Executive summary

The purpose of the Media Reform public consultation was to seek feedback on five proposals that aim to create modern media legislation for New Zealand’s media and content production sector and New Zealand audiences.

The draft proposals consulted on were high-level, and the purpose of the public consultation was to ensure the feedback informs further work and final decisions.

The Ministry received 197 submissions in total, comprising of 116 written and 81 survey responses, with 103 submissions representing organisations. Each submission provided feedback on one or more but not necessarily all draft proposals.

Media Reform submissions

Proposal 1: Ensuring accessibility of local media platforms

Of the 122 submissions received on this proposal, approximately 84 percent were in support and 14 percent were not.

While there was a broad level of support for the proposal, many submitters made suggestions for improvements to the definition of the ‘local TV services’ that would qualify and which devices would be captured. There was clear advocacy for an equivalent radio prominence regime. Many raised concerns about compliance burden and the risk of unintended market consequences considering our small market size.

Proposal 2: Increasing investment into and discoverability of local content

Of the 147 submissions received on this proposal, approximately 80 percent were in support and 13 percent were not.

There was broad support for the proposal and recognition of the need to protect local content. There was a lot of support for levies to be used as either an alternative to, or alongside, investment obligations. Many submitters considered that the right definition of local content would be critical and expressed a range of views on how it should be defined. Submitters were also concerned about the financial risks to the industry of implementing this proposal.

Proposal 3: Increasing captioning and audio description (CAD)

Of the 107 submissions received on this proposal, approximately 89 percent were in support and eight percent were not.

There was broad support for the proposal and many agreed that it would support fair and equitable access to audiovisual content. One of the key concerns raised was the cost and compliance burden of increasing CAD. However, submitters also indicated that artificial intelligence (AI) could help to produce cost-efficient CAD, but noted AI’s current capability and quality limitations particularly for local content. Submitters also called for the inclusion of additional requirements relevant to CAD, such as standards or guidelines of CAD quality and New Zealand sign language.

Proposal 4: Modernising professional media regulation

Of the 117 submissions received on this proposal, approximately 62 percent were in support and 23 percent were not.

There was overwhelming support to include all media content providers and user-generated content (social media platforms) in the proposed regulatory system. While more than half the submissions were in support of an improved regulatory system, many submissions called for a more simplified system that relies on self-regulation of the industry.

Proposal 5: Streamlining Crown content funders

Of the 146 submissions received on this proposal, approximately 63 percent were in support and 19 percent were not.

Submitters in support of the proposal almost always included caveats for how the consolidation process should work and/or for the characteristics of a consolidated entity. Similarly, while many submitters were impartial about the proposal overall, they provided comments on the way in which the two entities should be consolidated, if this proposal were to go ahead.

General feedback on Media Reform

The Ministry also asked submitters general questions on Media Reform as a whole programme, in terms of:

• whether the proposals should be progressed
• which proposals should be prioritised
• if there are other more effective measures
• how the proposal will help the Crown meet its obligations under Te Tiriti o Waitangi.

Of the 104 submitters who provided general feedback, approximately 60 percent agreed that the proposals should be progressed, and 13 percent did not.

The Ministry is undertaking further analysis on the Media Reform package. Any Government decisions on Media Reform will require Cabinet approval.

Introduction

Purpose of the summary document

The purpose of this summary document is to highlight the most significant themes raised by submitters on each proposal that will assist in the development of the Media Reform package. This summary document reflects feedback the Ministry received during public consultation; it is not a representation of the Ministry’s position on that feedback.

What is Media Reform?

The Media Reform: Modernising regulation and content funding arrangements for New Zealand discussion document set out proposals for public consultation to support the media and content production sector.

The current legislation for the media and content production sector is no longer fit for purpose as it is out of step with how media content is now produced and consumed and does not make room for ongoing change in the media landscape.

Over 35 years ago, the Broadcasting Act 1989 (the Broadcasting Act) established a framework to regulate content shown on linear TV or radio to ensure that it meets community standards. The Act also set up a system to publicly fund broadcast programmes, initially by establishing NZ On Air (formally, the Broadcasting Commission). The Film Commission Act 1978 established the New Zealand Film Commission (NZFC) to encourage and assist with films and support the New Zealand film industry.

The way we consume media has changed greatly in the last thirty years. Technological advancements and increasing globalisation have brought new options (predominantly global content platforms) into the market. Audiences now have significantly more choice around where and how they consume media content, and the types of content they consume.

The draft proposals consulted on are still in development and may change. The purpose of the public consultation was to ensure the feedback informs further analysis, detailed design, and Government decisions about what change to progress.

Media Reform consisted of five proposals

Media Reform proposed five changes to New Zealand media’s legislative frameworks:

1. Ensuring accessibility of local media platforms: Require TV manufacturers to ensure local media services are prominent and visible on devices such as smart TVs so they can be easily found by audiences.
2. Increasing investment into and discoverability of local content: Require streaming platforms and TV broadcasters to invest in local content and implement measures to ensure it is more ‘discoverable’ on their platforms, supporting the production of and engagement with New Zealand stories.
3. Increasing captioning and audio description: Require more captioning and audio description on content that is broadcast or streamed to ensure access for disabled people.
4. Modernising professional media regulation: Revise the broadcasting standards regime (including the Broadcasting Standards Authority) with platform-neutral and system-level regulation of professional media.
5. Streamlining Crown content funders: Consolidate NZ On Air and the New Zealand Film Commission into a single entity, supporting efficient administration of government funding for local content and industry development.

How we consulted

Public consultation on the Media Reform proposals ran from 12 February 2025 to 23 March 2025. The Ministry hosted two online public information sessions to introduce the proposals and answer questions, and an online workshop on each of the five proposals. Recordings of the information session and presentation portion of each workshop were made available on the Media Reform webpage on the Manatū Taonga website. New Zealand Sign Language interpretation was provided for all events.

Media Reform

Overview of submissions

In total, 197 submissions were received, comprising 81 online survey responses and 116 written submissions. Of the 197 submissions, 94 were submitted by individuals, and 103 on behalf of a group, organisation, or community group. The majority of written submissions (79 percent) were from groups or organisations, while most of the survey responses (86 percent) were from individuals.

Organisations that provided submissions include:

• Crown entities (e.g. Radio New Zealand, NZ On Air, NZFC)
• TV/radio broadcasters (e.g. NZME, TVNZ, Community Access Media stations)
• Local production companies (e.g. South Pacific Pictures, Greenstone TV)
• Arts, media and screen sector advocacy bodies (e.g. Radio Broadcasters Association, Australia New Zealand Screen Association)
• News publishers (e.g. Stuff)
• Digital technology companies (e.g. Apple)
• Global streaming services (e.g. Netflix, Spotify).

Submitters’ feedback has been anonymised where possible. However, specific stakeholders have been named where they would be directly impacted or contribute a high level of technicality to the proposal. For example, submissions by NZFC and NZ On Air have been referenced directly in Proposal 5 as both Crown entities would be affected by this proposal.

General feedback on Media Reform

The Media Reform discussion document also asked submitters general questions on the draft proposals as a whole, in terms of:

• whether the proposals should be progressed
• which proposals should be prioritised
• if there are other more effective measures
• how the proposal will help the Crown meet its obligations under Te Tiriti o Waitangi.

104 submissions were received which provided this general feedback.

Issues to prioritise

The theme of promoting local content and developing our film industry was most prevalent in these general comments that supported the Media Reformproposals.

Many submitters mentioned the urgent need to update outdated legislation to better support the changing media landscape.

Some submitters were concerned that the draft proposals would increase government intervention into media and content creation. 

Some submissions from both organisations and individuals sought prioritisation of equitable access, and stressed the importance of progressing the proposal to increase captioning and audio description of content.

A few media organisations and production companies considered the proposals should go further to support and sustain the media and content creation industries.

A large number of independent community access radio stations’ submissions prioritised the importance of protecting and uplifting the role of community media through Media Reform, and requested that changes should enhance accessibility, representation, and sustainability, rather than prioritise commercial efficiency at the expense of public interest media. 

Alternative measures suggested

A range of submissions called for the following alternatives:

• separate funding streams for commercial and local productions
• sustainable public-interest journalism
• improving the public’s trust in media
• different regulation for private and state-owned media
• a review of the Copyright Act 1994 in relation to AI and to ensure better protections and fair value is delivered to creators and intellectual property owners
• reviews of the Digital Identity Services Trust Framework Act 2023, Data and Statistics Act 2022, and Privacy Act 2020
• anti-siphoning legislation to allow free-to-air providers first right of refusal to bid for broadcast rights for events of national significance (usually major sporting events) to ensure the sustainability and accessibility of local content
• consideration of local media platforms in government advertising and procurement arrangements.

One guild suggested Media Reform missed the opportunity to enable creative vision and instead remains focused on commercial or technological considerations. This submission called for structural and financial support to enable content creators to lead with bold, innovative approaches rather than responding to market shifts.

A few submitters advocated for alternative measures, which were considered by Manatū Taonga during the design of each draft proposal.[1] These alternatives included:

• mandatory reporting requirements (e.g. for prominence)
• a levy for streaming platforms
• changes to the Screen Production rebate.

Out of scope alternatives

While the Media Reform discussion document outlined the parameters and constraints of the draft proposals, some submitters called for the following alternatives, which remain out of scope:

• an increase in funding
• regulation of social media platforms
• changes to Tax and Accident Compensation Corporation codes to meet the roles and contract style nature of the production industry work
• trade agreements to prioritise and protect domestic production
• provide tax breaks for platforms that invest in local content and creating funding pools for smaller creators
• review of the Films, Videos, and Publications Classification Act 1993.

Te Tiriti o Waitangi obligations

Many submissions commented on the benefit of investment obligations and using local content sub-regulations to prioritise and promote Māori content unique to New Zealand’s national identity. These submissions reflected that this would create a direct financial incentive to produce and promote content that reflects te reo Māori, tikanga Māori, and Māori narratives. Some noted that having Māori content on global streaming platforms would enable accessibility to wider audiences and encourage more Māori content development. Submissions commented that partnerships with Māori creators could foster authentic representation of Māori voices and storytelling from a Māori perspective.

A few media organisations strongly recommended all proposals include a specific analysis of Te Tiriti o Waitangi issues and impacts. Whakaata Māori recommended engaging iwi and Te Ao Māori experts to inform the proposed next steps in the government’s media reforms, to ensure structural inclusion, decision-making authority, and protection and elevation of te reo Māori across all platforms. Other individual submissions also called for the reforms to be co-designed with Māori.

12 independent community radio stations called for dedicated funding for Māori content production. One organisation considered the proposals may lack robust mechanisms to assess their effectiveness and instead suggested clear quotas or requirements for Māori content on broadcasting platforms and targeted support and funding for Māori broadcasting services.

Proposal 1: Ensuring accessibility of local media platforms

This proposal would require TV manufacturers to ensure local media services are prominent and visible on devices such as smart TVs so they can be easily found by New Zealand audiences.

There were 122 submissions on the proposal, with 61 representing organisations and 61 from individuals.

• 70 supported the proposal
• 33 supported the proposal with changes
• 17 opposed the proposal
• Two submissions were unclear on their position.

The key themes in the submissions were:

• difficulty finding local services
• definition of ‘local TV services’
• expanding the devices the rules would apply to
• inclusion of radio prominence requirements
• concern about compliance costs.

Difficulty finding local services

Many submitters agreed that local platforms can be hard to find on smart TVs, particularly compared with international apps. Some submitters shared personal experiences of difficulties experienced or observed. Many supportive submitters considered that the proposal would have a positive impact for audiences, particularly for those without the knowledge or capability to download local apps.

One submitter cited research from the United Kingdom and Australia that found many smart TV owners will not install apps if they are not pre-installed.

Definition of ‘local TV services’

While many submitters broadly agreed with the proposed definition of ‘local TV services’, many believed it needed to be refined to ensure certain local platforms would qualify. Some argued that the definition seemed to favour larger/existing providers, and that smaller and emerging local providers that play a crucial role in diversifying local media would be excluded. Some local broadcasters suggested that given our small market size, legislating prominence solely for the Freeview streaming app (which provides live streaming of local TV channels) may be more palatable to manufacturers than having to provide prominence to multiple local apps.

A number of submitters including representatives of global streaming services, device manufacturers and some local broadcasters considered that only local platforms which are demonstrably providing public media content (e.g. local news) should be captured under the definition.

Expanding the devices the rules would apply to

A large number of submitters suggested that the TV devices captured by the proposal should be expanded beyond those primarily used for audiovisual viewing, to include devices such as mobile phones, tablets, computers and gaming consoles. These submitters argued that such devices are increasingly used for media consumption and that their inclusion would help to future proof a prominence regime.

A representative group for device manufacturers argued that the proposal should be limited to devices used primarily for TV viewing, and that anything beyond would be disproportionate due to compliance burden and technological complexities.

A local broadcasting service outlined that traditionally, TV users tend to have an expectation that a smart TV will be equipped to provide easy access to local channels and apps, whereas for mobile phones there is an accepted understanding that apps need to be sought out and downloaded.

Inclusion of radio prominence requirements

Many submitters including representatives from the commercial and non-commercial radio sectors advocated for the inclusion of requirements to ensure the prominence of local radio services on connected devices such as smart speakers and in-car entertainment systems. Submitters argued that such requirements should be included as a future proofing measure, recognising the important role radio plays in providing access to local news, music, cultural content and particularly emergency information.

NZ On Air’s submission noted its Where are the Audiences? 2025 research which identified an increase in online radio/podcast listening, which it stated could be enhanced by easier discoverability.

Some submitters warned of unique technological complexities related to radio prominence issues and advised that it should be addressed separately to the issue of TV prominence.

Concerns about compliance costs

Some submitters agreed with the initial assessment in the discussion document that software changes required to comply with prominence requirements would be ‘modest’. However, representatives of device manufacturers strongly disagreed, arguing that the assertion overlooks technical and commercial complexities. Submitters did not provide any specific cost data.

A number of individual submitters raised concerns that TV manufacturers may pass compliance costs on to consumers by increasing the cost of TVs. Many submitters also noted New Zealand’s small market size and warned that overly prescriptive requirements may deter device manufacturers from our market. One organisation recommended close alignment with the Australian media regulator’s guidance and technological specifications to mitigate against this risk.

Proposal 2: Increasing investment into and discoverability of local content

This proposal would require streaming platforms and TV broadcasters to invest in local content and implement measures to ensure it is more ‘discoverable’ on their platforms, supporting the production of and engagement with New Zealand stories.

There were 147 submissions on this proposal, with 73 representing organisations and 74 from individuals.

• 73 supported the proposal
• 44 supported the proposal with changes
• 19 opposed the proposal
• 11 submissions were unclear on their position.

The key themes in the submissions were:

• the importance of protecting local content and the current issues facing production of local content
• the right definition of local content is critical
• support for an option that includes a levy as well as investment obligation
• concern about the financial impacts on the industry and workability with the current international tariff policy

Importance of protecting local content and the current issues facing production of local content

The majority of submitters supported requirements to protect local content and provided information on the importance of local content and New Zealanders being able to see themselves on screen. Many submissions specifically mentioned the importance of our stories being intertwined with our national identity.

A guild submitted that investing in local content is essential for fostering New Zealand’s culture, supporting local talent, and ensuring that our stories are told on a global scale. It argued the requirement to invest in and make local content discoverable is an important step towards cultural sustainability.

One submission stated that it is important that people of all backgrounds can see themselves and their stories on screen; that they are able to explore who they are as individuals and as a nation, and that sharing local stories increases a collective sense of belonging and identity and helps shape our futures.

A large number of submitters described how the sector is at a critical point due to a lack of funding and that this is leading to a reduction in local content. Many submitters specifically commented on the need to require global streamers to invest in the New Zealand content they benefit from.

One production company submitted that the local media industry is in crisis; the economic downturn, alongside fragmentation in audiences, has impacted the sector to a point of market failure for local screen content.

A guild stated that without significant and immediate additional funding, New Zealand screen production faces an existential threat. It argued that New Zealand's distinctive cultural voice—internationally recognised as authentic and iconic—is being severely disadvantaged on the world stage due to critical funding shortages.

One production company stated the proposed changes, if implemented, would play a crucial role in preserving employment within the sector.

Right definition of local content is critical

Many submitters commented on the definition of ‘local content’ and considered that the success or failure of this draft proposal would owe much to the definition. Submitters considered that the definition should ensure that local content is created by New Zealand-based creators, producers, and talent and tells New Zealand stories.

A broadcaster considered that the definition must cover scripted and all non-scripted genres and be content made for Aotearoa’s audiences, which tells New Zealand stories and reflects our country’s identity and culture.

A guild considered that local content should include works created by New Zealand-based creators, producers, and talent, with content primarily focused on New Zealand audiences and produced within the country.

One submitter recommended utilising the "significant local content" framework from the New Zealand Screen Production Rebate and extending it to include official co-productions. One broadcaster supported NZ On Air’s definition of “local content” as programming that reflects New Zealand identity and culture as a useful definition.

One media organisation recommended a definition framework based on authorship and control by New Zealand or Māori creatives, use of te reo Māori and Māori concepts, demonstrated cultural integrity and local economic and workforce contribution. Another submitter stated that when defining “local content” the Act must continue to ensure that the diverse communities of Aotearoa are represented fairly and equitably.

Support for an option that includes a levy as well as an investment obligation

Many submitters supported the option of also enabling levies to be used as either an alternative to, or alongside, investment obligations on streaming platforms. Submitters considered this combination could bring complementary benefits or that a levy could function as a back-stop. 

A guild considered that a combined investment obligation and levy could create a more reliable funding mechanism for local content, while also ensuring platforms contribute directly to the industry. The investment obligation would ensure that platforms actively engage with local content, while the levy could ensure a steady stream of funding for New Zealand content creators.

Two submitters considered a levy should be utilised as a back-stop in the event that a streaming platform failed to invest to the required level. They stated the levy requirements could be offset by higher levels of local content investment.

One media organisation considered that any changes or new requirements must support the sustainability and growth of the Māori production sector, support the Māori media sector workforce and talent pipeline, build Māori capability across the media sector and ensure Māori perspectives, stories and Māori language revitalisation outcomes are maintained or accelerated.

Benefits of a levy

Many submitters supported the option of a levy. They considered it would:

• ensure public interest content is factored into funding decisions, including Māori perspectives and stories
• provide a reliable and transparent funding stream to a range of New Zealand content creators.

Two organisations submitted a levy would ensure that public interest/cultural interest criteria would be factored into funding decisions.  One submitter considered that a levy would support economic welfare by ensuring a range of producers are able to benefit from the funding.

One submitter considered the levy model should be strongly considered with clear legislated and regulated caveats in order to protect, promote and endorse Māori content, Māori storytellers and platforms as per Te Tiriti and to serve Māori audiences.

Another submission stated that levies would help create a more sustainable financial structure with investment from international streamers and others, supporting the development of New Zealand screen storytellers for the future.

Concerns about financial impacts on the industry and workability within international trade context

Submitters raised a range of potential negative impacts this proposal could have on the industry including an increase in production costs and decreasing New Zealand’s attractiveness as a production destination. Submitters also raised concerns about the proposal’s workability within the context of shifts in international trade policy.

Inflating production costs

Many organisations were of the position that mandating investment could lead to increased costs for all participants, including broadcasters. They argued that local media companies would either get fewer hours of content for their investment than they do today or will be forced to spend more. One submitter stated that the costs could push content providers to either leave or deprioritise the New Zealand market.

Decreasing New Zealand’s attractiveness as a production destination

Submitters representing a streaming platform and an industry association stated that the proposal could negatively impact New Zealand’s attractiveness as a production destination. One submitter stated that the proposal would undermine the vast investments made from international partners into the New Zealand market for film and television.

Workability within international trade context

One broadcaster noted that in Australia, implementation of an investment requirement on global streamers remains delayed due to its complexity. Due to international trade policy shifts, some submitters commented on risks around opposition to imposing regulations of this nature on global companies operating in New Zealand.

Some production companies submitted that the Canadian levy[2] is viewed by the production community and politicians as unlikely to deliver significant results, and is already subject to legal challenges from American production studios, streaming services, and more critically, the United States Government.

Proposal 3: Increasing captioning and audio description

This proposal would require more captioning and audio description to be made available on content that is broadcast or streamed in New Zealand to ensure access to media for all New Zealanders.

There were 107 submissions on the proposal, with 56 representing organisations and 51 from individuals.

• 73 supported the proposal
• 22 supported the proposal with changes
• nine opposed the proposal
• three submissions were unclear on their position.

The key themes in the submissions were:

• support for fair and equitable access
• technical limitations currently restrict accessibility
• artificial intelligence aids efficiency but has limitations
• concern about the cost and compliance burden
• suggested additional requirements

Support for fair and equitable access

A large number of supportive submitters were in favour of increasing CAD on the basis that it would provide fair and equitable access to media content available in New Zealand, particularly for disabled communities who rely on CAD to be able to engage with content. Many submitters also mentioned that the proposal would extend equity and inclusion to those who speak English as a second language, or those who prefer to access media content with CAD.  

Concern about the cost and compliance burden

The primary concern submitters raised with the proposal was the cost of producing good quality CAD, and therefore the compliance burden legislative requirements would place upon content providers, particularly smaller providers with large content libraries.

Several submitters said that the current framework for funding Able through NZ On Air to produce CAD worked well and that the production of CAD should continue to be publicly funded, or that public funding for CAD should increase, or alternative funding should be provided, such as through subsidies, grants, or tax incentives.

Some submitters were concerned that without ongoing public funding, content providers would “race to the bottom” to meet requirements as cost efficiently as possible (e.g. by using AI) at the expense of maintaining good quality CAD.

Submitters also thought it was important that progressive targets be implemented over time so that content providers could meet targets in a timely and cost-efficient manner.

Technical limitations currently restrict accessibility

Several individual submitters indicated that local streaming platforms such as TVNZ+, ThreeNow, Māori+, and Sky Go do not provide full CAD services, while CAD levels on local linear broadcast channels tend to be better.

All local broadcasters that submitted were supportive of increased CAD, but outlined constraints in terms of technological capability, particularly in terms of providing audio description.

A few submitters, particularly those from the disabled community, said that they often preferred to use international streaming platforms due to the technical limitations of local streaming platforms. However, they would like to be able to use local platforms instead to access more local content.

Artificial intelligence (AI) aids efficiency but has limitations

Several submitters raised the emerging use of AI in relation to CAD. Submitters were divided on the use of AI, with some viewing it as a cost-efficient method of producing CAD, while others expressed concerns over AI’s ability to produce quality CAD specific to New Zealand audiences (e.g. be able to caption te reo Māori or produce audio descriptions with a New Zealand accent or voice).

Some submitters representing broadcasters and streaming services advised they are already experimenting with or implementing AI into the production of their CAD, particularly for captions. Some submitters suggested that AI is improving and could be used to produce CAD now or soon. However, other submitters were concerned that AI is not yet competent enough to produce good quality captioning and audio description without significant human quality assurance.

Additional requirements

Many submitters who agreed with the proposal suggested additional requirements alongside the proposed requirements for progressive levels of CAD. These additional requirements included:

• having standards or guidelines to ensure CAD is accurate and good quality
• including requirements to have New Zealand Sign Language (NZSL) alongside broadcast and streamed content
• ensuring that content providers, particular online streaming services, have assistive technology (e.g. screen readers) to accompany CAD, particularly for those who are blind or have low vision
• using New Zealand or local accessibility providers to produce CAD, particularly for local content (e.g. Able currently produces CAD services for local content).

Proposal 4: Modernising professional media regulation

This proposal would modernise the broadcasting standards regime to cover all professional media operating in New Zealand, not just broadcasters.

There were 117 submissions on the proposal, with 67 representing organisations and 50 from individuals.

• 45 supported the proposal
• 28 supported the proposal with changes
• 27 opposed the proposal
• 17 submissions were unclear on their position.

The key themes in the submissions were:

• support for regulation applicable to all media content providers
• need for a simplified regulatory system
• support for self-regulation.

Support for regulation applicable to all media content providers

The majority of submitters called for a future-focussed media regulatory system that included media content providers and user-generated content (social media platforms). The largest number of submissions specifically called for social media platforms to be included within the regulatory regime. These submitters argued that user-generated content reaches a larger audience and therefore has the potential to cause more harm and disinformation.

Many media stakeholders called for global content platforms to be subject to the same responsibilities and obligations (including financial and regulatory obligations) as New Zealand media companies. This would increase the consistency and durability of media regulation in New Zealand. Many media organisations specifically advocated for the inclusion of YouTube under the definition of ‘professional media’, as this platform has a significant degree of editorial curation, and a large volume of professional media content.

In trying to address the need for some form of statutory oversight of social media platforms, some submitters suggested the platforms’ inclusion be based on their revenue and reach.

Separately, a few community radio stations suggested a tiered approach to regulation that considers the scale and scope of media distributors. This approach would ensure appropriate levels of accountability and proportionate compliance requirements to the media company’s financial constraints. This option would protect small community radio stations, while also allowing for innovation and growth for media start-ups.

Need for a simplified regulatory system

Many submitters commented on the proposed function of the regulator and that it would add more complexity to the regulatory system, as opposed to simplifying and strengthening it. These comments related to the proposed ability to hear appeals on complaint decisions made by industry bodies. Many considered that the proposal would add another layer of adjudication to regulation that was duplicative and unnecessary.

The Broadcasting Standards Authority (BSA) advocated for the need to simplify the regulatory system, by making it easier for users to navigate, for content creators and providers to comply with, and for regulators to regulate. One broadcaster considered that the proposal does not achieve simplicity for consumers and perpetuates an unduly costly system, with complaints requiring time, cost and resource.

Many submitters raised the added complexity of the separate classification system for Commercial Video on Demand (CVoD) to operate alongside the proposed media regulator. Some submitters strongly recommended including the Films, Videos, and Publications Classification Act 1993 within the scope of the proposal to address gaps and overlaps between how content is regulated.

Some broadcasters and streaming platforms strongly recommended avoiding the compliance duplication under the Classification and Broadcasting Acts. Currently, some content providers operate both broadcast and streaming services and so are subject to both the CVoD and the BSA regulatory regimes.

Te Mana Whakaatu Classifications Office noted there are both gaps in and overlaps with the CVoD regime when it comes to parity between providers. The independent Crown entity advocated for an effective regulatory system to be focussed on mitigating harm from viewing content, rather than be determined by providers’ operating models which evolve over time. One broadcaster advocated for the scope of the regulator to be platform-agnostic, focused on the consumer experience.

Some submitters suggested establishing a single, independent national media regulatory and classification standards body, to cover audio-visual content, including broadcasting, social media, traditional print, literature and film.

Costs and compliance

A few submissions raised the associated costs with a new regulatory system. The BSA noted it is important to ensure that any new regime does not impose burdensome costs on an already struggling broadcasting industry.

Some smaller media organisations were opposed to levies to fund the regulator, while other submitters stressed it must be cost-efficient to reduce compliance costs for local media businesses and emerging media forms with limited resources. One submitter suggested that requiring the payment of a levy would be seen as an indirect form of state influence. This organisation advocated instead for a self-regulatory body to be primarily funded through membership fees to maintain independence.

Some broadcasters and streaming platforms noted CVoD providers already pay an annual levy, meaning some content providers are paying two sets of levies to two separate regulatory systems.

Support for self-regulation

In considering the proposed regulator’s functions, a few submitters referred to the merits of the current NZ Media Council self-regulation process. Many media organisations were supportive of the public access to a free, quick and simple complaints service.

These submitters did not support introducing a right to appeal from Media Council decisions, as they were supportive of the policy where complainants are required to forgo this right when they lodge a complaint. The purpose of the waiver is to ensure that a complaint to the Media Council is the only form of formal action that will be taken in relation to the article that is the subject of the complaint. In contrast, one organisation considered this limitation to not be in the public interest, and advocated for a standard practice of legal appeals against the statutory regulator’s decisions.

Rather than the proposed Government back-stop for complaints, many submitters were more supportive of a clear, accessible, and independent processes within the self-regulatory framework for unresolved disputes. Many media organisations and other associations strongly supported expanding the function of the Media Council to be the independent self-regulatory industry body to administer standard codes and process complaints for the media industry. This position aligned with other submitters singling out the importance of a media regulator being independent from the Government.

A few submitters noted the risk associated with the voluntary nature of self-regulation, in terms of how to ensure consistency and inclusivity of these frameworks, and how this could lead to discrepancies in how media organisations address complaints.

A few submissions raised the potential risk of this proposal to free speech. These submitters noted that moving away from industry self-regulation by broadening regulation functions of the government regulator could increase the risk of state intervention in media content and could stifle the diversity of voices essential to a democracy. One organisation acknowledged the increased perceived lack of independence that comes with extra regulation. A media company stressed further layers of government regulation would undermine media independence and press freedom, while a few organisations advocated for any regulatory framework to be sufficiently robust to protect freedom of expression.

Alternatives

Other submitters suggested a light touch approach for a government regulator similar to the United Kingdom’s Office of Communications (Ofcom) model that brings together all sectors across media, technology and creative industries, or the Irish Media Commission. One submitter recommended the establishment of an Office of the Media Commissioner with a role similar to the Telecommunications Commissioner or Ombudsman.

A broadcaster requested a consumer-focused and platform-neutral approach to this regime, focusing on the audience and matters of content and community standards and safety. One submitter advocated to focus regulatory efforts on the manner of content delivery (i.e. how it was funded, clearly labelling opinion pieces) rather than the substance of the content itself.

Proposal 5: Streamlining Crown content funders

This proposal would consolidate the New Zealand Film Commission (NZFC) and NZ On Air into a single content funding entity to improve efficiencies and support strategic funding outcomes, including by pooling resources and focusing industry development efforts.

There were 146 submissions on the proposal, with 76 representing organisations and 70 by individuals.

• 61 supported the proposal
• 31 supported the proposal with changes
• 28 opposed the proposal
• 26 submissions were impartial or unclear on their position.

The key themes in the submissions were:

• remit and functions of a consolidated entity
• concern about a ‘single door’ for content funding
• concern about the industry disruption and cost of change
• importance of continued platform funding.

Remit and functions of a consolidated entity

The biggest issue for submitters providing feedback on a consolidated entity is what a new entity would do in place of the current funding entities.

A significant number of stakeholders expressed an expectation that should consolidation go ahead, there would be thorough engagement with them on the remit and functions of a consolidated entity. Many submitters wanted reassurance that it would absorb and carry over the remits of both current entities, namely economic development of the screen sector and funding diverse local stories.

While many submitters expressed mixed views on the roles of the NZFC and NZ On Air, most agreed that the NZFC has more of an economic focus and NZ On Air has a more concerted effort towards promoting cultural content. Both entities, in their submissions and ongoing discussions with the Ministry, maintain a commitment to supporting both focuses. NZFC’s submission stated the “unique and distinct voice” of NZ film needs to be prioritised in a merged entity, while NZ On Air commented that “while our legislated remit is cultural, our impacts include strong economic benefits.” Submitters suggested that working with the sector on clarity for how a consolidated entity would support these focuses is of great importance.

While some submitters suggested that gaming, music, platform funding, and international film attraction be separated from this consolidation, most, including NZ On Air, were supportive of the entity retaining all funding functions. The key piece of feedback was that each subsector is unique and requires in-house expertise from whichever entity funds it. The New Zealand Screen Production Rebate, both domestic and international, was consistently mentioned across submissions as a valuable programme that needs to continue, regardless of its administrator.

Concern about a ‘single door’ for content funding

Some submitters were concerned that combining two entities into one might reduce competition and limit funding opportunities for different types of productions. They considered there is a risk that limiting the media sector’s funding opportunities to one institution may create perceptions that this one outlet has a disproportionate amount of influence over the sector. Other submitters suggested that the risk of diluting funding when one entity has greater oversight of the entire sector should be taken into account.

Concern about the industry disruption and cost of change

Many submitters expressed concern that this proposal is a significant change to a sector that has already undergone much transformation in the last few years. Since 2021, the media sector has responded to a government strategic framework for a sustainable media system, a government review of investment in the screen sector, the restructure of the NZFC, a one-year check in on the Screen Production Rebate, and targeted consultation on the Amplify creative and cultural strategy.

These submitters noted the risk that a consolidated entity could have on sector stability and believed that further consultation with stakeholders would be essential to manage disruption. One organisation thought the proposal was a distraction from other more important priorities needed to protect the local industry. A guild considered the timing and the potential for disruption to be of significant concern to producers. Another organisation noted recent changes in the sector had created production delays and insecurity for the industry, screen businesses and international partners.

The cost of this proposal was also raised, with one submitter reinforcing that this proposal “would require significant investment to carry out and it is unclear where the money would actually come from to do this.” Some submitters were concerned that finding cost efficiencies through this exercise would result in less investment in the media sector, with several submitters indicating that the combining of entities must not result in a reduction in funding levels. Some submitters also suggested that consolidating entities would be an opportunity to increase investment in the sector.

Importance of continued platform funding

In response to the questions asked on the role of media platform funding, a large number of submissions noted media platforms’ value to audiences and that NZ On Air’s current platform funding should remain with a consolidated entity. These submitters considered it important that the consolidated entity looks beyond screen to the wider media ecosystem and provides support to a range of platforms. These platforms include public and community access radio, archiving platforms and CAD services.

Footnotes

Next steps

This feedback is currently informing further analysis, detailed design, and Government decisions on the Media Reform package. Any final decisions on Media Reform will require Cabinet approval.

Appendix one: Public engagement

Public consultation commenced on 12 February and closed 23 March 2025.  The Ministry hosted two introductory webinars on the Media Reform proposals on Wednesday 19 February and Friday 21 February 2025 and were attended by over 120 people. Online workshops were held for each proposal. The Ministry also held separate sessions with the New Zealand Film Commission and NZ On Air staff to discuss Proposal 5: Streamlining Crown content funders. Consistent with the approach to public workshops, these sessions were an opportunity for entity staff to discuss the proposal, raise any questions and provide initial feedback.

Online survey

People interested in providing feedback on the proposals were invited to complete an online survey. A printable version of the survey was also made available on the Ministry’s website: Media Reform survey – printable version.

Written submissions (via email or post)

People wanting to provide more detailed feedback were invited to email submissions to [email protected] or mail a submission to the Ministry’s PO Box address.

Webinars and workshops

A series of online webinars and workshops took place in February and March 2025 with stakeholders from different parts of the media sectors:

Appendix two: Submissions statistics

Table 1. Number of written submissions / survey responses by submitter

Table 2. Number of submitters that commented on the various proposals

Table 3. Number of submitters in support or opposition to each proposal

Appendix three: List of submitters

Able

Access Radio Taranaki

Access Radio Wairarapa

Adam Isdale

Advertising Standards Authority

Aedan Ward

Ahmed Osman

Aidan Paul Manchester

Alexander (Axel) Paton

Allied Press

Andrew Mark Bell

Andy Galbraith

Apple

APRA AMCOS

Arthur Wang

Arts Access Aotearoa Putanga Toi ki Aotearoa (Conor Twyford)

Audio Described Aotearoa Ltd

Australia New Zealand Screen Association

Barrie Garnet Saunders

Benjamin John Reilly

Better Public Media Trust

Blind Citizens NZ

Blind Low Vision NZ (Cain Richardson)

Bob Deakin

Brian Finn

Broadcasting Standards Authority (BSA)

Canterbury Communications Trust

Canterbury Kia Ora Academy Trust

Chris Hibbert

Christian Broadcasting Association

Citizens Advice Bureau Christchurch Area

Community Access Media Alliance

Computer & Communications Industry Association

Consumer Electronics Suppliers Association (Evelyn Soud)

Cris Fulton

Creative Industries Futures, Toi Rauwhārangi, Massey University

Creative Waikato

Cult Chat Podcast and Radio Show (Dr Caroline Ansley)

Dan Kircher

Dan Salmon

Danie James Pickstone

David Ager

David Harvey

David Piper

Deaf Aotearoa

Dean Thomas

Digital Media Trust

Directors and Editors Guild of Aotearoa New Zealand

Disability Responsiveness New Zealand Ltd (Managing Director Dr Pam MacNeill)

Disabled Persons Assembly

Dr Trisha Dunleavy 

Electoral Commission (Benjamin Baker)

Equity NZ

Erin Murdie

Film Auckland

Film Crew Services Ltd (Sioux Macdonald)

Film Otago Southland

Free Speech Union

Freeview NZ

Fresh FM

Gary Davies

Gaylene Barnes

General Film & Communications, Endeavour Ventures and Libertine Pictures

Geoff Neal

Godwit Films (Jeremy Macey)

Graham Dunster

Grant Baker

Great Southern Studios

Greenstone TV

Guillaume Renier

Haley Williams

Hillary Kate Peacocke

Ian Murray Mills

Imogen Bunting

Interactive Games & Entertainment Association

Jack Marshall

Jack Tankersley

Janet Lawson

Janice Brown

Jeanie-May Willis

Joanne Walker

John Calder

John F Cantin

Justin Pemberton

K Govindaraju

Kandy Wahanui-Peters

Katherine Wyeth

Kay Howe

Kent Belcher

Kezia Bennett

Kim Coates

Kitty Rachel Conner

Koi Tū

Les Davis

Lois (and Martin) Griffiths

Luke East

Luke Hiscox

Luke Nola

Magdalina Dilley

Manawatū Access Media

Marie Tricart

Mark Jones     

Mary Schnackenberg

Matthew J. Saville

Maureen Passmore

Melissa Wells

Michael Halstead

Michael Paletta

Natalie Malcon

NBC Universal

Netball Central Zone

Netball New Zealand

Netflix

Netsafe

New Zealand Film Commission (NZFC)

New Zealand Music Commission

New Zealand Sign Language Board

New Zealand Society of Authors

New Zealand Writers Guild

News Publishers Association

Ngā Aho Whakaari / Kawea te Rongo

Ngā Taonga Sound & Vision (Stephanie Lay)

NHNZ Worldwide

Niche Media Ltd

Nicholas Green

NZ Comedy Trust

NZ Film Producers Alliance

NZ Media Association

NZ On Air

NZ Studio Group

NZME Ltd

Oscar McNoe

Pacific Islands Screen Artists Inc. (Abba-Rose Vaiaoga-Ioasa)

Pan Asian Screen Collective

Patrick O'Rourke

Paul Brown

Peter Fowler

Peter Meteherangi Tikao Burger

PlainsFM

Planet FM

Precise Digital Ltd

Privacy Commissioner

Public Media Alliance

Rachel Daniels

Radio Broadcasters Association

Radio Hawke's Bay

Radio New Zealand

Razor Films (Mark McNeill)

Reality Check Radio

Recorded Music NZ

Regional Film Offices of New Zealand

Renae Maihi 

Robin Laing

Roseanne Liang

Sarah Crawford

Scott Baker

Screen Industry Guild

Screen Music and Sound Guild

Screen Production and Development Association

Shannon Knight

Sigmund Spath

Simone Faets

Sky NZ

Sophie Bretherton-Jones

South Pacific Pictures

Spotify NZ

Stefan Olson

Steven Crundwell

Student Radio Network

Stuff

Susan Adele Thompson

Tāhono Media

Tanya Wheeler

Tash Christie

Taxpayers' Union

Taylor Nixon

Te Mana Whakaatu Classifications Office

Te Puna Matarau - Canterbury Screen Industry Association (Anna Canton)

Te Tari Tuhi Kupu A Whakaahua Script to Screen

Tegan van der Peet

Television Networks and Production Companies (Great Southern Television, Greenstone, Kevin & Co., Libertine Pictures, Pango, Sky, South Pacific Pictures, TVNZ, WBD)

Television New Zealand (TVNZ)

Tess Pilkington

The Physics Room Trust (Chloe Geoghegan)

The Spinoff (Amber Easby)

The Waikato Community Broadcasting Charitable Trust trading as Free FM 89.0 (Philip John Grey)

Thomas Bryan

Tjarda Wierdsma

Tony Holden

Vicki Keogh

Victoria Spackman ONZM

Warner Bros. Discovery

Warner Bros. International Television Production NZ

WeCreate

Wellington Access Radio

Whakaata Māori

Women in Film and Television