Automakers are turning their cars into rolling media hubs – and German regulators have already set important precedents: in 2024, the state media authorities classified the in‑car entertainment systems of several automakers as user interfaces, and the “Tesla Media Player” is additionally treated as a media platform. This makes clear that access to and discoverability of media services in cars are subject to media regulation.
The German Interstate Media Treaty (MStV) defines media platforms as services that combine broadcasting, broadcast-like or journalistic-editorial telemedia into a comprehensive offering determined by the provider (e.g. the OEM curates and controls an overall line‑up of third‑party radio, streaming and video apps such as Spotify, YouTube).
User interfaces, on the other hand, are the textual or acoustic overview of offerings or content on media platforms.
Providers of media platforms are required to
- notify the state media authorities one month before going live.
- ensure non-discriminatory access by guaranteeing equal access conditions for all content providers.
- Changes to media offerings may not be made without the consent of the content providers.
- Platforms that reach a certain minimum size must meet certain transparency requirements. For example, media platform providers must be transparent to their users about the principles according to which offerings are granted access to their platform. This includes, among other things, information about the criteria used to sort, arrange, and present content on their platform.
If an in‑car entertainment system qualifies as a user interface, the following requirements must generally be met:
- No preference for own offers or offers of third parties against payment
- Sorting of apps in the offering must be easily customizable by users on a permanent basis
- Broadcasting must be accessible at the first selection level with one click
- Publicly financed and public value broadcasting must be easy to find (if included on the platform)
In other words: the way you design and organize your in‑car media offering is no longer just a UX decision, it is a regulated activity. OEMs should therefore assess now whether their current and planned infotainment systems qualify as a media platform and/or user interface under the MStV, and if so, implement compliant product, UX and contractual setups early on and take the necessary legal compliance steps – for example, fulfilling the notification obligation vis‑à‑vis the competent state media authority. Doing this proactively reduces regulatory risk, avoids costly redesigns after launch and gives legal certainty for future, media‑rich vehicle generations.
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