Intermediary Services
Intermediary services act as intermediaries between those who create content and those who consume it.
They collect information and journalistic content, organise it, and make it available to users. To do so, they rely on proprietary algorithmic systems that use collected user data to assess the relevance of content and information. As a result, they influence which information users can easily find and access. Social networks (e.g. Facebook), video-sharing platforms (e.g. YouTube), and search engines (e.g. Google) are therefore considered intermediary services.
Intermediary services are used every day by countless people as a source of information, often without users even being aware of it. They therefore have a significant influence on opinion formation. Most people rely on only a small number of major intermediaries which, because of their central gatekeeping role, have the potential to shape access to information.
All of us use intermediary services every day. As a result, social networks, search engines, and video platforms play an increasingly important role in shaping public opinion.
Demands for the Protection of Media Diversity
Intermediary services such as X, Facebook, Instagram, TikTok, and Google have a significant impact on public opinion and pose potential risks to media diversity. Through the aggregation, selection, and presentation of media content, they can strongly influence how opinions are formed and decisions are made. At the same time, there is a risk that their operations may negatively affect the diversity of opinions, content, and providers.
We are committed to safeguarding diversity of opinion, content, and media providers in digital environments. To support this objective, we have formulated specific recommendations for legislators, platforms, and regulatory authorities. These are intended to stimulate debate and ensure that intermediary services assume responsibility for their role in the digital public sphere.
NEW LEGISLATIVE PROVISIONS
The State Media Treaty regulates media intermediaries for the first time. This regulation is primarily intended to ensure diversity. Under the “transparency requirement,” media intermediaries must, among other things, explain their key criteria for collecting, selecting, and presenting content, as well as how they weight these criteria when sorting information and content. In addition, media intermediaries may not treat individual journalistic content less favorably than other content by using additional, undisclosed criteria for collection, selection, or presentation. Nor may the underlying criteria themselves discriminate against any content (“prohibition on discrimination”).
In Germany, the state media authorities are responsible for monitoring compliance with these requirements. We ensure that the formation of opinions can take place freely and independently, even when using media intermediaries. This is because users must be able to access a wide range of services and channels, as well as a diversity of opinions and positions. Safeguarding diversity—including online—is thus one of the core tasks of the media authorities.