Update of EU rules on audiovisual media services

Zweites Deutsches Fernsehen (ZDF) welcomes the opportunity to contribute to the European Commission's evaluation of the Audiovisual Media Services Directive (AVMSD). As a public service broadcaster with a clear remit to serve the purposes of information, education and culture, we are convinced that the Directive plays a central role in safeguarding essential public interest objectives and that its importance is…

Given the number of health-related problems associated with obesity, childhood obesity has come under close attention in the last years due to its worrying trends. The WHO estimates that 1 child in 3 in Europe is overweight or obese.

The Commission's evaluation of the AVMSD focuses a wide range of important themes. The Finnish Media Federation (Finnmedia) (EU Transparency Register ID: 910162617573-84) position paper focuses on certain themes which are recognized to be most needed to take into account when considering the Commission's policy options to revise and update the AVMSD.

The European Cancer Organisation (ECO) welcomes the opportunity to contribute to the evaluation and potential update of the Audiovisual Media Services Directive (AVMSD). Our organisation replies to this consultation from a public health and cancer prevention perspective.

The Digital Poland Association (ZCP) presents this position in the framework of the Call for Evidence carried out by the European Commission in the context of the evaluation and review of the Audiovisual Media Services Directive (AVMSD).

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To date, the Spanish Union of Creators is the leading and pioneering association of Special Relevance Users in Spain or as influencers are known at national level. This brings together a total share of 18 % of Special Relevance Users registered in the Audiovisual Providers Register. This translates into a total share of 350 000 000 million followers within the digital audiovisual market.

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Televisión abierta welcomes the European Commissions initiative to evaluate and review the AVMSD to ensure its continued relevance in a rapidly evolving audiovisual landscape. In this context, we would like to highlight two critical aspects that must be preserved and reinforced in any future revision: 1.

BNE would like to highlight two critical regulatory priorities that must be preserved and reinforced in any future AVMSD revision: 1. Ensuring prominence and effective discoverability of public service and duly licensed broadcasting services 2. Recognising and safeguarding the strategic role of terrestrial broadcasting as a resilient and sovereign and widely accessible network for Europe.

The Slovak Television Broadcasters Association (ATVS) prefers the adjustment of the AVMS policy under option 2 (Targeted regulatory intervention), while we fundamentally reject option 3 (full review - an EU content directive/regulation). Regarding individual areas of regulation, ATVS as a national association representing both television broadcasters and VoD providers, we consider this necessary: 1.

Marine Friant-Perrot (HDR Lecturer) Nantes University We thank the European Commission for giving us the opportunity to share our views on how the Audiovisual Media Services Directive (AVMSD) could be revised to better protect children and the general public.

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For producers, IP rights are the backbone of editorial freedom, investment in new content and creativity. Production margins keep companies operational, but retaining IP rights is what enables continued reinvestment, innovation and creative risk-taking, editorial independence and cultural diversity. It also contributes to maintaining balanced relationships with clients across the audiovisual value chain.

Smoke Free Partnership and the Comité national contre le tabagisme welcome the European Commissions initiative to evaluate and revise the Audiovisual Media Services Directive (AVMSD), in light of the profound transformation of the media landscape.

Latvian NGO For Your Freedom welcomes the opportunity to provide input on the revision of the Audiovisual Media Services Directive (AVMSD). We consider this revision urgently needed, as the current rules are insufficient to protect children, in particular their right to the highest attainable standard of health and to effective protection from harmful marketing that undermines this right.

The COMMUNICATION USER ASSOCIATION is a non-profit organisation dedicated to defending the interests of citizens in their relationship with different media and communication systems. We believe that the update of the AVMSD text should take into account the following aspects, in order to achieve greater symmetry in the regulation of the different media service providers. 1.

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Contribution of the Czech Republic to the Call for Evidence for the Parallel Evaluation and Impact Assessment of the Audiovisual Media Services Directive (AVMSD) On the basis of the Call for Evidence for the Parallel Evaluation and Impact Assessment of the Audiovisual Media Services Directive published on the EC website, we provide comments on the objectives and measures considered – our contribution can be found in…

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PRELIMINARY POSITION - NO NEED TO REVISE THE AVMS DIRECTIVE INTRODUCTION PROG Producers of Germany represents more than 150 independent and arthouse producers. We are an ecosystem composed of flexible SMEs that are the most efficient tool for diversity and artistic boldness. Our members´ films regularly win prizes at majour film festivals like Berlinale, Cannes, Venice or else where in the world.

The Sports Rights Owners Coalition (SROC) is a forum 55 international and national sports bodies and competition organisers. SROC members contribute substantially to the wealth and wellbeing of countries, as key providers of long-term jobs, and some of the biggest tax-payers. According to the European Commissions most recent report, sport accounts for more than 2% of EU GDP and almost 3% of employment.

Rakuten TV Europe, SLU (hereinafter "Rakuten TV"), a Spanish subsidiary of Rakuten Group, Inc., which is headquartered in Tokyo, is a major Pan-European Video-on-Demand (VOD) platform headquartered in Spain. Operating across up to 43 countries, we provide European audiences with access to diverse content through a unique hybrid ecosystem combining Transactional VOD (TVOD), Advertising-based VOD (AVOD), and Free…

The Association of European Cancer Leagues (ECL) welcomes the European Commissions call for evidence on the Audiovisual Media Services Directive (AVMSD) and strongly supports its revision. ECL urges the Commission to reject Option 1 (no change), arguing that the current AVMSD does not provide effective or evidence-aligned protection for children against harmful marketing practices in a rapidly evolving digital media…

Smoke Free Partnership and the Comité national contre le tabagisme welcome the European Commissions initiative to evaluate and revise the Audiovisual Media Services Directive (AVMSD), in light of the profound transformation of the media landscape.

EuroHealthNet welcomes the Commissions evaluation/review of the AVMSD, including its focus on the rapidly evolving digital media environment, the rise of influencer-led marketing & uneven protection of minors across platforms and Member States. Children & adolescents spend substantial time in digital spaces: 42% are online >2h/day every weekday & 78% on weekends.

The Danish Chamber of Commerce thanks for the opportunity to provide input to the European Commission’s evaluation of the AVMSD and stresses the need for a modern, well-functioning and future-proof regulatory framework for the European media market. The Directive continues to play a key role, but technological developments and changing user behaviour make targeted adjustments necessary.

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The Netherlands Institute of the Classification of Audiovisual Media (NICAM) welcomes the European Commissions Call for Evidence for an Evaluation and Impact Assessment of the Audiovisual Media Services Directive (AVMSD). With this statement, we will contribute particularly with regards to the protection of minors. Our expertise and experiences stem from the mission of our organization.

We welcome this consultation and thank the European Commission for the opportunity to contribute to the discussion on how the Audiovisual Media Services Directive (AVMSD) could be revised to more effectively protect children, as well as the wider European population, from harmful marketing.

This position paper, prepared by the Catalan Communication Society (SCC), responds to the European Commission's call for evidence regarding the evaluation and possible update of the Audiovisual Media Services Directive (AVMSD).

The Association of European Radios (AER), representing commercial radio across Europe, welcomes the opportunity to provide feedback on the European Commissions call for evidence on the Audiovisual Media Services Directive. Please find attached our contribution for your consideration.

SPIR (Association for Internet Progress) represents the most important Czech companies active in the digital industry and is a local certified self-regulatory body for AVMSD. As for the scope of the directive, our members provide local VoD services (TV broadcasters´ VoDs and video/interviews databases of press publishers) and local video-sharing platforms.

Professor Amandine Garde has responded to this consultation on behalf of the Law & Non-Communicable Diseases Research Unit. Based on her expertise of harmful marketing regulation, and the number of publications she has published in this field alongside the policy work she has engaged in, she urges the Commission to firmly reject Option 1 (no change) and amend the Directive so it can - at long last - protect children…

Executive Summary Aylo supports the Commissions objective of ensuring that minors are effectively protected online and shares the concern that fragmented national approaches can undermine the internal market. This submission focuses on Art.

FID believes that the AVMSD should be revised to adapt it to the new information ecosystem, in particular to ensure citizens' access to reliable sources of information. The accompanying document details the following recommendations: 1. Ensuring citizens access to reliable sources of information 2. Regulating online information content creators 3.

Dr Nikhil Gokani, on behalf of the University of Exeter, welcomes the European Commissions consultation on revising the Audiovisual Media Services Directive (AVMSD) to better protect children and the wider population from harmful marketing. This response is a summary of our full response, which is attached.

NOS SGPS, S.A. (‘NOS’), through its shareholdings, provides electronic communications services and networks in Portugal and also operates in various areas of the audiovisual value chain. The activities of the NOS include support for the production of national films, the marketing and distribution of cinematographic and audiovisual works, the screening of films and television broadcasting, and the provision of…

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Executive summary This contribution presents Prime Video's view that reopening the Audiovisual Media Services (AVMS) Directive is premature at this time and not warranted. As a significant contributor to the European audiovisual industry, our primary concern is for stability, predictability, simplification and consistency in implementation.

The Evangelical Church in Germany (EKD) sees the evaluation of the Audiovisual Media Services Directive (AVMSD) as an opportunity to adapt the European media regulations to the rapidly changing media landscape. Media policy is a key component of democracy. It must safeguard freedom of expression, while always respecting human dignity and ensuring the protection of children and young people.

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Summary submission The Healthy Generation Program (the Netherlands). Please find attached letter for more details on its views and the need to amend the AVMSD. The Healthy Generation Program (the GG-Program), an initiative by 23 cooperating health foundations in The Netherlands, welcomes this opportunity by the European Commission to comment on the anticipated revision of the Audiovisual Media Services Directive…

In the attached document, the TF1 group submits its contribution to the evaluation and revision of the AVMS Directive. We are also sending the two studies cited in our contribution via the links below: - https://www.arcom.fr/se-documenter/etudes-et-donnees/etudes-bilans-et-rapports-de-larcom/evolution-du-marche-de-la-communication-et-impact-sur-le-financement-des-medias-par-la-publicite -…

CANAL+ believes it is too early to reopen the AVMSD: not only are the existing provisions flexible enough to address new challenges and market realities but, more importantly, the 2018 revision was recently implemented making it difficult to fully assess its impact on the market.

GESAC, through its 32 members - authors' collective management organisations - represents more than 1.2 million creators and rightholders in all artistic fields, including music, audiovisual, visual and literary arts, from across the EU/EEA. Please find attached GESAC's contribution to this consultation.

Founded in 2007, the French Telecoms Federation (hereinafter FFTélécoms) brings together 23 electronic communications operators, several of which also distribute audiovisual media services. It supports them in promoting a balanced regulatory framework that enables French players to develop in an increasingly competitive environment.

The German Advertising Federation (ZAW) is the national association of the advertising industry in Germany. It forms a large, dynamic network of 43 member organisations through which it represents all sectors and disciplines in advertising. The AVMSD works precisely because it balances legal obligations with proven, agile self-regulatory systems such as the German Advertising Council and EASA.

DOT Europe welcomes the opportunity to contribute to the European Commissions evaluation and update of the Audiovisual Media Services Directive (AVMSD). We represent both video-on-demand (VoD) providers and video-sharing platforms (VSPs) and therefore represent a broad spectrum of services regulated under the Directive.

The Civil Society of Multimedia Authors, LaScam, is a collective management organisation representing more than 57 000 authors in the fields of audiovisual and radio documentaries, journalism, literature, translation, illustration and content creation.

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IAB Europe encourages the Commission to maintain a stable and predictable regulatory framework. The current AVMSD remains fit for purpose, and challenges identified in the audiovisual ecosystem stem primarily from fragmented enforcement and a lack of consistent guidance. These issues can be addressed without reopening the Directive.

IMPF is the global trade and advocacy body for independent music publishers, representing more than 300 companies worldwide. Our members are deeply rooted in local cultural and economic ecosystems, investing in songwriters and composers, supporting cultural diversity, and enabling repertoire to reach audiences across borders.

Seldia welcomes the opportunity to contribute to the call for evidence on the evaluation and update of the Audiovisual Media Services Directive (AVMSD). We acknowledge that the audiovisual media ecosystem has undergone significant changes since its last revision. However, we believe that the AVMSD remains fit for purpose.

The feedback indicates that the current definitions and general provisions of the AVMSD are adequate, flexible, and compatible with the Digital Services Act (DSA). While influencer obligations are already covered under existing provisions, additional EU-wide guidance would help clarify compliance expectations and ensure consistent implementation across Member States.

As a major European sports broadcaster, beIN SPORTS considers that the Directive still provides a relevant and balanced framework. At this stage, the priority should not be a comprehensive revision, but rather a strict, consistent and transparent enforcement of existing provisions, particularly those essential to the financing of sport and to fair competition in the audiovisual market.

Sky welcomes the opportunity to contribute to the European Commissions consultation on the evaluation of the Audiovisual Media Services Directive (AVMSD). Sky is one of Europe's leading media and entertainment companies, connecting and entertaining millions of customers across six countries. Europes media sector is not just a cultural asset, it is a strategic one, and it is undergoing profound transformation.

See attached reply. Executive summary: The Internet Foundation welcomes the European Commission’s initiative to evaluate and modernise the regulatory framework for audiovisual media services. The digital ecosystem has fundamentally changed since the last revision in 2018.

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Bitkom welcomes the opportunity to contribute to the European Commission's Call for Evidence (CfE) regarding the evaluation of the Audiovisual Media Services Directive (AVMSD). In a rapidly evolving media environment, this evaluation represents a crucial moment to assess the effectiveness and relevance of the current regulatory framework.

Yle considers the strengthening of visibility regulation is essential for trusted, reliable, and culturally relevant content and emphasizes updating visibility obligations to match the rapid development of media user interfaces and user experience (UI/UX) across different platforms.

Fossil Free Football advocates for the world's most popular sport to align itself with a science based approach to climate change. Part of that advocacy concerns the promotional messages communicated to football supporters when they engage with the game on television or online services. Sports events and advertising of products through sport via sponsorship are regulated by the AVMSD.

The European Coalitions for Cultural Diversity (ECCD), founded in 2005 to support the UNESCO Convention on the Protection and Promotion of the Diversity of Cultural Expressions, continues to promote its principles at EU level following the Conventions ratification in 2006. Chaired by a former Member of the European Parliament, the ECCD brings together ten permanent national coalitions and two observers.

Child Helpline International is a global network of 143 child helplines in 124 countries and territories. We submit our contribution attached. Summary: Children are living a mental health crisis as demonstrated by the sheer number of children contacting European helplines for support with emotional distress, self-harming and suicidal behaviours, addiction and eating disorders.

Middle Tech Europe (MTE) is a growing alliance whose members currently include Automattic, Dailymotion, Discord, Dropbox, Patreon, Pinterest, Reddit, WeWard, Yahoo, and Yubo. Our members operate a wide variety of services, ranging from video-sharing and e-commerce to e-mail, forums, communication, media, and hosting services representing the often missing middle-voice in tech policy discussions.

The European Broadcasting Union (EBU) welcomes the opportunity to contribute to the European Commissions evaluation of the Audiovisual Media Services Directive (AVMSD). As the voice of public service media (PSM), we firmly believe that the Directive plays a vital role in advancing core public interest objectives - and that its importance has never been greater.

The Advertising Information Group (AIG) welcomes the opportunity to respond to the European Commissions Call for Evidence on the Evaluation and Update of the AVMSD Rules. 2. The European audiovisual media environment has undergone significant change since the 2018 revision, including the rise of non-linear services, video-sharing platforms (VSPs), and influencer marketing.

The AVMSD seeks to safeguard the freedom of expression and the free movement of goods while ensuring a high level of consumer protection with easy-to-use and effective procedures. Several key provisions rightfully allow for proportionate limitations when other fundamental interests are at stake, such as public health and environmental protection.

The European Union has the competence to regulate cross-border marketing and to harmonise national rules in order to facilitate the establishment and proper functioning of the internal market, in particular the free movement of goods and services. In addition, the EU Treaties require the Union to ensure a high level of health and consumer protection across all its policies, including internal market policy.

The European Video on Demand Coalition believes that the most appropriate course of action, as outlined in the Commission's policy options, is maintaining the status quo (baseline scenario): no change to the AVMSD. We strongly advocate for focusing first on full and proper implementation by Member States and on guidance on how principles need to be implemented.

Audiovisual media service providers with editorial responsibility have for many years been subject to strict regulations under the audiovisual media service directive (AVMSD). The last revision of the directive in 2018 brought necessary changes that were meant to reflect the evolving landscape of audiovisual content consumption and distribution.

Bundesverband Digitale Wirtschaft e.V. supports the European Commission’s objective of ensuring an efficient, fair and future-proof regulatory framework that protects media pluralism, fosters innovation and strengthens the competitiveness of the digital economy. However, the existing legal framework of the AVMSD continues to provide a solid foundation for audiovisual services in Europe.

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Adigital, the Spanish Association for the Digital Economy, appreciates the opportunity of providing feedback to the call for evidence. The attached document includes a series of considerations in key areas such as definitions, viewers protection or commercial communications, or the financial contribution for the production of European works that we believe should be taken into account in the upcoming evaluation of…

The Audiovisual Media Services Directive (AVMSD) establishes a series of principles and rules for operators under its jurisdiction, which implies, for video-on-demand (VOD) platforms, an obligation to respect certain quotas of European content. It also proclaims the right to accessibility for persons with sensory disabilities but does not set concrete rules to guarantee that right.

Please find in attachment EASA's full feedback. Key points and recommendations: - There is no ground for reopening the AVMSD, since the AVMSD remains fit for purpose. - Existing rules fully apply to influencer marketing. - Enforcement, awareness-raising & self-regulation are of the essence to protect viewers and minors.

ZVEI welcomes the upcoming revision of the Audiovisual Media Services Directive (AVMSD) as a crucial op-portunity to restore coherence, reduce fragmentation and enhance the effectiveness of the European internal market.

Executive summary The Audiovisual Media Services Directive continues to provide a robust, balanced and futureproof regulatory framework. It delivers legal certainty, safeguards viewers and minors, and accommodates innovation in audiovisual and online advertising markets. Influencer marketing is already comprehensively addressed under existing EU legislation.

UDi.Con. welcomes the evaluation/revision of the Audiovisual Media Services Directive, highlighting the need for a clear and comprehensible regulatory framework for consumers, especially with regard to the transparency of commercial communications and the protection of minors.

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The SACD, founded in 1777 by Beaumarchais, is the oldest copyright collecting society. It represents more than 60 000 authors of the live performance, the audiovisual, the cinema and the web, and defends their rights through political, institutional and professional actions. It also supports contemporary creation and plays an active role in national and European fora for cultural diversity.

Filed in French · English published by the European Commission

Please find attached the feedback of the European Magazine Media Association (EMMA) and the European Newspaper Publishers' Association (ENPA) to the Call for Evidence on the evaluation of the Audio-Visual Media Services Directive (AVMSD). We remain at your disposal for any clarification.

With this contribution, Confindustria Radiotelevisioni intends to provide some reflections on the prospects for revising the set of rules laid down in the AVMSD, with a view to contributing to the evolution of the rules in a pro-competitive manner. Lassociazione agrees with approach No 2 entitled Targeted regulatory intervention set out by the Commission in Section B of the consultation document.

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The Society of Audiovisual Authors (SAA) is the umbrella association of European collective management organisations representing audiovisual authors. Its 33 members in 25 countries manage rights for over 177,000 film, television and multimedia European screenwriters and directors.

foodwatch Input into the Call for Evidence on Audiovisual Media Services Directive (AVMSD) foodwatch is a European non-profit consumer organisation that has been fighting for safe, healthy and affordable food for all people since 2002. foodwatch operates at the national and European levels and has offices in Austria, France, Germany, the Netherlands and Brussels.

The World Federation of Advertisers (WFA) considers the current Audiovisual Media Services Directive (AVMSD) fit for purpose and believes it should not be reopened (policy option 1). The Directive continues to provide the right balance of legal certainty, consumer protection and stability in a rapidly changing media environment.

Contribution from The Brewers of Europe to the evaluation of the EU Audiovisual Media Services Directive The Brewers of Europe brings together national brewers associations and companies from 28 countries to represent and support the interests of Europes 10,000+ breweries. We welcome the opportunity to contribute to the evaluation of the EU Audiovisual Media Services Directive.

The German Digital Opportunities Foundation welcomes the European Commissions Call for Evidence for an Evaluation and Impact Assessment of the Audiovisual Media Services Directive (AVMSD). The aim of the AVMSD is to establish and ensure a level playing field of a single market for audiovisual media services in the European Union, while contributing to the promotion of cultural diversity and offering an adequate…

This submission is led by CAADs EU Policy Task Force and draws on evidence from across our network, including ClientEarths recent Digital Distortion report, which documents how platform-based advertising systems amplify climate disinformation and associated environmental harms.

A comprehensive regulatory approach is needed to reduce the exposure of children and adolescents to the marketing (commercial communication) of foods and drinks high in fats, sugars and salt. Despite high levels of exposure to the marketing of these foods, the association of such marketing with adverse health effects and the long-standing recommendations to limit childrens exposure, policy approaches to address…

TikTok is a leading destination for mobile video, that first entered the EU market in 2018. Creators of all backgrounds sit at the heart of TikTok, forming a community where authenticity and diversity are celebrated. More than 200 million people across Europe now come to TikTok every month - to express themselves, be entertained, learn a new hobby or skill and find or grow a business.

AllScreens, the association of film distributors and audiovisual media, is closely following the discussions at European level on the possible opening and reform of the Audiovisual Media Services Directive (AVMSD). From the point of view of AllScreens, there is no need to open up or substantially revise the existing Directive.

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Input regarding blockchain developed in our participation in the "Crescine" Horizon Europe project: Our report called : "Blockchain's Role in Transforming Europe's Film Industry": can be found at this link: https://zenodo.org/records/17207187 The key contribution of our blockchain report is that EU audiovisual regulation should provide legal clarity, interoperability and space for experimentation, enabling digital…

It is too early to reopen the AVMSD and efforts should instead prioritise enforcing the current rules and assessing their interaction with the newly adopted DSA and EMFA. The main issue is a lack of effective enforcement, which creates an uneven playing field where broadcasters and VOD services face stricter obligations than largely unregulated VSPs.

CNA Cinema and Audiovisual welcomes the opportunity to contribute to the public consultation launched by the European Commission on the future revision of the Audiovisual Media Services Directive (AVMSD). CNA strongly believes that any revision of the AVMSD must reinforce the instruments that support independent producers and ensure the visibility, circulation, and financing of European works.

The Swedish Heart Lung Foundation underline the need for a strong public health perspective in the EU rules on audiovisual media services, with particular urgency around regulating digital marketing of unhealthy products targeted at children and adolescents.

Beyond Mainstream is a coalition of international streaming services offering specialised and genre-specific content globally, including across the EU. Our members serve audiences with diverse cultural, linguistic and creative interests and operate under unique business models compared to generalist audiovisual providers.

The Internet Society welcomes the opportunity to contribute to the impact of rules on audiovisual media services. We are especially concerned about the trend to use IP and DNS-based blocking without considering its side-effects.

Please find attached our recommendations specifically for prominence of audiovisual media services, and below a short summary. Prominence rules applicable to distributors of audiovisual service providers and user interface providers require harmonisation. To achieve this, the European Commission should issue guidance on prominence, as foreseen by the European Media Freedom Act (EMFA) .

Today, in addition to traditional media services, video-sharing platforms, influencers and, increasingly, AI-generated content are shaping the media landscape. These developments not only change the way media is used, but also pose new challenges to the existing legal framework: unclear rules, lack of transparency and manipulative advertising practices create real risks for consumers in their daily lives.

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We welcome the Commission’s focus on and examination of, inter alia, the scope, prominence of media services of general interest (Article 7a of the AVMSD), including potential imbalances between competing market players such as difficulties for certain service providers to gain prominence on smart TVs and user interfaces, as well as stakeholders’ views on possible legislative changes to the Directive.

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As the only supranational organisation representing more than 1 million deaf people before the European Union through a network of National Associations of the Deaf (NADs) from 31 countries (27 Member States, Iceland, Norway, Switzerland and the United Kingdom), the European Union of the Deaf (EUD) issued a report on the implementation of the AVMSD.

Our study group is currently engaged in TV and digital marketing monitoring and has identified considerable gaps in the present Audiovisual Media Services Directive: - Ad Art. 9 (3-4): Several studies have shown that co-regulation and self-regulation are inefficient means of reducing exposure of children and adolescents to HFSS advertising. (e.g. Boyland et al. 2022; Jensen et al.

This feedback is presented on behalf of CresCine European Union (EU) funded project. CresCine is a European Horizon 3-years initiative designed to enhance the international competitiveness and cultural diversity of the small European markets film industry (HORIZON-CL2-2022-HERITAGE-01, project ID: 101094988).

LEONINE Holding GmbH is one of the leading independent media companies in Germany, covering the entire value chain of the moving image market. We are closely following the discussions at European level on the possible opening and reform of the Audiovisual Media Services Directive (AVMSD). We are not in favour of opening up the AVMSD.

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The umbrella organisation for the film industry (SPIO), which represents the interests of the German film industry, takes good note of the discussions at European level on the possible opening-up and reform of the Audiovisual Media Services Directive (AVMSD). We strongly oppose the opening up of the AVMSD.

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In respect of a possible AVMSD revision, Deutsche Telekom AG (DTAG) holds that the country-of-origin principle should be strengthened by -- foreseeing higher levels of harmonization in the Directive, -- while decisively reducing Member States leeway to issue stricter or more detailed rules in the fields already coordinated through EU legislation; where Member States opt to establish rules on public-value services…

The Committee of Entities Representatives of Persons with Disabilities of the Autonomous Community of Valencia (CERMI CV), in response to the Call for Data (Ref. Ares (2025) 10181999) for the evaluation and revision of the Audiovisual Media Services Directive (AVMSD), presented the attached document containing 120 technical and legal contributions structured in 50 thematic blocks.

Filed in Spanish · English published by the European Commission

We underline the need for a strong public health perspective in the EU rules on audiovisual media services, with particular urgency around regulating digital marketing of unhealthy products targeted at children and adolescents.

Executive Summary Telefónica responds to the European Commissions Call for Evidence on the evaluation and potential revision of the Audiovisual Media Services Directive (AVMSD), a cornerstone of EU media regulation last updated in 2018 and complemented by the European Media Freedom Act (EMFA) in 2024.

To whom this may concern, PHOENIX group welcomes the Commissions initiative aimed at improving the cross-border circulation of media content and protecting viewers. To educate and inform patients about the patient-centered care they can receive in their local pharmacies, PHOENIX group uses influencer marketing on Instagram and TikTok in several markets where we are active with our pharmacy operations notably in…

Movendi Sweden (formally IOGT-NTO, Junis and UNF) and The European Centre for Monitoring Alcohol Marketing (EUCAM) welcome the initiative to evaluate and update the Audiovisual Media Services Directive (AVMSD). As public health organizations working to reduce alcohol-related harm especially among young people and other risk groups like people in recovery from alcohol addiction - we consider audiovisual regulation a…

Stellungnahme der Spitzenorganisation der Filmwirtschaft (SPIO) zur Diskussion um die Überarbeitung der AVMD- Richtlinie Die Spitzenorganisation der Filmwirtschaft (SPIO) als Interessenvertretung der deutschen Filmwirtschaft nimmt mit großer Aufmerksamkeit die Diskussionen auf europäischer Ebene zur möglichen Öffnung und Reform der Richtlinie über audiovisuelle Mediendienste (AVMD-RL) zur Kenntnis.

Audio description and audio subtitling are effective measures to implement accessibility for visually impaired persons. Despite the slow and challenging transposition, the revised Audiovisual Media Services Directive (AVMSD) brought positive points in terms of accessibility.