The publication of the comments on the MedienInvestVG makes it clear that, whilst the industry hardly questions the law’s objective, it does take issue with its specific provisions. The real conflict is not between support and opposition, but centres on the question of how investment, rights, infrastructure and exploitation are distributed within the film industry.

From platforms such as Apple, through broadcasters such as ARD, to producers’ associations, trade unions and cinema operators: the responses to the MedienInvestVG paint a broad yet contradictory picture of the industry. An overview of the key areas of conflict.

A law that has received widespread support – and equally widespread criticism

The MedienInvestVG (Media Services Investment Obligation Act) is one of the German Government’s key media policy initiatives. The aim is to require audiovisual media service providers – in particular streaming platforms – to invest a proportion of their turnover in European film and television series productions.

The collection of comments that has now been published makes it clear that the general thrust of the legislation is widely accepted within the industry. The conflict does not centre on whether more investment is needed, but rather on how this investment is to be organised, allocated and regulated.

Platforms: Warning about regulatory fragmentation

Apple’s statement is representative of the perspective of global streaming platforms. It accepts investment obligations in principle as part of the European media market, but warns against increasing regulatory fragmentation.

The main concern is that differing national requirements make it difficult to plan international business models. In particular, criticism has been levelled at unclear definitions of content eligible for investment, as well as potential overlaps with existing funding mechanisms.

The platform perspective thus highlights a fundamental conflict of objectives: whilst national policy aims to strengthen cultural value creation, streaming services operate in global markets using scalable licensing and investment models.

Producers: In favour – but want more control over rights

The producers’ associations – including Produktionsallianz and PROG – support the investment commitment in principle, but make this conditional on clear demands for structural reforms.

The central issue is the distribution of rights. From the producers’ point of view, it is not enough to channel additional funds into the sector if economic exploitation rights remain predominantly concentrated in the hands of clients or platforms.

The investment commitment is thus seen not merely as a financing instrument, but as a means of strengthening the position of independent producers within the value chain.

Broadcasters: Between system integration and feasibility

ARD has adopted a constructive stance towards the proposed legislation. Whilst it does not question the fundamental objective, it does highlight issues relating to practical implementation and integration into existing support and funding systems.

The focus here is less on political orientation and more on operational compatibility: how can new investment obligations be reconciled with existing funding instruments, internal programme budgets and public-law structures?

The broadcaster’s perspective thus highlights a key tension between regulation and system compatibility.

Trade union perspective: Investment must benefit workers

With ver.di, a labour market policy perspective is entering the debate that goes beyond traditional industrial policy arguments.

Whilst the investment commitment is generally welcomed, it is emphasised that additional funding will only generate social value if it is channelled into stable employment covered by a collective agreement lead to.

In doing so, ver.di shifts the debate away from the issue of investment levels and towards that of working conditions. More money in the system is no guarantee of better social standards in the reality of production.

Cinemas: Warning of structural difficulties

The Central Association of German Cinemas (HDF KINO e.V.) brings a perspective on film distribution to the debate that is only touched upon in many other statements.

Whilst the MedienInvestVG focuses heavily on production and streaming, the HDF warns against the structural neglect of cinema distribution. Cinemas are not only cultural venues, but also a central component of the film industry’s value chain.

The concern is that if funding and investment instruments are primarily geared towards production and platforms, there is a risk of a further shift in the balance at the expense of traditional distribution stages.

Technical service providers: No infrastructure, no production

The Association of Technical Services for Film and Television (VTFF) focuses on the industrial infrastructure of film production.

From the perspective of technical service providers, the key question is whether the law will actually lead to more continuous domestic production. Only then will studios, post-production and VFX companies see reliable levels of workload.

The VTFF places particular emphasis on the importance of planning certainty. Fluctuating funding criteria and uncertain investment structures would jeopardise the location’s competitiveness in the long term.

This shifts the focus away from cultural policy issues and towards traditional industrial policy for production infrastructure.

Creative organisations: Structural reform rather than simply an influx of funds

Organisations from the creative sector – including the Federal Association of Actors (BFFS), the Federal Association of Directors (BVR), the German Academy of Television (DAfF) and the AG Animationsfilm – support the reform’s objectives, but have linked this to calls for structural improvements.

The focus is on working conditions, the realities of production and the economic participation of creative trades. The investment commitment is seen as an opportunity to address existing imbalances within the sector, rather than simply providing additional means of production.

Overall picture: A debate spanning the value chain

An analysis of the comments reveals a consistent pattern: the MedienInvestVG does not represent a classic conflict between support and opposition. Rather, the debate spans the entire film industry value chain.

• Platforms are warning of regulatory fragmentation and excessive economic complexity.
• Producers are calling for greater rights and a fairer share of the profits.
• Broadcasters emphasise system integration and practicality.
• Trade unions focus on working conditions.
• Cinemas are warning of structural weaknesses in distribution.
• Technical service providers point to infrastructure and capacity utilisation.

This makes it clear that the law does not merely affect individual market segments, but has the potential to shift the balance between all stages of the production and exploitation chain.

Conclusion: A consensus on the goal – and a dispute over the system

The MedienInvestVG is not fundamentally questioned by the majority of stakeholders. The political objective of boosting investment in European audiovisual works enjoys broad support.

The real conflict lies in the fundamental question of the system: how is value creation organised, how are rights allocated, how are investments effectively implemented – and who ultimately benefits from them?

The parliamentary process is therefore likely to be shaped less by the question of „whether“ and more by that of „how“. The submissions reveal an industry that is united in its objective but is clearly drifting apart when it comes to the structure of its future regulatory framework