This article was the Topic of the Week in the newsletter of KW 45 in 2025.

Proven private providers

Necessary photos have long been reliably created by private sector companies, such as specialist photography retailers, drugstores, or vending machine operators. Since May 2025, the required digital transmission ensures that no morphed (i.e. computer-altered) photos end up on official documents. To meet the requirements, service providers have invested significant sums. The basis for this is the "Law to Strengthen Security in Passport and ID Matters," passed by the Bundestag in 2020, which explicitly provides for choice in passport photo creation — for citizens as well as municipalities.

State enterprise advantage

The Federal Printing Office, a state-owned company, has also invested and developed a biometric data acquisition system called PointID, which is now to be provided to as many municipalities as possible. 171 million euros are to fund approximately 10,000 PointID photo booths for 6,000 municipalities over five years. The funding was originally supposed to be covered by a photo fee of 6 euros that municipalities collect and forward to the Federal Printing Office, as stipulated in the 2020 law. However, a March 2025 decision by the Federal Ministry of the Interior stated that this photo fee would entirely remain with municipalities. The resulting funding gap is now "solidarily" closed through an increase in the general ID card fee from 37 to 46 euros.

Choice undermined

A problematic cross-subsidization from the perspective of the private sector: Municipalities receive revenue without incurring direct expenditures. This incentive actively motivates them to prefer using PointID over other private provider systems. The result is that citizens are effectively forced to use municipal systems, even though they are legally entitled to free choice in photo creation. Furthermore, the possibility to consider alternative systems is limited by the cross-subsidization of PointID via ID card fees. The German Chamber of Commerce and Industry (DIHK) warns against a loss of significant investments by private companies in innovative acquisition systems.

Against this backdrop, the DIHK critically evaluates the planned increase in ID card fees. Although the 2020 reform aims to strengthen digital processes and ease administrative burdens, the "solidary" funding of the Federal Printing Office’s PointID system leads to significant market distortion and a loss of innovation potential.

Existential threat to businesses

Private photo providers are under pressure due to these developments. Demand for externally produced passport photos is declining, resulting in revenue losses. For many specialist photography stores, passport photo creation accounts for up to 50 percent of revenue. A decline in this income jeopardizes locations and jobs. The DIHK predicts that around 1,500 jobs may be affected. Negative effects on municipal trade tax revenue and – due to vacancies and declining customer traffic – on the attractiveness of city centers also loom.

Fair competition needed

The DIHK demands:

• A waiver of the ID card fee increase if it does not exclusively cover increased administrative and production costs
• Market-conform photo fees that reflect all costs of the PointID system – including development, rollout, and support
• Ensuring citizens' freedom of choice in photo creation
• Fair competition conditions for all providers – without state favoritism of specific systems

A functioning competition is the prerequisite for innovation, diversity, and economic stability. However, the current fee structure endangers these principles – and thus the economic foundation of many small and medium-sized enterprises.