Targeted initiative for a better copyright environment for European creativity and innovation

Regarding Article 4, rights reservation mechanisms are difficult to monitor and enforce, while differing technical standards create fragmentation and legal uncertainty. More importantly, the lack of meaningful transparency prevents rightholders from determining whether, how and to what extent their works have been used, whether rights reservations have been respected, and whether licensing opportunities exist.

First of all, we would like to strongly endorse the findings of our European Federation FERA (Federation of European Screen Directors). Our reply is intended to respond to the implementation of the DSM (2019) Directives and the related amendments to the Belgian Copyright Act (2022). The audiovisual sector in Belgium has a French-speaking and Flemish language reality. This response concerns the Flemish reality.

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RAAP, Recorded Artists Actors Performers CLG, is pleased to submit its response to the European Commissions Call for Evidence as part of the review of the Copyright in the Digital Single Market Directive / Targeted initiative for a better copyright environment for European creativity and innovation. RAAP is the Irish collective management organisation representing performers.

Anthropic is an AI safety and research company working to build reliable, interpretable, and steerable AI systems. We welcome the opportunity to respond to this call for evidence on the EU copyright framework. Advanced AI holds transformative potential as an engine of productivity and scientific progress across the EU - with the capacity to compress decades of advancement into years and accelerate discovery across…

A new legislative proposal should address the need of an EU framework ensuring open access to and reuse of all publicly funded research results. The framework should be based on rights retention obligation and open access publication obligation of all beneficiaries of public research funding enhanced by the mandatory secondary publication right that allows authors-researchers to publish all their research results in…

Warner Music Group welcomes the Commissions aims to enhance the resilience and competitiveness of the creative industries. Europes music industry is supported by a clear legislative framework, which is vital to business certainty and local investment. These aims would be best served by a focus on the implementation and enforcement of that framework.

Svenska Fotografers Förbund (SFF) is the national professional association for photographers in Sweden. SFF welcomes the Commission's focus on control, licensing and remuneration when protected works are used in generative AI. The DSM Directive introduced important principles, but it has not materially improved photographers' ability to exercise their rights in practice. Photography is particularly exposed.

Joint submission of challenger search engines to the call for evidence on the review of the Copyright Directive DuckDuckGo, Ecosia, Startpage We are companies operating privacy-respecting, challenger search engines in the EU.

1. Approach to consultation on the state of play on digital piracy of time-sensitive content. The Coalition highly appreciates that the Commission, in the current Call for Evidence, goes beyond the narrow approach that had so far characterised its action in this area and addresses online piracy not only with regard to live events, but also with regard to the broader category of time-sensitive content.

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The EU has updated its regulatory framework for the digital age, including the rules on copyright. The priority is now to ensure that these rules work in practice. The EU must deliver a full, consistent and meaningful implementation of the existing EU acquis, and ensure meaningful transparency of AI models and an effective single market for enforcement.

The EU copyright framework remains fit for purpose and should not be reopened prematurely. It is technologically neutral and flexible to address new developments, including the growing use of AI. Reopening copyright legislation at this stage would create legal uncertainty and business risk during a lengthy EU legislative process and subsequent national implementation.

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European Football Clubs (EFC) notes the European Commissions written and oral assessments of the effects of its Recommendation (EU 2023/1018) on combating online piracy of sports and other live events. In particular, EFC shares the Commissions conclusion that the Recommendation has failed to significantly curb the volume of live event piracy, notably due to the limited effectiveness of notice-and-action mechanisms…

Finnish Actors Union thanks the European Commission for its initiative to collect evidence-based input on the functioning of the CDSM Directive. The Finnish Actors Union represents over 2,000 professional Finnish actors working across theatre, film, television, radio, and digital media. We are responding to two specific issues: the use of performers works for AI training and AI-generated impersonation of performers.

Cloudflare welcomes the opportunity to respond to the European Commission's Call for Evidence on the Review of the Copyright in the Digital Single Market Directive and Targeted Initiative for a Better Copyright Environment. Please find our contribution attached.

In view of the members of the ELEXAI consortium, the exception for text and data mining (TDM) for scientific research purposes (Article 4 of Directive (EU) 2019/790) constitutes a long-awaited and welcome development for the European research community.

We are pleased to attach herein the response by the Irish Recorded Music Association (IRMA) to the Call for Evidence, as part of the review of the Copyright in the Digital Single Market Directive / Targeted initiative for a better copyright environment for European creativity and innovation.

Phonographic Performance Limited (PPL) is grateful for the opportunity to respond to the Commissions Call for Evidence. PPLs response is limited to the Commissions exploration of material reciprocity and the right under Article 8(2) of the Rental Directive.

The European creative fashion industryincluding luxury, apparel and footwearis a global leader and a major contributor to the EU economy. Our objective is to contribute to an EU copyright framework that reflects the specific characteristics of the industry and ensures that the value of its creative output is properly recognised.

Performers, Entidad de Gestión de Derechos de Propiedad Intelectual (hereinafter AISGE) is the collective management organisation authorised by the Spanish Government to administer the rights that Spanish Intellectual Property Law (Royal Legislative Decree 1/1996 of 12 April, amended by Laws 23/2006 of 7 July and 21/2014 of 4 November) grants to artists in their audiovisual performances and that, in particular, the…

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Getty Images submission focuses on visual content and the need for a reliable EU copyright framework to support legal and sustainable AI innovation, as well as a wider online ecosystem that incentivizes licensing.

The Bulgarian Association of Music Producers (BAMP) is a non-profit organization that brings together the leading companies in Bulgarias recorded music industry. Founded in 1996, BAMP represents and protects the rights and interests of producers of sound recordings and music videos in Bulgaria.

Confindustria Cultura Italia wishes to share with the European Commission its comments on certain aspects of the so-called Copyright Directive, a measure of particular interest to its member. The EU has updated its regulatory framework for the digital age, including the rules on copyright. The priority is now to ensure that these rules work in practice.

SNEP is the main professional organisation bringing together labels and producers of recorded music in France. Its members include the three major companies in the sector and almost 250 independent labels. Its members thus account for 80 % of turnover and 70 % of employees in the sector. SNEP is the French group of IFPI, the international federation of labels and record companies.

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The European Broadcasting Union (EBU) the worlds leading alliance of public service media (PSM) welcomes this crucial consultation. We welcome the targeted approach put forward and wish to comment on 1. generative AI and copyright, 2. piracy of live events, and 3. Follow-up to the RAAP case, as outlined in the attached document. We remain available to further exchange and input on these key points.

The Digital Poland Association, an organization representing the national digital and modern technologies sector, submits these comments and recommendations in response to the European Commissions Call for Evidence. We highly appreciate the opportunity to participate in these consultations, as we firmly believe this is a vital topic deeply connected to the future of European competitiveness.

France Digitale, a leading non-profit organisation representing French and European startups and venture capital firms, is pleased to contribute to this call for evidence on the review of the CDSM Directive. Our members include numerous European AI companies operating across the value chain, from model developers to deployers.

The Spanish Ministry for Digital Transformation and the Civil Service focuses its contribution on online piracy of live events. The diagnosis is shared, existing remedies are not sufficient to respond to piracy of live content. In particular, that the assessment that the 2023 Recommendation on piracy of sports events has had a limited impact.

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Please find attached AEVOD's -Spanish VOD Association- response to the Call for Evidence on the review of the Copyright in the Digital Single Market Directive. AEVOD represents the leading video-on-demand platforms operating in Spain.

The Independent Film & Television Alliance - IFTA - believes the Copyright Digital Single Market Directive 2019 has been a landmark piece of EU legislation, offering a strong enabling copyright protection infrastructure for EU creative industries, including the film and television sector.

News Media Europe (NME) is the voice of the progressive news media industry in Europe, representing over 2,700 news brands across print, online, radio and TV through national associations from thirteen countries.

GLOBAL TRADE BODY SUBMISSION ICMP is the global trade body representing the music publishing industry worldwide and welcomes the opportunity to provide this input. a. AI LICENSING The Call for Evidence cites challenges for rightholders in AI licensing.

PRS for Music is a world-leading music collective management organisation (CMO) representing the rights of more than 190,000 songwriters, composers and music publishers. Through direct licensing in Cyprus, Malta and the UK, and a network of almost 100 reciprocal agreements, we license over 45 million musical works worldwide, ensuring creators are paid whenever their musical compositions are streamed, downloaded…

STM is grateful for the opportunity to respond to the Call for evidence on a Targeted initiative for a better copyright environment for European creativity and innovation and provide information to support the EU Commissions assessment of the need for intervention and potential ways forward.

A central issue in the current debate is the ability to analyse lawfully accessible information at scale. A reliable TDM framework is key digital infrastructure, not only for AI development but also for research, cybersecurity, healthcare and broader economic productivity.

Video Games Europe welcomes this opportunity to respond to the European Commissions Call for Evidence concerning the review of the DSM Copyright Directive and a possible targeted initiative to support a better copyright environment for European creativity and innovation. We set out our position in the attached file. The European video games sector is one of Europes most dynamic creative and technological industries.

Europe could be addressing urgent competitiveness and societal imperatives through AI. The DSM Directive review will shape the regulatory environment in which Europes AI sector and AI adoption throughout the economy and society either thrives or stagnates. It presents a full spectrum of policy options from permissive to the most restrictive regime imaginable.

Skyscanner is a global travel metasearch service used by 160 million consumers globally every month. We welcome the Commission's objective of strengthening the resilience and competitiveness of Europe's content economy in the AI age, and we focus our feedback on two of the policy options identified: improving rightsholders' access to information on the use of their content, and enabling appropriate remuneration for…

IFPI Austria Verband der österreichischen Musikwirtschaft is the Austrian national group of IFPI and represents the interests of the Austrian recorded music sector in all cross-company matters. Its members include Austrian independent labels as well as the local affiliates of international music companies, together representing around 90% of the Austrian music market.

The Association of European Radios (AER), representing commercial radio across Europe, welcomes the opportunity to provide feedback on the European Commissions call for evidence. The European radio broadcasting sector is a cornerstone of media pluralism, cultural diversity, and local information.

DSM Directive Survey- Questions for Press Publishers Sveriges publicisters kollektiva förvaltningsorganisation (SPCMO), which represents Swedish publishers of newspapers, magazines, periodicals and specialized press including in digital formats welcomes the opportunity to submit its observations in response to the European Commissions Call for evidence.

This submission to the European Commission's Call for Evidence on a better copyright environment (Ares(2026)4845636) comes from the Media Governance & Industries Research Lab (University of Vienna) for the Horizon Europe project ANIMA MUNDI. It draws on Deliverable D4.1 (Sarikakis et al., 2025): five stakeholder workshops, eleven focus groups, and 43 industry participants across Europe (June to September 2025).

This submission responds only to the first of the four areas of intervention identified in the call for evidence: the challenges faced by creators linked to artificial intelligence. As a member of COMMUNIA, Open Future supports the positions set out in COMMUNIA's submission on the other areas addressed by the initiative: in particular, access to and reuse of publicly funded research and Public Domain materials…

The Computer & Communications Industry Association (CCIA Europe) welcomes the opportunity to provide feedback on the European Commissions call for evidence on its upcoming targeted initiative for a better copyright environment for European creativity and innovation. The Association respectfully submits the seven recommendations in the position paper attached.

VAUNET considers the existing EU copyright framework to remain broadly fit for purpose. The review, and any targeted initiative that may follow, should focus on making the current rules work in practice. AI can be a powerful driver of innovation, economic growth and better journalism and audiovisual services.

The SPPF is an OGC governed by French law representing the related rights of the main independent music labels which brings together more than 3 000 producers and manages more than 7,6 M of phonograms and video recordings.

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The Premier League welcomes the European Commissions call for evidence on a Targeted initiative for a better copyright environment for European creativity and innovation, particularly its recognition of the critical issue of online piracy currently facing European sports and other live content sectors.

The European Alliance for Research Excellence (EARE) welcomes the opportunity to provide input into the call for evidence on the review of the Copyright in the Digital Single Market (CDSM) Directive. In particular, to ensure a copyright framework that effectively supports research and innovation, the EU should address the key challenges faced by researchers and innovators in the application of the TDM exceptions.

Given the emergence of new players since the implementation of the CSDM directive in 2019, and the resulting transformation of the audiovisual landscape, the TF1 Group, France's leading private television group, which includes TF1, Europe's leading TV channel whose news programmes attract more than 10 million viewers everyday, welcomes the European Commissions planned revision of the Copyright framework.

CREATe is the Centre for Regulation of the Creative Economy, hosted by the School of Law at the University of Glasgow. We are core funded by the Arts and Humanities Research Council as UK research infrastructure. We produce, collect and review independent evidence on the effects of copyright, competition, information and technology law on society and the creative economy.

beIN SPORTS welcomes the European Commissions initiative to strengthen the copyright framework to better support creativity, innovation, and competitiveness in the EU, and to address the growing threat of online piracy of live events.

GRAMMO is the Greek Collective Management Organization representing producers of sound recordings and audiovisual recordings. It manages the related rights of record companies, collects and distributes royalties and promotes the protection and effective enforcement of those rights.

The European AI Forum (EAIF), representing 14 national AI associations and more than 3,000 members across the EU, submits this response to the Commission's Call for Evidence on the review of the CDSM Directive. We welcome this timely review, which arrives at a critical juncture: the deployment of General Purpose AI (GPAI) models has exposed significant interpretive gaps in Articles 3 and 4 CDSM, creating legal…

Svenska Oberoende Musikproducenter (The Swedish Independent Music Producers, SOM) is Europe's (and perhaps the world's) oldest organization for independent phonogram producers, founded in October 1974 (under the name NIFF). SOM represents approximately 330 Swedish phonogram publishers, including both professional record labels and self-releasing artists. SOM comments on the following areas: 1.

The Polish Digital Publishers Employers' Association (ZPWC) represents Polish digital press publishers reaching 26 million Poles monthly; their professional, fact-checked content is now a core input for generative AI.

This response was prepared by the Chair of Intellectual Property Law (IPWI) at the Faculty of Law and Administration at the Jagiellonian University in Kraków. It addresses three areas for the future development of EU copyright law: artificial intelligence, remuneration of authors and performers, and access to protected content for research and public-interest uses.

AIPA is the Slovenian collective management organisation for audiovisual co-authors, performers and film producers. We welcome the combined review of Directive (EU) 2019/790 and the proposed targeted legislative initiative. The review must assess practical outcomes, not merely formal transposition. Evidence from the 2026 Acting Fairly?

The Coalition for Creativity (C4C) is a Brussels-based coalition. Our membership spans libraries, scientific and research institutions, digital rights groups, technology businesses, and educational and cultural heritage institutions.

EGEDA is an intellectual property rights management organisation which represents and defends the interests of audiovisual producers and manages intellectual property rights (licences and royalties) on behalf of and in the interests of those rightholders and their successors in title.

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On behalf of the Dutch organisations of authors, performing artists, publishers and producers and their collective management organisations, the Dutch Copyright Federation would like to provide further information regarding their joint positions on the following topics: - enforcement of copyright and related rights in the AI context; - improving enforcement remedies against online piracy of live events; See attached…

A balanced copyright framework plays a crucial role in supporting creativity, investment, access to knowledge and innovation. The EU has made significant progress in adapting copyright rules to the digital environment, including via the Copyright (CDSM) Directive and the copyright-related provisions of the AI Act.

FIMI represents major record labels and distributors of the recording sector for a total of over 2,500 of the most famous brands in the world. Born in 1992, FIMI (Federation of the Italian Music Industry) is founding member of Confindustria Cultura Italia the official federation of the cultural industry in Italy and IFPI (the voice of the recording industry worldwide): it represents the interests of some 2,500…

IFPI is the voice of the recording industry worldwide, representing over 8,000 record company members across the globe. We work to promote the value of recorded music, campaign for the rights of record producers and expand the commercial uses of recorded music around the world.

CANAL+ believes it is neither necessary nor advisable to reopen the 2019 Copyright in the Digital Single Market Directive (CDSMD or Copyright Directive), which has led to significant achievements amongst which fairer sharing of value between creative sector players and online platforms which must be preserved.

Confartigianato Imprese is the most representative Italian organisation of crafts and micro and SMEs and one of the most important social partners in Italy. At national level, it has 104 local associations, 21 regional federations, 1.206 offices and 10.700 employees, offering different types of services to over 1.5 million craftsmen and small entrepreneurs and almost 700.000 businesses.

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Börsenverein des Deutschen Buchhandels e.V. represents the German book sector. We would like to provide the following feedback: AI developers have consistently refused to engage with publishers and acquire licenses for the works they have used in training AI models. Many such uses have been illegal, and pirated sources have been used systematically.

The EU copyright framework is fit for purpose and should not be the subject of premature revision or amendment. It is dynamic, technologically neutral and sufficiently flexible for addressing new issues, including with the uptake of AI technologies.

The German Advertising Federation (ZAW) is the national association representing the advertising industry in Germany. It comprises a large, dynamic network of 43 member organisations, through which it represents all sectors and disciplines within the advertising industry: advertisers, media, communication and media agencies, market/social research and advertising professions.

Submission by Aylo Premium Ltd- Full letter attached Aylo Premium Ltd, a limited liability company organised under the laws of the Republic of Cyprus, submits this response as a rights holder producing lawful, consensual and age-verified adult content for the European market. A full letter is attached, which we ask the Commission to review in full. Key points below. Scale of harm.

The European Music Managers Alliance represents music managers across Europe. Managers work directly with and represent artists, performers, songwriters and producers on rights, contracts, income, licensing, career development and the practical impact of new technologies. This gives managers direct evidence of whether copyright rules are working for creators in reality.

The Bundesverband Musikindustrie e.V. (BVMI) represents around 150 record producers and music companies representing over 80 % of the German music market, from large international music companies (Universal Music Group, Sony Music, Warner Music Group, BMG, Believe, etc.) to small and medium-sized enterprises and family businesses.

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The Motion Picture Association is a trade association representing seven international producers and distributors of film and television content, which serves as the global voice and advocate of the international film, television, and streaming industry.

Sky is one of Europes leading media and entertainment companies, connecting, informing and entertaining millions of customers across Europe. We invest in and distribute high quality, award-winning content, produce the biggest live sporting events, and provide free access to news. Through these investments and job creation, Sky significantly contributes to the European economy.

TONO welcomes the European Commissions review of the Copyright in the Digital Single Market Directive and its initiative to explore targeted measures aimed at ensuring a better copyright environment for European creativity and innovation.

We welcome the European Commissions initiative to review the copyright framework in light of technological developments, in particular generative AI. We support efforts to ensure a balanced approach that strengthens innovation, while safeguarding the rights and incentives of rightholders, such as CEN and CENELEC for their copyright protected standards and European standardization deliverables.

European Leagues has taken note of the European Commission's assessment of the effects of Recommendation (EU) 2023/1018 on combating online piracy of sports and other live events. European Leagues members share the Commission's conclusion that the Recommendation has not significantly reduced the volume of piracy of live events, notably due to the continued failure of certain online intermediaries to act effectively…

MTV Oy thanks the Commission for the opportunity to provide input to the Commissions review of the DSM Directive and the preparation of targeted measures. MTV is a major commercial television broadcaster in Finland, providing the Finnish audiences with independent quality news, entertainment, drama and sports content via a variety of television channels, a versatile VOD service and a digital news portal.

In its submission Knowledge Rights 21 (KR21) Netherlands argues that the EU's current fragmented copyright framework undermines cross-border collaboration and forces public institutions into repetitive costs for scholarly materials.

Tarlogic Security is an European cybersecurity company providing specialised services in offensive security, cyberintelligence, vulnerability management, incident response and digital risk protection. The company has been recognised in the Financial Times and Statista Europes Long-Term Growth Champions 2026 ranking, which highlights European companies with sustained growth over the last decade.

ACT is a policy trade association for the small business technology developer community. Our members are entrepreneurs, innovators, and independent developers within the global app ecosystem that engage with verticals across every industry.

As a recently founded university with a strong interdisciplinary focus centred on computer science, IT:Us main comments relate to the research, education and preservation exceptions (Articles 37) of the Directive on Copyright in the Digital Single Market (CDSM) and to a possible EU secondary publication right.

As an SAA member, we fully support the SAAs contribution to this call for evidence, which is attached. In addition, we support the establishment of a nontransferable, collectively managed right to remuneration to ensure fair, effective and enforceable compensation for authors and performers.

Bauer Media Group (BMG) is one of Europes largest media businesses, entertaining, informing and serving over 200 million people. BMG welcomes the opportunity to respond to the European Commissions Call for Evidence from the perspective of its audio and publishing businesses.

The Finnish Research Library Association would like to draw attention to the following points: Secondary Publication Right/Self-Archiving There is a clear need for harmonised European regulation regarding the secondary publication right for scientific articles.

EIFL calls for the introduction of a mandatory research exception and an EU-level SPR to support researchers and boost open science. Repository Managers from Latvia, Armenia, Serbia and Moldova share their experiences obtaining and depositing published research, and EIFLs model SPR provision is designed to meet the five policy options in the Commission study, Improving Access to and Reuse of Research Results.

About Ifpi Sweden Ifpi Sweden represents the record companies operating in Sweden. Ifpi Sweden's member companies collectively account for around 75% of the Swedish recorded music market. Our member companies invest in Swedish artists, music productions, marketing, export and innovation. Recorded music is a central part of Swedish cultural life and the creative economy.

News/Media Alliance is a nonprofit organization representing over 2,000 newspaper, magazine, and digital media publishers in the United States and internationally. NMA's membership accounts for nearly 90 percent of the daily newspaper circulation in the United States, some of the biggest publishers in Europe, and over 500 individual magazine and digital-only brands.

Summary of the contribution INTRODUCTION BELA ASBL brings together representatives of the Belgian committees of the Belgian delegations of the SACD and Scam, representing more than 8,600 member authors in Belgium. Its mission includes providing the relevant authorities with legislative advice on artistic creation and copyright.

Article 18 and Recital 73 of the 2019 Directive established the principle of appropriate and proportionate remuneration. Six years on, the EU's own work documents that its operational implementation has failed for audiovisual screenwriters.

The EU copyright framework is fit for purpose and should not be the subject of premature revision or amendment. It is dynamic, technologically neutral and sufficiently flexible for addressing new issues, including with the uptake of AI technologies.

RELX operates across the fields of scientific research, legal and regulatory intelligence, risk analytics and business information. All our AI tools are developed in accordance with the RELX Responsible AI Principles, which require privacy protection, transparency, explainability, human oversight and compliance with data protection law, including a commitment not to use customer data to train AI models.

The Czech National Association of the International Federation of the Phonographic Industry (ČNS IFPI; https://ifpicr.cz/) is one of the IFPI´s national groups in the EU. Our members are phonogram producers, which we represent. We consistently work on protection of phonogram producer´s rights, promotion of value of recorded music, policymaking on copyright and digital legislation etc.

DILIA is an association of authors and other copyright holders based in the Czech Republic, performing the activities of a collective management organization (CMO) and an art agency. We welcome the opportunity to contribute to the European Commission's review of Directive 2019/790/EU on copyright in the Digital Single Market (DSM).

ACT, the Association of Commercial Television and Video on Demand Services in Europe, represents Europes leading commercial broadcasters and on-demand services. Our members play a central role in financing, producing and distributing European works, and are key contributors to Europes cultural and creative ecosystem.

The Ivors Academy is the leading organisation for songwriters and composers. We celebrate the highest standards of craft through the prestigious Ivor Novello Awards, campaign for a fair and equitable music industry and empower music creators at every stage of their careers. For over 80 years we have championed the rights of songwriters and composers.

The EUs cultural heritage and GLAM (galleries, libraries, archives and museums) institutions strongly promote protecting copyright, but copyright restrictions are at odds with the AI sectors approach of indiscriminately scraping the open web.

Ladies and gentlemen, Illustrators Organisation e.V. is the professional association for illustrators in Germany. We would like to thank you for the opportunity to comment on the review of the CDSM Directive and the initiative on targeted changes to the copyright framework in the EU. Our opinion can be found in the attached PDF file called ‘260723_IO_CallForEvidence’.

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Hessen is an innovation-friendly AI country, not least thanks to the research network hessian.ai. At the same time, the Hessen Ministry of Science and Research, Arts and Culture (HMWK) attaches great importance to ensuring that the creative sector in Europe is protected by the EU in the light of the increasing use of AI, especially by large tech companies.

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Wikimedia Sverige is a non-profit association that works for free knowledge. We work with cultural heritage institutions, universities, public authorities and civil society to make knowledge more accessible through open licences and free knowledge platforms such as Wikipedia, Wikimedia Commons and Wikidata.

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The Italian Internet Providers Association welcomes the Commission's decision to assess copyright, generative AI, online piracy and research within the same review and targeted initiative. This combined approach is necessary because the main copyright challenge has moved beyond traditional piracy websites and illegal streaming.

The Swedish Library Association is a non-profit-making and non-partisan member and interest organisation which brings together and promotes all types of libraries. We are advocating and generating debate to ensure that libraries are put in the best possible position to be a force for AI in democratic society, and TDM TDM exceptions have been important for research and AI development, but their practical application…

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The European Copyright Society (ECS) was founded in 2012 with the aim of creating a platform for critical and independent scholarly thinking on European Copyright Law and policy. Its members are scholars and academics from various countries of Europe, seeking to articulate and promote their views of the overall public interest on all topics in the field of authors rights, neighbouring rights and related matters.

On the issue of material reciprocity with third countries in relation to the remuneration rights applicable to performers and phonogram producers, HOTREC argues that the current framework, particularly following the CJEUs RAAP judgment, has led to fragmentation across Member States and created structural imbalances in neighbouring rights remuneration.

Alliance Française des Industries du Numérique is the professional trade union representing, in France, industrialists in digital infrastructure, computing, consumer electronics, printing, photography, antennas and connected objects.AFNUM’s reply is available as an attachment.

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TikTok is a leading global video-sharing platform. Creators of all backgrounds sit at the heart of TikTok, forming a community where authenticity and diversity are celebrated. With more than 200 million monthly active users across Europe, our top priority is to promote a safe experience so that everyone can express their creativity.

The European Commission is seeking a targeted revision of the 2019 Copyright in the Digital Single Market Directive. Through this revision, the Commissions goal is to strengthen the resilience and competitiveness of European cultural and creative sectors. The use of generative AI raises various issues for rights holders, particularly regarding fair remuneration.

A summary of the recommendations, the full text of which can be found in the Annex. The Deutscher Bibliotheksverband e.V. (dbv) recommends: A clarification that the use of data sets also for the training of generative AI is covered by the TDM authorisation under Article 3 of the DSM Directive.

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The proliferation of generative AI imaging systems has a significant economic impact on European image agencies and photographers. AI models are often trained on copyright-protected images created by European rights holders without their effective consent or adequate remuneration.

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DOT Europe, representing leading online service providers in Europe, argues that the EU already has the legislative tools needed to navigate the intersection of AI and copyright, and that new regulatory burdens should be avoided until existing rules are properly enforced and the AI Act has had time to bed in.

APOLLON welcomes the Commissions Call for Evidence, which combines the review of the CDSM Directive with a targeted initiative on a better copyright environment. We submit that the evidence-gathering for the CDSM review is currently not robust enough: the performer-facing survey is excessively complex and does not enable most performers to provide meaningful, experience-based input.

Core messages from the Confederation of Swedish Enterprise Copyright is no longer solely a cultural policy issue. In a digital and knowledge-based economy, copyright is also a central issue for competitiveness, innovation, scaling, and the functioning of the Single Market. As an intellectual property right, copyright has a totally different position for business than most other rights.

ITSRIGHT srl is a collective management organisation founded in 2010 and based in Italy, representing neighbouring rights of music performers and producers of phonograms. We appreciate the opportunity to be involved in this consultation process and give our represented rightholders the chance to have their say.

The Society of Audiovisual Authors (SAA) is the umbrella association of European collective management organisations (CMOs) representing audiovisual authors. Its 34 members in 26 countries manage rights for over 177,000 film, television and multimedia European screenwriters and directors.

In our view, the EU needs holistic and functional solutions to protect public interest activities and strengthen Europes research, innovation and education ecosystem. The EU should recognise the problematic and exploitative business model of modern scientific publishing and protect academic authors through a harmonised EU Secondary Publication Right, enabling immediate open access (no embargo, VoR) to publicly…

The Federation of Film Distributors in Spain (FEDICINE) is a sectoral association representing film and television content producers and distributors, acting as a national and European spokesperson and supporter of the film, television and streaming industry.

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GitHub welcomes the opportunity to respond to this Call for Evidence. We share the Commission's view that the CDSM Directive set a sound foundation, and the questions raised by new technology are best addressed by focused, well-evidenced adjustments where necessary rather than by reopening the Directive.

SCF is the leading collective management organization for neighboring rights related to copyright, held by phonogram producers pursuant to Article 72 et seq. of Law No. 633 of April 22, 1941. Its corporate purpose is the collective management of rights owned by phonogram producers who grant it a specific mandate, as well as the performance of all activities connected with the administration of such rights.

The Spanish Professional Football League (LALIGA) notes the European Commissions written and oral assessments of the effects of its Recommendation (EU 2023/1018) on combating online piracy of sports and other live events.

"The Danish Union of Journalists - Media and Communication" has the following remarks to the call for evidence on the copyright DSM directive: Article 4: First, the article is problematic because the opt-out options are not operational for journalists and other media workers. Next the assumption that content for AI-training should be covered by article 4 creates fundamental problems for journalism.

The Italian Publishers Association (AIE) welcomes the opportunity to contribute to this consultation. The development of the AI licensing market is currently hindered by AI providers' systematic use of pirated sources, their lack of transparency and refusal to comply with EU law.

ITI - the Information Technology Industry Council - is the global trade association of the technology industry, representing 80 of the worlds most innovative tech companies. Our membership spans across the entire spectrum of technology, including global leaders on software and AI, hardware, cloud, cybersecurity and semiconductors.

Nuovo IMAIE, as Collective Management Organization representing and managing performers rights in Italy, welcomes the Commissions Call for Evidence as it addresses the review of CDSM and other specific initiatives aiming at strengthening the position of creators and creative industries especially in the online and AI environment.

SGAE is the Spanish CMO for musical, audiovisual and dramatic works, representing over 142,000 members, and a member of GESAC and SAA whose submissions supports. SGAE urges the Commission to legislate with substantive, clear and enforceable rules rather than procedural or voluntary half-measures, which have proven insufficient.

COMMENTS FOR THE REVISION OF DIRECTIVE (EU) 2019/790 ON COPYRIGHT IN THE DIGITAL SINGLE MARKET SUBJECT: Technical contribution by the Spanish Hospitality Association to the initiative to revise Directive (EU) 2019/790: Proposal to adapt the concept of ‘public communication’ and pricing criteria to the individualised digital environment. I. LOCUS STANDI AND SUBJECT MATTER 1.

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The German Association for Intellectual Property Law (GRUR) is a non-profit scientific association for all members of professional groups and organisations active in the field of intellectual property and copyright law. I. Generative AI and copyright There is a widespread criticism of the transparency prescribed by Art 53(1)(d) AI Act.

The Verband der Automobilindustrie e.V. (VDA) represents the interests of the German automotive industry at national, European and international level. As a representative of the key sector of the German economy, the VDA assumes its responsibility for around 620 member companies.

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Please find attached the official statement of Luovat ry - response to the Call for Evidence on the Review of the DSM Directive and Targeted Initiative on Copyright and Artificial Intelligence. Luovat ry broadly represents the creative sector in Finland, ranging from companies to individual creators and performing artists, and through its 17 member organizations brings together tens of thousands of professionals…

As the National Chamber of Commerce for Electronics and Telecommunications, we support the position of the Association of Signals, which we enclose in the file. The DSM Directive has significantly increased the liability of platforms for copyright infringements, including through content licensing obligations and notice and stay down mechanisms, but does not fully address the specificities of modern piracy, in…

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The music producers IFPI Finland ry promotes the ability of record companies to invest in new artists and productions and to receive appropriate remuneration. The European Commission’s objectives are best achieved by ensuring that existing legislation is effectively applied and enforced.

Filed in Finnish · English published by the European Commission

AGEDI is a non-profit association established by music producers to collectively manage the rights that the Intellectual Property Law (Revised Text of 12th April 1996) grants to phonogram producers. It is the collective management society for producers of phonograms and music videos. The Ministry of Culture granted AGEDI the preceptive authorisation by Order of 15th February 1989 (BOE 11th March 1989).

Finnish Composers' Copyright Society Teosto, the collective management organisation for composers, lyricists, arrangers and music publishers considers that the structural challenges posed by generative artificial intelligence for copyright needs to be addressed urgently.

The Association of Finnish Nonfiction Writers (Suomen tietokirjailijat ry) is the largest writers organisation in Finland. It promotes nonfiction and protects the copyright and financial interests of nonfiction writers. The association has over 3,300 members, including writers of general nonfiction, textbooks and research articles.

Spedidam is a French collective management organisation (CMO) of performers rights. It represents and defends the interests of all performers in the audio and audiovisual sector, regardless of their nationality, the type of performance (dance, music, comedy, etc.) or their role (featured or non-featured artists).

Please find attached CEPI's submission. CEPI the European Audiovisual Production Association represents over 2,800 European independent film and TV producers across Europe through 19 national associations across 17 European countries.

PlayRights experience shows that the CDSM Directive has not delivered the meaningful improvements for performers that were originally envisaged. Although it introduced important principles, such as appropriate and proportionate remuneration and greater transparency, these objectives have largely remained unrealized in practice.

The EU copyright framework is fit for purpose and should not be the subject of premature revision or amendment. It is dynamic, technologically neutral and sufficiently flexible for addressing new issues, including with the uptake of AI technologies.

The umbrella organisation Initiative Urheberrecht represents the interests of authors and performers in Germany. It brings together 44 member organisations representing more than 140,000 creators and performing artists across the full range of creative professions, including, central to this submission, illustrators, photographers, translators, journalists, composers and performers.

IMPALA is the European association of independent music companies, with over 6,000 members across 33 European markets. We represent independent music companies (labels) and self-releasing artists, either directly or through national trade associations. We welcome this call for evidence on questions of great importance for our members and Europes music ecosystem as a whole.

Since our formation in 2021, the Live Content Coalition has consistently called for urgent legislative action to address the issue of online piracy of live events in Europe by rectifying the limits of the notice and takedown regime.

The Sports Rights Owners Coalition (SROC) notes the European Commissions written and oral assessments of the effects of its Recommendation (EU 2023/1018) on combating online piracy of sports and other live events.

Confindustria Radio Televisioni wishes to share with the European Commission its comments on certain aspects of the so-called Copyright Directive, a measure of particular interest to its member broadcasting companies. The Association has previously expressed its satisfaction with the text currently in force.

Drehbuchverband Austria/Austrian Screenwirters Association Contribution to the European Commission's Call for Evidence Targeted initiative for a better copyright environment for European creativity and innovation Reference Ares(2026)4845636 Closing date: 25 June 2026 Stakeholder category: Non-governmental organisation 24 June 2026 The Austria Screenwriters Association represents the professional interests of…

Viaplay Group operates streaming services and television and radio broadcasting channels across the Nordic countries. Please find attached our full response. We would like to highlight the following points regarding the RAAP judgement: The situation created by the RAAP judgement gives rise to a structural imbalance in which significant economic value will flow out of the European Union - primarily to the United…

Generative AI and the limits of the TDM framework The DSM Directives TDM exceptions predate generative AI and now operate in a setting in which training, inference and output generation may affect human creativity, cultural diversity, media pluralism and democratic discourse.

This submission focuses on four areas where we consider the Commissions intervention to be both legally well-founded and practically necessary: The unauthorised use of toy IP in AI training data, and the transparency and remuneration gaps this creates; The risk of AI-enabled imitation of toy characters and designs at scale; The inadequacy of existing enforcement mechanisms against digital forms of IP infringement…

The Syndicat des Scénaristes is an independently funded French union for screenwriters. Created in 2022, its mission is to protect and further advance French screenwriters rights, particularly during all the creative work that happens before a script is ever brought to the screen. Article 18 and Recital 73 of the 2019 Directive established the principle of appropriate and proportionate remuneration.

Almega is the largest employers' organization for the private service sector in Sweden. We represent more than 10,000 companies covering about 60 service industries, employing more than 500,000 individuals. Almegas member companies operate in in IT, tech, media, architecture, engineering, and other knowledge-based work.

Corint Media is a European company in the private media industry, a limited liability corporation li-censed as a Collective Management Organization (CMO) under the German Collecting Societies Act (Verwer-tungsgesellschaftengesetz, VGG). Corint Media manages the rights of almost all German and several international private television and radio stations as well as of numerous press publishers.

The evaluation of the Directive 2019/790/EC We believe that the Directive 2019/790/EC (further DSM Directive) is a positive and necessary piece of legislation, however it currently seems not to provide for sufficient means for the press publishers and other right holders to enforce the obligations set out in the article 4 and article 15 of the Directive.

CDSM Review / University of Helsinki The University of Helsinki welcomes the review of the CDSM Directive, especially in terms of supporting the circulation of scientific knowledge and fostering research and innovation.

Stance of the Society of Polish Illustrators (SPI) on the implementation of the DSM Directive (2019/790) into the Polish legal order and the application of Text and Data Mining (TDM) exceptions (This is an abbreviated text. Please find attached the full version below.) The Society of Polish Illustrators (SPI) brings together Polish illustrators and represents their professional, economic and copyright interests. 1.

The European Magazine Media Association (EMMA) and the European Newspaper Publishers Association (ENPA), representing the vast majority of European publishers of newspapers, magazines, periodicals and specialised press, including in digital, appreciate this opportunity to provide feedback on the European Commissions Call for evidence support the review of the 2019 Copyright in the Digital Single Market Directive…

IFRRO welcomes the DSM Directive (DSMD) review and the opportunity to provide evidence. The DSMD has established an important framework for addressing certain challenges of the digital environment and for supporting the reuse of protected works and licensing solutions.

On behalf of KVAN (Royal Association of the Archive Sector in the Netherlands), this response to the Call for Evidence requests targeted EU copyright reforms to improve systemic regulatory weaknesses and empower heritage institutions to fulfill their public missions in the digital age.

The CARD welcomes the Commission’s initiative to gather stakeholders’ feedback on the implementation of copyright rules in the EU. In this context, it wishes to formulate a clear and unambiguous position. As a preliminary remark, the CARD wishes to reiterate its preference for maintaining the current framework of the Directive on Copyright and Related Rights in the Digital Single Market and 2019 and express its…

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Media IP Rights feedback on 2019 DSM Directive. We believe that the DSM Directive was a welcome and necessary step in addressing the challenges the EU single market faced in the digital environment. One of the areas that was addressed by the DSM Directive is the introduction of certain measures to ensure performers receive appropriate and proportionate remuneration when their work is used online.

Feedback by UrheberAllianz Film & Fernsehen (Authors' Alliance Film & Television) The UrheberAllianz Film & Fernsehen represents approximately 2,400 German film and television authors across the professions of directing, cinematography, film editing, production design and costume design. GENERAL POSITION We do not support reopening the Directive.

Svensk Scenkonst is a trade and employer association for all professional performing arts in Sweden. It represents around 260 activities in music, dance, theatre, opera and contemporary circus. Members include the country’s performing arts institutions, as well as private performing arts companies and operators in the field of professional performing arts.

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I am writing on behalf of the Working Committee Archives and Law, a committee initiated by the Conference of the Heads of the State Archives in Germany (Konferenz der Leiterinnen und Leiter der Archivverwaltungen des Bundes und der Länder). This coordinating body includes the Federal Archives as well as the archives of Germanys 16 federal states.

The International Federation of Film Distributors and Publishers' Associations (FIAD) gathers national organisations of film distribution companies. Film distributors are the intermediaries between film producers and cinema exhibitors and cover the entire range of companies: small and medium-sized companies specialized in art house films, as well as larger companies focused on mainstream films.

On behalf of the European Open Web Search Initiative, we welcome the opportunity to support the review of the Directive 2019/790/EC on Copyright in the Digital Single Market. Please find our contribution attached. The review of the CDSM Directive offers a critical opportunity to close a structural gap in the European digital framework.

In the attachment, please find our submission to the European Commissions Call for Evidence: Report on the review of the Copyright in the Digital Single Market Directive / Targeted initiative for a better copyright environment for European creativity and innovation.

CEPIC represents hundreds of picture libraries and agencies whose core business is the licensing of visual works, most of them SMEs. We welcome the Commissions combined call for evidence on the CDSM Directive review and the targeted copyright initiative. Our response addresses the copyright-related aspects of generative AI for visual content, in line with the European Parliaments resolution of 10 March 2026.

The German Football Association (DFB) is one of the largest sports federations in the world, with more than 8 million registered members, including more than 1.2 million women and girls. Some 24.000 clubs and 139.000 teams are currently involved in gambling organised by the DFB and its regional and regional associations.

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Defending European free media and safeguarding the operational conditions of editorial media and journalism and other professional media is more important than ever. Robust, independent press and other professional media secure and promote European democracy; freedom of speech and citizens access to professional news, literature and other content; education, learning, culture, and skills; and finally information…

Wikimedia Europe represents Wikimedia movement affiliates across Europe. The Wikimedia movement is made up of a network of organisations and volunteer communities that write, curate and maintain free and open knowledge projects like Wikipedia, Wikidata, and Wikimedia Commons.

Small and national language scholarly publishing environments need regionally and culturally sensitive attention: one approach does not serve all The emphasis should be on improving existing regulatory tools and their efficiency rather than on creating new ones Those demanding secondary publishing rights should cover their costs Enforcing mandatory secondary publishing rights will erode existing funding mechanisms…

The Confederation of Finnish Industries (EK) is the leading business organisation in Finland with its 17 member associations and more than 15 000 member companies (96% SMEs) with 900 000 employees across different sectors. We represent the interests of the Finnish business community both nationally and within the EU.

VNO-NCW and MKB-Nederland, representing businesses across all sectors of the Dutch economy, strongly welcome the fact that the European Commission is now explicitly considering legislative action in response to the consequences of the RAAP judgment (Case C-265/19).

The Estonian actor association (ENL) thanks the European Commission for its initiative to collect evidence-based input on the functioning of the CDSM Directive. However, we would like to point out that the pre-review questionnaire was overly complex and methodologically weak. There were many clerical mistakes and illogicalities.

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This submission is made by Pär Frid, Swedish composer. I submit it in my personal capacity, informed by my work as an audiovisual composer and by my roles as board member of Skap (Swedish composers association), STIM (Swedish music rights CMO), and delegate to ECSA (European Composer and Songwriter Alliance).

The Information Technology and Innovation Foundation (ITIF; Transparency Register #: 923915716105-08) is pleased to submit the attached comments in response to the European Commissions open consultation on the Targeted Initiative for a Better Copyright Environment for European Creativity and Innovation (Initiative No. 18173).

The Faculty Board of the Faculty of Law at Lund University, having been given the opportunity to comment on the proposal in question, hereby submits the following opinion highlighting several selected legal and structural challenges to the EU copyright ecosystem and briefly presenting corresponding conceptual, legal and practical recommendations.

The Writers Guild of Spain, trade union of the screenwriters of Spain, with over 1100 members, has been actively involved in the last decade in the advancement, transposition, implementation and review of the EU rulings and their national and European developments impacting our professional community.

On behalf of the Dutch organisations of authors, performing artists and their collective management organisations, Platform Makers and VOI©E point out the importance of reintroducing the principle of material reciprocity regarding the renumeration for use of sound recordings for Dutch performers. See attached file.

Lefebvre Sarrut welcomes the European Commissions call for evidence to ensure a better copyright environment for European creativity and innovation. As a legal publisher and a provider of innovative legal AI solutions, we operate on both sides of the copyright and AI equation. We state there can be no quality AI without quality content. We create, curate and disseminate high-value legal knowledge.

Cleriti House BV welcomes the European Commission's review of the DSM Directive and the opportunity to contribute observations based on practical implementation experience in the European film and television sector.

The key priority for the development of copyright law in the age of AI is to establish a legal framework for remuneration for the use of the output. As this output continues to be used, the substitution effectwhich poses a particular threat to human creativitycomes into play, with the potential to completely replace fundamental areas of music-making.

John Wiley & Sons (Wiley) is a global research publishing and education company publishing approximately 2,500 peer-reviewed journals and some 35,000 scholarly books. Wiley is a significant participant in the European research ecosystem, including as a leading party to transformative agreements in Germany through the DEAL Consortium.

I am replying on behalf of "Niedersächsischer Beirat für Bibliotheksangelegenheiten". As an association of academic libraries, we consider it essential to establish clear exemptions for the scientific community, in order to facilitate the use of AI methods and models (including machine learning and data mining) for research in a straightforward manner and with low barriers to entry, free from complicated…

We believe that any regulation of AI should: 1. Develop legal and technological tools that allow for prior and express authorisation by rightholders, or at least a representative part thereof. 2. Be based on transparent and fair remuneration criteria, which are essential for the development of a competitive market, not only in the context of intellectual property rights.

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AEPO-ARTIS welcomes the Commissions combined Call for Evidence and particularly the fact that it aims to collect the information necessary to support the review of the CDSM Directive. With regard to the review of the CDSM Directive, AEPO-ARTIS has serious concerns regarding the quality of the evidence currently being gathered.

Internet Archive Europe (IAE) is a European non-profit established in Amsterdam in 2004. Our mission is to foster digital preservation and open access, and to ensure the legal framework governing these activities serves the public interest. We work with memory institutions across Europe whose activities depend on the framework the CDSM Directive established. 1.

GDA is a Portuguese CMO representing more than 20,000 musicians and actors. On behalf of our members, we make the following comments. Concerning the review of the CDSM Directive, the objective of Article 18 remains highly relevant. However, in practice, it has not led to any meaningful improvement in performers conditions.

The evidence collected by COMMUNIA and its research partners demonstrates that existing copyright rules continue to create obstacles for scientific research, public-interest AI development and cultural heritage dissemination. Researchers continue to face legal uncertainty when sharing research materials across borders. Public-interest AI initiatives lack clarity regarding the application of the TDM exceptions.

Norma is a Dutch collective management organisation for neighbouring rights, representing twenty-three thousand performing artists. We submit the following comments on behalf of our rightsholders. The TDM exception in art.

AIE is the Spanish Collective Management Organization representing music performers rights on phonograms and audiovisual. On behalf of more than 39.000 members we make the following comments. The documentation submitted by AIE to the European Commission presents our position on four key regulatory areas related to performers rights in the context of the CDSM Directive and broader EU copyright framework.

Allied For Startups (AFS) supports making the EU's existing copyright framework work better for both creativity and innovation, rather than introducing new regulatory layers. The CDSM Directive and AI Act already provide the foundations for a balanced approach; the priority should now be legal certainty, harmonised implementation, and reducing fragmentation across Member States.

This contribution draws on research conducted in the context of the Fair MusE Horizon Europe project (Grant Agreement 101095088), with a particular focus on the digital music sector (see deliverable D2.3). It analyses the CDSM Directive (CDSMD) and identifies structural challenges that could partly be addressed through competition law, the Digital Markets Act (DMA), and the Digital Services Act (DSA).

Please refer to the attached opinion. In short: Research institutions, libraries and cultural heritage institutions need a modern copyright framework harmonised across Europe to ensure scientific progress, digital innovation and Europe’s international competitiveness. It is true that the implementation of the DSM Directive has laid important foundations for boosting research and innovation.

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During the latest Eurovisioni Conference held in Rome on November 2025 where a panel session was dedicated to the A.I. and the reform of copyright , emerged a consensus on the necessity to protect the works and creations of authors, i.e. human beings, from the possible confusion with works created by machines (artificial intelligence), with minimal human intervention.

Bildupphovsrätt i Sverige is a non-profit collective management organization (CMO) representing visual artists in Sweden. The visual arts sector continues to face significant challenges in securing effective licensing of copyright-protected works in the digital environment.

Ekhoscenes is the leading French employers’ trade union at national level in the private performing arts sector. Since 1984, the mission of Ekhoscenes has been to represent, promote and defend the interests of its members. Ekhoscenes brings together producers of shows covering the entire chain of creation and broadcasting of a show living in France.

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This summary is based on an investigation conducted over a few days in late March and the first two weeks of April 2026 using publicly available tools. The list of affected artists is incomplete - the true scale is likely considerably larger.

The European Grouping of Societies of Authors and Composers (GESAC) welcomes the European Commissions (EC) Call for Evidence as an important and necessary first step towards introducing an additional legislative framework addressing key challenges in the field of copyright/authors rights.

Submission to the European Commission Call for Evidence Overall Summary The current application of the CDSM Directive, particularly Articles 3 and 4 on text and data mining, is inadequate for the realities of generative AI, creating legal uncertainty and enabling large-scale use of protected works without authorisation or remuneration.

I am a professional music producer, mixing engineer, songwriter and Ableton Certified Trainer based in Belgium, with over 25 years of experience and 220 releases. I am a board member of Muziekgilde, a member organisation of ECSA. I was invited to speak on the "Gen AI vs Music" panel at the European Parliament in May 2026, organised by AEPO-ARTIS.

For its comments on the DSM Directive, the German Association of Journalists (DJV) refers in general to its replies to the evaluation questionnaire, which it submitted within the deadline of 13 June 2026. With regard to AI and copyright, please find attached a position paper. The DJV is Germany’s largest journalism organisation, with around 25.000 members.

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Please find attached ALLEA's STATEMENT ON THE IMPORTANCE OF THE TEXT AND DATA MINING EXCEPTION FOR SCIENTIFIC RESEARCH The European Federation of Academies of Sciences and Humanities (ALLEA) welcomes the opportunity to contribute to the ongoing review of the Directive on Copyright in the Digital Single Market (Directive (EU) 2019/790, CDSM Directive).

See the Annex. Summary: CRUI, the Conference of Rectors of Italian Universities, participates in the European Commission's consultation on the revision of the Copyright Directive in the Digital Single Market, underlining the importance of a regulatory framework that protects authors and creators but also promotes research, higher education and the open circulation of knowledge in Europe.

The Italian Society of Authors and Publishers (Società Italiana degli Autori ed Editori SIAE) welcomes the opportunity to contribute to this Call for Evidence launched by the European Commission concerning the impact of Directive (EU) 2019/790 on Copyright and Related Rights in the Digital Single Market (CDSM Directive), as well as the remaining challenges relating to the use of copyright-protected content in the…

VG Bild-Kunst, the German visual CMO, representing more the 75.000 direct members and more than 280.000 international visual artists, welcomes the opportunity to contribute to the discussions about a functioning legal framework in the age of digital mass uses. Much has been already achieved with the CDSM Directive and its collective licensing solutions for CHI and teaching.

The review of the Copyright in the Digital Single Market Directive (CDSM Directive) provides an important opportunity to assess whether the existing framework continues to deliver on its objectives in a rapidly evolving technological environment.

Suomen Musiikintekijät ry / Finnish Music Creators is the Finnish association representing professional music creators, founded in 1954. Our membership encompasses the full breadth of music creation in Finland: songwriters and lyricists working across popular music genres, film and audiovisual composers, folk and children's music creators, jazz composers, and composers working in the field of game music.

ZAPA (Union of Audiovisual Authors and Producers), operating within the Polish Filmmakers Association, is the leading collective management organisation in Poland, representing the rights and interests of audiovisual creators as well as producers.

Overall Summary The current application of the CDSM Directive, particularly Articles 3 and 4 on text and data mining, is inadequate for the realities of generative AI, creating legal uncertainty and enabling large-scale use of protected works without authorisation or remuneration.

Danish Industry (DI) welcomes the Commissions ongoing review of the Copyright in the Digital Single Market (DSM) Directive, as well as the associated call for evidence and public consultation regarding text and data mining (TDM). Setting the right framework for copyright and data access is fundamental to innovation, growth and competitiveness in Denmark and in the EU as a whole.

European Visual Artists (EVA) welcomes the opportunity to share the experience of the visual arts sector with the current copyright framework and the emerging AI technologies in the context of the assessment of the DSM Directive. As the European Union reaffirms its leadership in the global race for technological innovation, it must do so without compromising the values that define it.

The Committee to Protect Scientific and Scholarly Work under the umbrella of Danish Academics has following remarks: Art. 3 and general observations regarding copyright: European researchers need a legal right to Open Access publication regardless of opposing terms in their agreements with journals.

The European Union has a strong tradition of supporting an open, secure, and globally interoperable Internet, while also advancing key public policy objectives in the audiovisual sector, including the protection of minors, the reduction of illegal or harmful audiovisual content, and the promotion of media pluralism.

The Finnish E-library is a shared service for municipalities for borrowing e-books, audiobooks and digital magazines. The service is provided by the National Library of Finland in cooperation with public libraries. The digital revolution has significantly transformed the book industry, with e-books and audiobooks gaining increasing popularity.

Akava is the central labour market organisation for highly educated professionals in Finland, and its membership includes a large number of individuals whose work and livelihoods are affected by copyright. In this statement, we focus primarily on general principles. Copyright legislation is no longer up to date, particularly in light of developments in artificial intelligence, and therefore requires reform.

Kopiosto ry is a Finnish collective management organisation representing authors, performers and publishers, providing licensing solutions for the lawful use of copyrighted content across sectors such as education, public administration and business. A well-functioning EU copyright framework is essential to ensure both innovation and sustainable creative markets in a rapidly evolving technological environment.

The DSM Directive brought about substantial reforms to the liability framework governing online platforms in relation to copyright infringement. Notably, Article 17 introduced a dedicated liability regime for online content-sharing service providers, including obligations to obtain prior authorisation from rightholders and to implement a ‘notice-and-stay-down’ mechanism designed to prevent the repeated availability…

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The International Federation of Actors represents performers' trade unions, guilds and professional associations in over 60 countries. As such, FIA speaks for hundreds of thousands of professional creative workers performing on live shows and on all recorded media, including those in the US and in most EU member states. FIA has the pleasure to contribute to this consultation, copy of which is attached to this form.

SVT:s response on the follow-up on the RAAP Case (please read the attached file for SVT:s full response): As a national broadcaster financed by public funds SVT must express our serious concern regarding the legal and economic consequences arising from the RAAP judgment.

The Business Software Alliance (BSA) represents the world's leading software and technology companies. Our members are active across the full AI value chain as developers of AI systems, providers of cloud and data infrastructure, and as significant users and producers of copyright-protected content.

The Copyright in the Digital Single Market (DSM) Directive was negotiated before two major developments transformed the online information ecosystem: the emergence of large-scale generative AI systems and the increased monetization of user-generated content and widespread rollout of platform monetization programs.

The European University Association welcomes the opportunity to provide input on the growing interconnections between research, innovation, and copyright policy. As noted in the call for evidence, the uneven implementation of the optional scientific research exception under Directive 2001/29/EC (Infosoc Directive) creates challenges for cross-border collaboration.

Society of Authors ZAiKS welcomes the European Commissions review of the Copyright in the Digital Single Market Directive and supports the preparation of a targeted legislative initiative addressing the challenges arising from technological and market developments.

The Basketball Federation of Slovenia welcomes the European Commission’s initiative to review Directive (EU) 2019/790 and to consider additional measures to ensure more effective protection of copyright and related rights in the digital environment. From the perspective of the KZS, one of the key challenges is the unauthorised use of copyright-protected sports content on social networks.

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Contributors: Alexander Giboi (EANA), Lilian Hübner (dpa), Verena Krawarik (APA) In Response to the European Commissions Call for Evidence on the Review of the Digital Single Market (DSM) Directive Subject: Protecting the European Information Ecosystem: Why Copyright Enforcement in the AI Era is Essential for Democratic Resilience and Innovation.

EuroISPA, representing over 3,300 ISPs across the EU and EFTA, believes that the current framework needs clearer calibration rather than new legislation. On online piracy, EuroISPA's central argument is that the problem is one of enforcement, not a gap in the law.

Yleisradio Oy (Yle) is Finland's national public broadcasting company. We welcome the targeted approach put forward by the European Commission. Please find the attached PDF file, which contains our full response. Our response regarding the follow-up to the RAAP case can be found below.

The Finnish Musicians’ Association represents music performers in Finland and has the following views on the Commission’s call for evidence: The review of the DSM Directive has not succeeded in its objective of protecting music performers as the weaker contracting party and safeguarding their rights in the digital environment.

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Article 4: First, the article is problematic as the opt-out options are not operational for journalists and other media workers. Next the assumption that content for AI-training should be covered by article 4 creates fundamental problems for journalism. The lack of labeling makes it difficult to assess what and how content has been used for coding of AI. And for generative AI the problem will increase significantly.

SPARC Europe believes that Europe's copyright framework should support open science by ensuring access to publicly funded research, enabling lawful reuse and computational analysis of research materials, and ensuring that rights granted by law remain effective in practice. Europe would benefit from an ambitious and fully harmonised EU-level Secondary Publication Right (SPR) for publicly funded research outputs.

The Irish Writers Union is the main advocacy body for writers Ireland. Our response is based on feedback from our experience at advising on publishing contracts for our five hundred members. A) The CDSM Directive has failed to achieve its intended effect, particularly within copyright contract law and the elimination of the digital value gap.

The OpenMined foundation supports a balanced European approach to copyright, creativity, and artificial intelligence. The EU should avoid two extremes: allowing unrestricted extraction of creative and informational content by AI providers, or creating an overly restrictive copyright framework that would make the open web dependent on individual licensing for almost every form of machine access.

This submission is made in response to the European Commissions combined call for evidence concerning, first, the review of Directive (EU) 2019/790 on copyright and related rights in the Digital Single Market (CDSM Directive) and, the possible targeted legislative initiative for a better copyright environment for European creativity and innovation. Please find attached One Hungary's detailed response.

KLYS is the umbrella organization of professional cultural creators in Sweden, with 14 member organizations, in all representing approximately 30,000 creators and performing artists working in the fields of visual arts, theatre and film, music, literature and journalism.

Banijay Entertainment appreciates the opportunity to express its views on the Copyright framework and the future of the DSM Directive, a crucial instrument to foster European creativity and innovation. As Europes largest independent content producer and distributor, operating across 12 EU territories, Banijays business is built on the creation, production, financing, exploitation, and distribution of original…

LIBER, the Association of European Research Libraries, which brings together 431 libraries in 40 countries, welcomes the opportunity to contribute to this call for evidence. The 2019 Directive has brought about significant progress. However, the provisions related to research remain fragmented across Member States.

Ladies and gentlemen, please find attached our paper on the evaluation of copyright in the Digital Single Market Directive. In many cases, we have to find that the CDSM contains unfavourable rules for photographers. We have already pointed this out in several rounds of evaluations and replies to questionnaires. It would be helpful if you could better coordinate these different interviews.

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Please see the attached document for our full feedback. The European Commissions call for evidence on the review of the 2019 Copyright in the Digital Single Market Directive is welcome. The related targeted initiative aspires to foster a better copyright environment for European creativity and innovation.

BIMA is the Belgian independent music association. We welcome the European Commissions intention to clarify the rules on the use in the EU of sound recording of third country nationals where no remuneration right applies in those third countries.

Unicorns Lithuania, a Lithuanian startup and technology association representing more than 130 leading companies, welcomes the opportunity to provide feedback. As part of Europe's data and AI economy, our members rely on scalable, data-driven solutions.

The European Independent Media Publishers association (EIMP), representing over 2.000 innovative, independent, local, and regional digital-native media outlets across Europe, welcomes the Commission's initiative to gather feedback on possibly targeted measures to modernise the Copyright in the Digital Single Market (CDSM) Directive, and remains fully committed to serving as a trusted institutional partner to ensure…

IAO is the umbrella association for national organisations representing the rights and interests of featured artists in the music industry. The implementation of Articles 1822 of the CDSM Directive has not achieved its objectives for artists.

With respect to the European Commissions public consultation on the amendment of the Copyright in the Digital Single Market Directive, we would like to appreciate this initiative. LITA, Society of Authors is a collective management organization based in Slovakia, representing authors within the literary, drama, audiovisual and visual branch.

The Federation of Screenwriters in Europe (FSE) is the European network of regional and national guilds and trade unions of professional audiovisual screenwriters. FSE brings together 31 member organisations from 27 European countries, representing more than 10,000 screenwriters.

This contribution is submitted on behalf of the University of Naples Federico II as its institutional response to the European Commissions Call for Evidence. The attached document has been formally approved and digitally signed by the Rector, Professor Matteo Lorito.

The National Library of Sweden (KB) administers the national Bibsam Consortium. The consortium has 97 participating organisations, including higher education institutions, research institutes, and government agencies. Despite the implementation of the Directive, publishers continue to limit TDM through contractual terms.

The Network of Authors’ Rights (NAR) represents 15 writers’ and translators’ associations. In our opinion, we refer to 1) the impact of Directive 2019/790 (EU) on authors in the book sector and 2) options for legislative initiatives on copyright and new technologies (so-called AI). (1) The UR Directive (2019/790 (EU)) has failed to achieve its intended positive effect for authors.

Filed in German · English published by the European Commission

The Federal Chamber of Architects (Bundesarchitektenkammer e.V. – BAK) represents the interests of around 140.000 architects of all disciplines vis-à-vis politicians and the public at national and international level on behalf of the 16 chambers of state architects.

Filed in German · English published by the European Commission

On behalf of the Federation of European Publishers (FEP) we would like to share the following feedback. The refusal of AI providers to comply with EU law and to buy licences, the systematic use of pirated sources and the difficulty for rightsholders to enforce their rights due to a lack of transparency, create a systemic imbalance which prevents the development of an AI licensing market.

RadioMedia represents the Finnish commercial radio sector. We welcome the Commissions review of the Copyright in the Digital Single Market Directive and the targeted initiative for a better copyright environment for European creativity and innovation. Commercial radio supports a strong, balanced and workable copyright framework.

Founded in 2016, The Guild comprises twenty-three of Europes most distinguished research-intensive universities in seventeen countries and is dedicated to enhancing the voice of academic institutions, their researchers and their students.

I have personally discovered that 79 songs from my catalog are listed in The Atlantic's AI Training Dataset Watchdog - a public record of musical works ingested into AI training datasets without the consent of rights holders. Following consultation with a law firm specializing in AI copyright infringement, I joined a class action lawsuit in the United States as a plaintiff.

Open Knowledge Sweden Submission to the European Commission Call for Evidence Review of the Copyright in the Digital Single Market Directive and Targeted Initiative Open Knowledge Sweden is a Swedish non-profit promoting open knowledge through public domain, open source and Creative Commons licences.

It is crucial to preserve copyright exceptions and further harmonize and expand them for the benefit of the general interest. This is essential to improve access and use of the knowledge commons, and facilitate the mission by research organizations, universities, cultural heritage institutions, libraries and other communities that advance access to knowledge in the digital environment.

We welcome the European Commissions initiative to hold public consultations on the amendment of the Copyright in the Digital Single Market Directive. Our response focuses on the copyright infrastructure, i.e. on the first problem, objectives, policy options, and likely impacts mentioned in the Call for Evidence. Please find it here attached. Thank you.

The European Writers Council (EWC) is the worlds only federation representing exclusively authors in the book sector. Our response is based on feedback from our 55 member organisations across 34 countries and 260,000 individual members, on a) the impact of the CDSM Directive and b) policy options as set out in Ares(2026)4845636.

This reply is submitted by APA Associazione Produttori Audiovisuali (APA), an association representing independent producers of series, films for TV and VOD, entertainment, documentaries and animation (‘Producers’).

Filed in Italian · English published by the European Commission

CSC sees the review of the Directive 2019/790/EC on Copyright in the Digital Single Market as an opportunity to improve the copyright legislation to strike the right balance between safeguarding intellectual property and supporting data-driven research and innovation, including AI development.

We welcome the European Commission’s initiative to hold public consultations on the amendment of the Digital Single Market Directive, specifically related to the challenges faced by researchers in managing their copyright in publications, i.e. secundary publishing rights, in a section of copyright issues. Please find attached our response.

Filed in Slovenian · English published by the European Commission

AUDIOCOOP’s challenge to Spotify concerns the demonetisation policies for extracts with fewer than 1.000 reproductions. This choice severely penalises emerging artists and small independent Italian labels, prompting AUDIOCOOP to promote petitions to remunerate each individual stream.

Filed in Italian · English published by the European Commission

AMETIC appreciates the opportunity to participate in this public consultation and to contribute to the debate on the specific initiative to improve the copyright environment for European creativity and innovation. You can find our contributions in the attached file.

Filed in Spanish · English published by the European Commission

NPO contribution to the Targeted initiative for a better copyright environment for European creativity and innovation. NPO is the Dutch public broadcasting organisation. We welcome the targeted approach and we wish to comment on the following points of the Call for Evidence of the European Commission: Generative AI and copyright and Follow-up on the RAAP case.

The French Publishers Association (SNE) appreciates that the European Commission is reflecting upon how to help right-holders in enforcing their rights used by AIs. It would also like to warn the Commission against initiatives which would weaken copyright in the field of research. 1.

Full submission from the Copyright Information and Antipiracy Centre (CIAPC) is attached as a pdf-file. CIAPC finds that the existing copyright framework remains mostly fit for the purpose, and the EU copyright acquis should not be reopened. However, problems lie with differences in national implementation and in inefficient and even reluctant application.

DSM Article 3 and 4- We have been in favour of restrictions on text and data mining (TDU) and research at an early stage. We have focused on what is known as ‘text and data mining’, i.e. what we understand to have been a purpose of anaylating texts, sound recordings, etc. for various reasons. These may include optical surveys, analysis of old radio programmes, treatment of ethnic minorities on television.

Filed in Swedish · English published by the European Commission

Please find enclosed the comments of the SPANISH CENTRE FOR REPROGRAMME RIGHTS, EGDPI, CEDRO, to the PUBLIC CONSULTATION launched by the European Commission to seek OPINIONS ON SPECIFIC MEASURES FOR MODERNISING THE FRAMEWORK OF EU AUTOR RIGHTS, AND ON THE PRACTICAL IMPACT AND EFFECTIVE OF THE RULES introduced by the 2019 DIRECTIVE ON AUTOR RIGHTS IN THE DIGITAL ONE MARKET Many thanks to [name removed] CEDRO…

Filed in Spanish · English published by the European Commission

Full submission from the European Publishers Council is attached. The review of the Copyright in the DSM Directive takes place at a critical moment for journalism, media plurality, democratic resilience and European competitiveness.

CONTEXT AND EMPIRICAL BASIS This submission draws on the Data4SCI project (An Empirical Perspective on Challenges and Opportunities of the European Data Act for SMEs in the Swedish Creative Industry), conducted by Uppsala University and KTH Royal Institute of Technology, Sweden.

Please find below the summary of our submission. Full submission is attached as a PDF file. We submit that the absence of a single, interoperable, and machine-actionable rights-reservation standard should be treated as a defined shortcoming, and that an open standard should be endorsed in preference to a market-dominant proprietary alternative.

Schibsted believes that AI can be a powerful tool for innovation, economic growth and better journalism. Our objective is not to slow technological progress, but to ensure that it develops within a framework that is fair, transparent and allows for a sustainable market for journalism. Our central message to the Commission is clear: the DSM Directive is a functioning framework and should not be reopened.

We believe it is crucial to preserve copyright exceptions, particularly those related to text and data mining and the reproduction of artwork for illustrative purposes in educational and vocational contexts. These exceptions are essential for our researchers' work and, more generally, for all users.

The attached document provides feedback on the European Commission (EC) call for evidence from May 13 to June 25, 2026, on two initiatives that will be run in parallel: the report on the review of the Copyright in the Digital Single Market Directive (hereafter, CDSM Directive) and the preparatory work for a legislative initiative with targeted changes to the EUs copyright framework to enhance the resilience and…

The Call does not explicitly address issues related to access to culture. However, as the Commission has indicated openness to additional perspectives, as a member of Eblida Executive Committee and the head of library services in Vantaa City Finland, I would like to highlight two key issues that are particularly relevant for European citizens, libraries and municipalities.

The University of Ljubljana advocates a more ambitious and harmonised European copyright framework to support research, open science, and the public interest. Its core position is that the results of publicly funded research should be openly accessible immediately upon publication not only formally, but also under a genuinely open licence (CC BY or equivalent) that enables immediate use, dissemination, and reuse.

I submit this feedback as Dimitrios Bitzenis / freeSongs music, an independent European rightholder, creator, author, composer, performer, producer, phonogram producer and publisher of the freeSongs - Dimitrios Bitzenis repertoire.

The French Publishers Association (SNE) appreciates that the European Commission is reflecting upon how to help right-holders in enforcing their rights used by AIs. It would also like to warn the Commission against initiatives which would weaken copyright in the field of research. 1.

In the hospitality sector, music is used to enhance the service experience and create a atmosphere for guests. The amended reciprocity rules resulting from Case C 265/19 of the European Court of Justice risk and have also led to an increase in tariffs for certain sound recordings, which in turn leads to increased costs for, inter alia, hotels, restaurants, cafés and spa establishments.

Filed in Swedish · English published by the European Commission

The largest technology platforms have little incentive to engage in meaningful negotiations. The current legal and regulatory framework does not provide effective mechanisms for rightsholders to protect their content, enforce their rights, obtain transparency, or secure fair remuneration.

See paper attached Executive summary Despite the lack of any clear European law stating that hosting providers have a legal obligation to respond to take down notices from rights owners for live event piracy in less than 30 minutes, successful industry engagement by the audiovisual sector (chiefly led by AAPA and/or its members) has meant that many legitimate hosting providers now do so.

Intergram is a collective management organization based in the Czech Republic that represents performing artists and producers of sound and audiovisual recordings. In general, the cultural and music industry too are being challenged by the developments in the field of generative artificial intelligence, namely by the training of the AI models on copyrighted recordings without authorization.

This response is submitted on behalf of the Audiovisual Producers´ Association (APA), which represents audiovisual producers and production companies in the fields of live-action, documentary and animated films, film services, advertising and TV works in the Czech Republic.

This contribution concerns the out-of-commerce regime for works and subject matter governed by Articles 8 to 11 of Directive (EU) 2019/790 on copyright and related rights in the Digital Single Market (DSM Directive).

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This contribution is made within the framework of the European University Alliances, an initiative of the European Commission funded by the Erasmus+ programme. European University Alliances such as CIVICA are developing an increasing number of joint degrees, multi-campus programmes, shared teaching activities, blended intensive programmes, and transnational pedagogical collaborations.

In my view, the Commission’s initiative is correct and overdue. However, the question is not: Copyright or Artificial Intelligence? Instead: How do we create a digital ecosystem where creators, research, platforms and AI providers work together fairly? 1. However, copyright does not need a right to prevent innovation.Generative AI modifies texts, images, music, videos and voices. Creatives must be protected.

Filed in German · English published by the European Commission

I welcome the Commissions initiative to review the Copyright in the Digital Single Market Directive and to address the new challenges created by generative AI, especially for licensing, remuneration, enforcement and the protection of authors and performers.

We hope that the European Battery Alliance (EBA) will increase the cycle life of lead-acid batteries by 50%, increase energy density by 25% for the same volume and weight, improve battery safety by 35%, extend weather resistance to -50°C~150°C, increase CCA test time, reduce the minimum temperature from -18°C to -50°C, and extend the duration from 30 seconds to 150 seconds.

1. General: This submission draws on the findings of the book Music Contracts in the Streaming Age: Law and Policy in the European Union and the United Kingdom (Cambridge University Press, 2025, https://shorturl.at/Td2G6) and related academic work (see https://lirias.kuleuven.be/cv?Username=u0085979).

To establish connection to Vgregion [email removed] the Eu Ombudsman & The European Parliament has got all my diarienumbers to protect companies with copy right in supply chains. [EOWEB#57824] New complaint from: [email removed] - I Connect a real deal Inclusion to EU & WIPO Global Award Entry 2026 via Horizon Europe and need a partner who Can protect my community online and in my own life.