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Association of European Radios

AER

The Association of European Radios is a trade body representing commercial radio stations to the EU institutions.

Lobbying Activity

European radio trade body opposes new EU audiovisual rules

20 Dec 2025
Topic — The Commission is evaluating the impact of current European audiovisual media rules.
Message — The association opposes extending audiovisual regulations to radio to avoid unnecessary burdens. They recommend focusing on tech platforms that act as gatekeepers to radio content. They also call for mandatory radio receivers in all new vehicles sold in Europe.123
Why — This would prevent expensive compliance costs and stop tech platforms from charging access fees.45
Impact — Tech companies and car manufacturers would lose control over their interfaces and advertising revenue.67
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Meeting with Barry Andrews (Member of the European Parliament)

13 Nov 2025 · Radio regulation in Europe

European radio industry seeks ePrivacy reforms to protect advertising

14 Oct 2025
Topic — The EU is proposing a digital omnibus to simplify regulations for businesses.
Message — The association requests aligning data collection rules with the GDPR to allow for legitimate interest processing. They also argue that individual service consent should take precedence over generic browser settings.12
Why — These changes would secure advertising revenue by reducing the impact of user consent fatigue.34
Impact — Internet users may face restricted content access unless they agree to data tracking.5
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Meeting with Thomas Schmitz (Cabinet of Executive Vice-President Henna Virkkunen)

16 Sept 2025 · Association of European Radios

Meeting with Gerasimos Sofianatos (Head of Unit Communications Networks, Content and Technology)

15 Sept 2025 · Digital Networks Act - Review of the European Electronic Communications Code

Meeting with Sean Mernagh (Cabinet of Executive Vice-President Teresa Ribera Rodríguez)

15 Sept 2025 · Digital Networks Act, Digital Markets Act (DMA).

European radio industry demands digital prominence and advertising protections

29 Aug 2025
Topic — The EU is setting consumer policy and digital fairness priorities for 2025-2030.
Message — The AER requests lighter obligations for radio broadcasters while imposing strong rules on digital gatekeepers. They call for avoiding excessive advertising restrictions and ensuring radio's findability on connected devices.123
Why — This approach would protect their advertising-based revenue model and ensure market visibility.4
Impact — Big tech gatekeepers would lose the ability to prioritize their own services over radio.5
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European radio association urges mandatory broadcast receivers in vehicles

11 Jul 2025
Topic — This consultation seeks to improve EU digital infrastructure for cloud and AI transitions.
Message — The group demands all new vehicles include receivers supporting broadcast and internet formats. They also request that radio stations remain prominently placed and easily findable on digital dashboards. Finally, they oppose the introduction of mandatory network fees for online content delivery.123
Why — These rules would cement radio's presence in vehicles and prevent new distribution costs.45
Impact — Global tech firms would lose their exclusive influence over car infotainment software platforms.67
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Meeting with Sunčana Glavak (Member of the European Parliament)

10 Jun 2025 · Role of radio in media landscape

European Radios Urge Flexibility in Political Ad Labeling Rules

28 May 2025
Topic — The Commission is establishing technical specifications for political advertising labels and notices.
Message — The association requests flexible rules for audio and fewer complex information requirements. They also oppose mandatory volume increases for labels to avoid irritating listeners.123
Why — Broadcasters would avoid significant compliance costs and preserve the listener experience.45
Impact — Transparency advocates lose when listeners receive less detailed information during live broadcasts.6
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Meeting with Marie-Helene Boulanger (Head of Unit Justice and Consumers) and EBU-UER (European Broadcasting Union) and

22 May 2025 · Consultation of media representatives and associations in the context of the preparation of the upcoming European Democracy Shield (“focus group”).

Meeting with Tena Misetic (Cabinet of Commissioner Dubravka Šuica)

20 Feb 2025 · Introductory meeting

Meeting with Jördis Ferroli (Cabinet of Commissioner Michael McGrath)

18 Feb 2025 · European Media Freedom Act (EMFA)

Meeting with Sunčana Glavak (Member of the European Parliament)

10 Dec 2024 · Fight against misinformation and disinformation, role of radio as a trustworthy media, advertising limitations, DMA and DSA

Association of European Radios Rejects Network Fees and Spectrum Changes

28 Jun 2024
Topic — This consultation explores scenarios for mastering Europe's future digital infrastructure and connectivity needs.
Message — AER opposes mandatory payments from content providers to support telecom network infrastructure costs. They want specific radio frequencies reserved exclusively for broadcasting well beyond the year 2030. Radio broadcasters should be granted safe harbours to protect them from future financial obligations.123
Why — This prevents new costs and secures the frequencies needed for terrestrial radio broadcasting.4
Impact — Large telecom companies would lose potential direct payments from various digital content providers.5
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Response to Proposal on the conditions for the remuneration of third country recorded music played in the EU

22 Sept 2022

The Association of European Radios – AER – is the Europe-wide trade body for commercial radio, representing the interests of companies operating over 5,000 commercial radio stations to the EU Institutions. AER promotes the development of commercially-funded radio broadcasting in Europe, by ensuring a fair and sustainable economic framework for radio so it can continue to thrive. AER welcomes the opportunity to respond on behalf of its members to the European Commission’s call for evidence on the application of Article 8(2) of the Rental and Lending Right Directive (2006/115/EU), and the impact of the Court of Justice of the EU (CJEU)’s RAAP Judgment. The CJEU held that Article 8(2) applies to use in the EU of phonograms published for commercial purposes irrespective of nationality. It also held that Member States are not entitled to legislate on the equitable remuneration of performers and producers from sound recordings. The CJEU found that it is for the EU and not Member States to limit the single equitable remuneration right of the third country nationals, should it choose to do so. In so doing, the decision has put into question the reciprocal approach adopted by a number of Member States since the introduction of the WPPT in 1995, with unfair consequences for users of music rights, who are at risk of receiving requests for substantial increases in royalty payments, and with no benefit to performers and producers of phonograms established in the EU. For instance, the Netherlands have updated their national statute book to reflect the Court’s Decision, and this has led to a significant increase in costs for Dutch broadcasters in the remuneration of performers and producers of phonograms established in third countries. An analogous situation is expected to arise in other Member States where national legislation has the effect of limiting the single equitable remuneration right of third country nationals, because such nationals are established in countries (such as the USA) which have refused to grant a right to single equitable remuneration to EU nationals. In these countries, commercial radio broadcasters could find themselves in a position where collecting societies start collecting royalties on behalf of nationals in third countries which have refused to grant a right to single equitable remuneration to EU nationals, in a context where there is significant legal uncertainty around whether or not such royalties are due. The situation is particularly acute in relation to music produced or performed by nationals in the USA, as American music is highly popular in Europe, and this country has refused to grant a right to single equitable remuneration to third country nationals, including those established within the EU, under article 15 of the WPPT. In practice, this results in nationals of Member States who operate in the international recorded music business not receiving an adequate income and experiencing greater difficulty in recouping their investments. It also means that users of music rights in some Member States, including radio broadcasters, will have to unduly bear the financial consequences of the RAAP decision, with no benefit to performers and producers of phonograms established in the EU. We therefore agree with the Commission on the need to find a solution to this unbalanced situation in order to better defend users of music rights, European performers and producers internationally. We thank you for your attention and we look forward to providing further feedback to the follow-up targeted public consultation. AER remains at your disposal for any additional information you may require.
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Response to The Union Position for the World Radiocommunication Conference 2023

26 Jul 2022

The Association of European Radios – AER - is the Europe-wide trade body for commercial radio, representing the interests of companies operating over 5,000 commercial radio stations to the EU Institutions. AER promotes the development of commercially-funded radio broadcasting in Europe, by ensuring a fair and sustainable economic framework for radio so it can continue to thrive. AER welcomes the opportunity to respond to the Commission’s call for evidence aimed at establishing a common EU position to be negotiated by Member States on behalf of the EU and to be adopted by the Council at the World Radiocommunication Conference 2023. WRC-23 will be the forum where the decision on the future use of 470-694 MHz band will be made at international level. More specifically, the AER would like to give its views on the WRC-23 Agenda Item 1.5 regarding the review of the use of the 470-960 MHz band and possible regulatory actions in the 470-694 MHz band. The EU UHF Decision foresees, in its article 4, that the 470-694 MHz band shall be used by broadcasting organisations and PMSEs “at least until 2030”. AER considers that a review of how the UHF band is used is both premature, and uncalled for, as such a review would put into question the long term availability of the UHF band for terrestrial broadcasting, which in term would threaten service continuity for terrestrial TV and radio audiences across Europe, and the broad range of public value that terrestrial broadcasters deliver to society. Such public value includes the provision of trusted local and national news bulletins, at a time when fake news is rife on social media networks. Terrestrial TV and radio are also a source of companionship (for example supporting people who may be lonely or feel isolated), entertainment and music discovery (providing cultural enrichment), and an amplifier of charitable causes and issues of major importance to society (such as the under-representation of young people from minority ethnic backgrounds in the creative industries). Given the above, defending the position of the EU UHF Decision at WRC-23 is crucial: the UHF band must continue to be allocated on existing primary basis to terrestrial broadcasting and with a secondary allocation to PMSEs without any changes. AER therefore urges the Commission, the Council and Member States’ representatives to strongly oppose a co-primary allocation to mobile services and support a position of ‘No change’ to the Radio Regulations under WRC-23 agenda item 1.5 in order to preserve European broadcasters and the public value contribution we make to society, incentivise high levels of investment in quality and trusted content over the longer term, and support Europe’s creative sector and global soft power.
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Response to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services

31 Mar 2021

The Association of European Radios (AER) is the Europe-wide trade body for commercial radio, representing the interests of companies operating over 5,000 commercial radio stations to the EU Institutions. AER promotes the development of commercially-funded radio broadcasting in Europe, by ensuring a fair and sustainable economic framework for radio so it can continue to thrive. Following the initial examination of the Digital Services Act (DSA) proposal and internal discussions, AER’s members would like to highlight the points in the attached document. Indeed, these are only preliminary observations as we continue our analysis on this important Regulation for the digital economy.
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Response to Consumer Credit Agreement – review of EU rules

1 Sept 2020

Commercial radio is funded almost entirely by advertising, enabling it to remain free-to-air and free-to access to millions of listeners. It relies on its advertising business model to be present on every platform, including online, enabling it to create content and innovate. Unnecessary restrictions on advertising should be avoided. Studies show long terms and conditions in radio and audio do not benefit consumers and fail to provide protection. Advertising limitations also severely impact radio’s opportunities to remain a valuable European content provider by cutting off revenue. We, at AER, are happy to be able to comment on the Roadmap on the Revision of the Consumer Credit Directive. Please see attached AER's contribution.
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Response to Evaluation of the Consumer Credit Directive

27 Jul 2018

AER is the only Europe-wide trade body representing only radio to the EU institutions in Brussels, representing the interests of over 4500 private/commercial radio stations across the EU28 and in Switzerland. We are happy to be able to comment on the evaluation / roadmap of the Consumer Credit Directive 2008/48/EC. The commercial radio industry fully supports the CCD’s principles of facilitating a well-functioning internal market and ensuring consumers are adequately protected. But there is clear evidence that this regulation is negatively affecting financial services, motors and retail businesses as well as the radio industry, and that the standard information resulting from the CCD is failing to protect consumers – whilst this appears in the “Context”, it does not seem to appear in the “Purpose and scope” of the "evaluation roadmap”. We would therefore like to underline that the following points should be considered in the evaluation 1. We understand that the scope of the CCD review has been extended to take into account concerns that were voiced with the REFIT Platform in 2016, ending with an Opinion (https://ec.europa.eu/info/sites/info/files/vi4afccd.pdf) adopted on September 21st, 2017, recommending that the Commission assess ‘the relevance, effectiveness and efficiency of the standard information requirements triggered by Article 4 in the context of the upcoming report of the Directive, currently scheduled for 2019’ 2. It is important to note that standard information requirements in advertising have a different impact than in other circumstances and should indeed be treated differently in this assessment 3. Given the impact of the current Directive on advertising, it would also be key that representatives from the wider advertising industry are included in the targeted consultation for this review, including those organisations who also submitted to the REFIT Platform on the same issue Research commissioned by AER members in the United Kingdom and France thus demonstrates that these standard information requirements in advertising are failing to inform and protect consumers – only 3-4% of radio listeners recall the total amount payable immediately after hearing a radio advertisement with a consumer credit offer and a majority of listeners thought terms and conditions were designed to protect the advertiser rather than the consumer. When listeners were presented with a shorter focused alternative to the current requirement for standard information the recall rate improved dramatically. Article 4 of the Consumer Credit Directive 2008/48/EC (CCD) requires that “Any advertising concerning credit agreements which indicates an interest rate or any figures relating to the cost of credit to the consumer shall include standard information”. For radio, this means that the information has to be read aloud in real time. This can result in over 25 words of technical financial jargon at the end of ads or, in the case of radio advertising, 12-15 seconds of additional airtime. This increases the length of a radio ad and hence cost to the advertiser. It can also have a negative impact on creativity and damages the listener experience. For both these reasons advertisers can be put off using radio, including small and medium enterprises for whom radio can provide a valuable opportunity to reach consumers. The unique characteristics of radio have been considered in recent legislation. We stand ready to help to ensure consumer protection is optimised in a workable manner for our sound-based advertising funded industry, providing free-to-air trusted information in times of crisis, disasters or on your way to work. More information here: http://ec.europa.eu/smart-regulation/refit/simplification/consultation/docs/refitplatform_aer_submission_04052016.pdf
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Meeting with Stig Joergen Gren (Cabinet of Vice-President Andrus Ansip)

19 Dec 2017 · SatCab Regulation

Meeting with Eduard Hulicius (Cabinet of Commissioner Věra Jourová) and Radiocentre

16 Nov 2017 · Consumer credit directive

Meeting with Eduard Hulicius (Cabinet of Commissioner Věra Jourová) and EUK Consulting

20 Sept 2016 · Consumer credit directive obligations on advertising in radios

Meeting with Laure Chapuis-Kombos (Cabinet of Vice-President Andrus Ansip)

16 Sept 2016 · commercial radio - Consummer Credit Directive

Meeting with Andrus Ansip (Vice-President) and

29 Feb 2016 · Spectrum, UHF band