Introduction
Since the early 2010s, “Video On Demand” (VOD) has steadily captured an increasing share of Iranian media consumption and has begun to play a key role in the country’s overall media landscape. From its inception until now, there have been many disputes among various executive bodies about how VOD should be regulated, and no clear, optimal regulatory framework has been established. To envision an ideal scenario, it’s necessary to analyze the historical background first. This study seeks to establish a preliminary framework for regulation by identifying key historical events, segmenting the timeline using major milestones, and then pinpointing the emerging issues. The ultimate goal is to support and help policymakers in designing strategies that reflect the sector’s evolving complexities, based on documented evidence.
Methodology
This research employs documentary studies and interviews with experts and well-informed professionals. Data were analyzed using a descriptive and analytical approach. Themes were extracted from historical events and organized into analytical tables in chronological order. Expert feedback helped to identify key historical turning points, leading to the division of the timeline into distinct periods. For each period, a summary of the relevant themes was provided. Using these tables, the regulatory issues in the VOD sector were further categorized. Finally, to ensure the validity of the findings, the analytical tables were shared with experts, and additional input was incorporated based on their advice.
Discussion and Results
Based on the findings, the evolution of VOD regulation in Iran can be divided into five periods, each marked by historical milestones:

Period of Ambiguity and Instability (2011–2019)
Period of Stabilizing Iran's Audiovisual Media Regulation Authority (SARTA) (2019–2021)
Period of SARTA’s Decline (2021)
Period of Management and Approach Changes at SARTA (2022)
Period of Early Convergence (2023 and Beyond)





Period Title


Date


Measures Taken




Ambiguity and Instability


2011


The Ministry of Culture and Islamic Guidance appointed the Institute of Visual Media to regulate and propose legal frameworks for VOD




2014


IRIB was tasked with overseeing comprehensive audio-visual content (including VOD) per an order from the Supreme Leader




2015


A directive from the Supreme Leader to the then-President underscored IRIB’s exclusive mandate to regulate comprehensive audio-visual media in the digital space




2016


SATRA, under IRIB, was launched




Stabilizing SARTA


2019


Efforts focused on stabilizing the licensing process for audio-visual media platforms under SATRA, with intervention from the prosecutor’s office marking the end of fragmented regulation in the VOD sector




2020


Additional steps were taken to stabilize licensing for digital content by including a dedicated budget line for SATRA in the 2020 Budget Law and transferring production permits to IRIB.




SARTA’s Decline


2021


Responsibilities within IRIB became divided after the establishment of a Secretariat for the Production Permit Council within its Planning, Programming, and Budget Center (the “Almas” system). This coincided with efforts by the Ministry of Culture and Islamic Guidance under the 13th government to reclaim regulatory authority, as evidenced by the removal of SATRA’s budget line in the 1401 Budget Law




Management and Approach Changes at SARTA


2022


A change in SATRA’s management brought about shifts in regulatory approaches and altered the organization’s interactions




Early Convergence


May 2023


A memorandum of understanding was signed between IRIB and the Ministry of Culture and Islamic Guidance under the auspices of the Office of the Supreme Leader.




July 2023


The Supreme Council of the Cultural Revolution passed a resolution aimed at better organizing comprehensive audio-visual content




 
Based on the analysis of these developments, the study identified several key regulatory challenges in Iran’s VOD sector:

Lack of Political Consensus: There is significant internal and inter-agency disagreement—especially regarding private sector activities—with various bodies alternately viewing them as opportunities or threats.
Outdated Legal Framework: Unclear platform responsibilities—and, more broadly, an ambiguous legal framework governing their rights and obligations—along with vague regulatory competencies, the lack of clearly defined duties for some regulators, the way offenses and penalties are legally codified, insufficient guidelines for international interactions among platforms, weak rules on foreign investment, and inadequate child protection measures are all issues in urgent need of legal reform.
Impact of Political Change: Frequent shifts in government and political priorities have significantly influenced policymaking and regulation, undermining public trust.
Fragmentation of Regulatory Bodies: There is an excessive number of decision-making organizations compared to the real market players, leading to fragmented governance.
Unclear Institutional Relationships: The roles and boundaries between regulatory bodies and other institutions (legislative, executive, and judicial) are undefined, resulting in overlapping authorities and interference.
Conflicts of Interest: Competing interests at both intra- and inter-organizational levels have led to conflicts in regulatory practices.
Unresolved Theoretical Issues: Persistent questions remain on issues such as whether broadcast regulations should be the same as broadband ones, where the boundary lies between comprehensive and non-comprehensive content, and what the optimal regulatory model should be.
Incomplete Regulatory Approaches: Some regulators tend to adopt overly restrictive policies instead of more facilitative ones; in some cases, there is a narrow focus solely on content, neglecting industrial and economic aspects.

Conclusion
The study concludes that the main challenges in VOD regulation stem from a lack of policy consensus and the proliferation of governance bodies in the media sector. The key recommendation is to develop an integrated, overarching media policy that can achieve consensus among various agencies. Although the ideal long-term solution would involve establishing an independent, comprehensive media regulator that brings together all stakeholders, this is a gradual process requiring the gradual development of cognitive, legal, and discursive capacities in the country. As a more immediate measure, establishing a “regulator of regulators” or at least fostering effective, legally structured coordination and a clear division of responsibilities among existing regulators is recommended.