Youth Protection Officer
Advisory and complaints contact for the protection of minors in media. Content age-rating review, technical youth-protection measures, and input on programming and platform design.
JMStV § 7 · JuSchG
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What is a Youth Protection Officer?
A Youth Protection Officer, in German Jugendschutzbeauftragter, is the advisory point and complaints desk for the protection of minors in media inside a broadcaster or telemedia provider. The subject is the protection of children against media content, not the protection of young people at work: the role covers content and platform design, not the employment of minors in a company. It gives users a defined contact and works to keep offerings from impairing the development of minors.
The central provision is § 7 of the Jugendmedienschutz-Staatsvertrag (JMStV, the interstate treaty on the protection of minors in media). It requires a youth protection officer from anyone broadcasting cross-state licensable television, and from commercial providers of licence-free television under § 54 Medienstaatsvertrag or of generally accessible telemedia with content that may impair or endanger minors. § 7 Para. 3 JMStV exempts intermediary services under Regulation (EU) 2022/2065. The officer must be involved in questions of the protection of minors, advises the provider on the offering as well as on restrictions, and serves as the point of contact for users. The JMStV is complemented by the Jugendschutzgesetz (JuSchG, the federal youth protection act), which governs carrier media, age ratings and, since its reform, provider precautions plus the role of the Bundeszentrale (the federal agency for the protection of children in media).
The officer reviews the age rating of content, advises on technical measures such as age verification, scheduling or youth-protection programs, contributes to programming and platform design, and handles user complaints. The JMStV does not require the officer to be an employee; under § 7 Para. 5 JMStV the provider supplies the resources and grants paid release from work so far as the role requires.
Supervision rarely takes issue with a single rating. What shows up instead is missing trace. The officer is appointed, but the contact details that § 7 Para. 1 JMStV requires to be kept available are out of date. Complaints are answered by support, the officer never sees them. A new format goes live, involvement is obtained only afterwards, against the rule on timely involvement. Or the assessment of an offering survives as an email thread nobody can reconstruct later. In practice the role needs three things: a documented appointment plus proof of expertise, a named route by which complaints reach the officer, and a deputy for holiday or sickness so the complaints desk stays staffed.
Duties of the Youth Protection Officer
- Act as the contact point for users and advise the provider on the protection of minors under § 7 Para. 4 JMStV
- Review the age rating and classification of content against the JMStV and JuSchG categories
- Advise the provider on technical youth-protection measures such as age verification and youth-protection programs
- Contribute to programming, scheduling and platform design so impairing content is appropriately restricted
- Handle complaints about content that may impair the development of minors
- Assess developmentally impairing and inadmissible content and recommend removal or restriction
- Support the provider in fulfilling precaution duties under the reformed JuSchG
- Liaise with the competent supervisory bodies and recognised self-regulation institutions
- Document reviews, advice and complaint handling so decisions remain traceable
Appointment of the Youth Protection Officer
§ 7 Para. 1 JMStV requires an appointment from anyone broadcasting cross-state licensable television. The same applies to commercial providers of licence-free television offerings under § 54 Medienstaatsvertrag and of generally accessible telemedia where the offerings carry content that may impair or endanger minors. Under § 7 Para. 3 JMStV the duty does not apply to intermediary services within the meaning of Article 3 point g of Regulation (EU) 2022/2065. The provider must keep essential information about the officer easily recognisable, immediately reachable and permanently available, in particular a name and data allowing rapid electronic contact. Under § 7 Para. 4 JMStV the officer must be involved appropriately and in good time in the production, acquisition, planning and design of offerings and in all decisions on the protection of minors, and must be fully informed about the offering.
The officer must have the expertise the tasks require. Under § 7 Para. 2 JMStV telemedia providers with fewer than 50 staff or demonstrably fewer than ten million monthly accesses on a yearly average, as well as broadcasters that do not broadcast nationwide, may waive the appointment if they join an institution of voluntary self-regulation and oblige it to carry out the tasks.
Under § 7 Para. 5 JMStV the officer is free from instructions, may not be disadvantaged for carrying out the tasks, receives the necessary material resources and is released from work on continued pay so far as the tasks require. The appointment, the proof of expertise and the published contact details should be documented and kept current.
- Broadcasting cross-state licensable television under § 7 Para. 1 JMStV
- Commercially offering generally accessible telemedia with content that may impair or endanger minors
- Commercially offering licence-free television under § 54 Medienstaatsvertrag
- The provider operates an offer requiring age verification or scheduling restrictions
- Losing the § 7 Para. 2 JMStV waiver, for example on passing 50 staff or ten million monthly accesses
Industries and Sectors
- Broadcasting and television
- Video-on-demand and streaming platforms
- Video-sharing services with duties under §§ 5a and 5b JMStV
- Online games and gaming platforms
- Adult-content and dating services
- App stores and digital distribution
- Publishing and online media
- Telemedia and web portals
How CIVAC supports the Youth Protection Officer role
CIVAC keeps the appointment of the youth protection officer under the JMStV (Interstate Treaty on the Protection of Minors in the Media) as a role file. The appointment itself, the evidence of expertise, the contact details registered with the Landesmedienanstalt (state media authority) and the stand-in for leave and sickness sit in one place, each flagged before it has to be brought up to date.
Age-rating reviews, advice on technical measures and the handling of complaints run as cases with a date, a handler and an outcome, so the provider can show how an offering was assessed and when the officer was involved. Recurring reviews of youth protection software, age verification and scheduling are tasks with a reminder. Role templates give the assessment and the complaint case a fixed structure, training is recorded per person, and the append-only audit trail makes later changes visible. The role costs 49 euros per month, with the option of appointing an external officer through CIVAC.
Frequently Asked Questions
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