibility, which is the main attribute of the media. “The EMFA is an opportunity to be more transparent. It is a starting point, not a watertight definition and this is a process that must be built with conversations and being aware of the balance of the different interests at stake.“, he stated regarding the European regulation. “We are putting at stake very relevant aspects of our democracy“.