The ABC is opposing an extension of content quotas to its own activities – as it would undermine independence – but supports reform of existing rules. It argues for an across-the-board 40 per cent tax rebate for Australian producers with extra support for specialist documentary programs like arts, science and religion and that any regulation of children’s content apply to online services like Netflix and Stan.

SBS has not endorsed any of the options laid out in the paper except the tax rebate for producers. However it proposes additional funding so that it can provide Aboriginal and Torres Strait Island children’s content and premium multi-cultural and multilingual drama to address the decline in Australian programming created by commercial broadcasters.

But the two views differ from commercial television networks. Free TV has called for the complete removal of quotas supporting Australian drama, children’s content and documentary and the extension of tax subsidies to reality, while retaining their commitment to broadcast at least 55 per cent Australian content overall.

Under existing guidelines commercial broadcasters are required to show 260 hours of children’s programs and 130 hours worth of preschool programs. Australian content guidelines also require at least 250 points of first-release Australian drama, and 24 hours worth of children’s drama.

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“This model would provide maximum flexibility to allow commercial free-to-air broadcasters to respond to audience preferences and pivot as necessary to genres that are in demand and can be monetised,” the lobby group said in its submission.

However if the government opts to retain sub-quotas governing drama, children’s and documentary, Free TV wants to “spend” all its quota points on some genres and ignore others. It would also be free to focus on “drama content with higher production values and global appeal” – in other words, fewer hours of “better” Australian drama content. It has also argued for more weight to be given to serial dramas such as Neighbours or Home and Away. Like the ABC, Free TV supports a 40 per cent producer offset.

Netflix, which has previously created Australian titles like Lunatics, The White Rabbit Project, and Tidelands, is asking for voluntary guidelines to be created for streaming services and for investment in local content to be made at their own discretion. It proposes that streaming services advise the Government annually of contributions to the sector, which would allow it to assess whether more “targeted regulatory action” is required. Netflix declined to provide figures on the amount it currently invests in Australia content or the size of its local subscriber base.

Free TV argues shows like Lego Masters, starring hosts Hamish Blake and 'Brickman' Ryan McNaught, ought to attract the same level of subsidy as drama.

Free TV argues shows like Lego Masters, starring hosts Hamish Blake and ‘Brickman’ Ryan McNaught, ought to attract the same level of subsidy as drama.Credit:Nine Entertainment

The Australian Children’s Television Foundation wants the government to provide a universal 30 per cent tax rebate for producers. It also supports the removal of the P (pre-school) and C (children’s) category requirements for commercial broadcasters – shifting the responsibility to the ABC and SBS – with an amended obligation on the commercial networks and streamers to make and screen content for children aged 0-16.

SPA’s submission argues for a flexible scheme that would allow each broadcaster or streamer to tailor a programming mix in consultation with the regulator – the ACMA or a new body. It would be bound by a “new revenue-based expenditure obligation”, but existing drama and documentary sub-quotas would remain.

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SPA has also called on the government to double the production of Australian content, employment in the sector and the Australian production industry in five years”.

Arenamedia’s submission – which has the backing of a number of other independent producers and distributors – argues for quotas on the streaming platforms, a standardised offset, and targeted support for children’s content and feature films. But it also argues that a revised framework of regulation and subsidies needs to be flexible enough to adapt to innovations that are impossible to currently foresee.

The government has not indicated a precise time frame for its consideration of submissions or next steps. However, a spokesman for Communications Minister Paul Fletcher has indicated the government will consider all views as it looks at media reform.

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