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30.09.2013 | Positionspapier EU Green Paper Preparing for a Fully Converged Audiovisual World: Growth, Creation and Values


On 24 April 2013 the European Commission released its Green Paper on Preparing for a Fully Converged Audiovisual World: Growth, Creation and Values. Bitkom welcomes the public consultation and the Commission’s approach to carefully assess developments of the audiovisual media landscape prior to introducing policy and/or legislative measures in this field.

In view of the increasingly convergent media landscape Bitkom is of the opinion that a forward-looking analysis should evaluate whether and to what extent the current form of regulation, including the differentiation between linear and non-linear services, is still appropriate and proportionate in light of regulatory objectives enshrined in the Audiovisual Media Services Directive (AVMSD). We consider statutory regulation as a last resort instrument which should only be applied under exceptionally justified circumstances. To this end, we are convinced that forces of competition and self-regulatory initiatives can effectively ensure achievement of several regulatory objectives.

Furthermore, the evaluation of the current regulatory regime should assess, by means of empirical studies, the impact of different audiovisual services on society and users’ ability to exercise control over them. Such evaluation should be carried out in a technologically neutral manner and regardless of the current classification of services as linear or non-linear. Services that are functionally substitutable and have the same impact on society should be treated equally in terms of regulation, irrespective of the service provider’s position in the value chain or its prior regulatory status. Lighter regulatory instruments should be used with regard to services that have a lower societal impact and/or offer users a higher degree of autonomy.

Bitkom’s position paper comments in detail on the Commission’s ideas raised with regard to:

  • Market considerations
  • Financing models
  • Interoperability of connected TV
  • Infrastructure and spectrum
  • Regulatory framework
  • Media freedom and pluralism
  • Commercial communications
  • Protection of minors
  • Accessibility for persons with disabilities


  • Nick Kriegeskotte
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