Statement on the proposals of the Broadcasting Commission of the Länder on the reform of the Interstate Treaty on the Protection of Minors in the Media (JMStV-E)

On 15 March 2022, the Broadcasting Commission of the Länder adopted concrete proposals
for a reform of the Interstate Treaty on the Protection of Minors in the Media (JMStV)
and put them up for discussion. We thank you for the opportunity to comment and welcome
the synchronisation of the federal and state regulations on the protection of minors in order
to continue to ensure the uniform protection of children and young people in Games.
guarantee. We see this hearing as an important step in the political process towards a new
JMStV and combine this with the express expectation that further oral hearings will follow
and that adjustments will be made against the backdrop of the Suggestions are possible and desired.

A safe and good upbringing of children with media, a high level of youth protection and the promotion of media competence have always been part of our DNA as a games industry. Numerous innovative and exemplary content-related and technical solutions for the protection of minors originate from our industry. Many of these best practices are adopted and used by other industries. For this reason, we as an industry have been calling for many years for a modern, convergent and internationally compatible legal protection of minors that does not fall short of our modern standards, as has been the case up to now.

We expressly welcome the aim of the Broadcasting Commission to optimise the already existing systems for the protection of minors and to link them in such a way that they can develop their effectiveness in the best possible way. However, there is still considerable need for improvement in many of the proposed regulations, which is explained below. The However, we consider the approach chosen for the operating systems not only to be outdated, but also, in the proposed form, not suitable for achieving the desired goals for content-related, technical and legal reasons, as well as not internationally compatible and even inhibiting innovation.

The full statement can be found in the attached PDF.

Dr. Christian-Henner Hentsch
+49 30 240 87 79 22
Maren Raabe
+49 30 240 87 79 15