Consultation participation and their own register declarations, side by side. Counts, not judgments — participation is not influence.
Counts here are a floor, never a total: they cover the 583 consultation files tracked so far (42,224 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
Register facts self-declared (snapshot 2 Sept 2026); cost bands are floors. Shared files are shared attention, not evidence of coordination.
What each said, in their own words
Their opening passages on the files they share, verbatim and in filing order. We do not summarize, compare, or characterize positions — read them at source.
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.
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.
PlayRight* strongly supports the initiative defined in the present Call for Evidence and appeals to the Commission to pursue the said initiative with the highest priority. You will find our feedback in attachment. *PlayRight is the collective management organisation (CMO) of neighbouring rights for performing artists in Belgium and manages as such the single equitable remuneration.
IMPALA is the European association of independent music companies. EU performers and labels stand to be the most impacted by the “RAAP” ruling. We very much welcome the European Commission’s intention to introduce rules for third country nationals through a legislative intervention.
Take this comparison with you
2 organizations on one sheet: every file each filed on, their register declarations, and a working link to each submission. Free: we ask for your name and email, and PolicySpeak may contact you about the product (privacy policy). The per-file record stays downloadable without signing up on each file’s page.