Cine-Regio AISBL (European Associations of Regional film & AV funds)
Cine-Regio
The members (regional public film and audiovisual agencies) exhibit a range of support schemes and services to the Film and Audiovisual sector which aim to support film & AV culture, encourage social cohesion and build regional infrastructure and businesses.
ID: 829063922689-04
Lobbying Activity
Response to General revision of the General Block Exemption Regulation
6 Oct 2025
Cine-Regio AISBL the association of regional film and audiovisual funds in Europe (including autonomous regions and communities) welcomes the opportunity to contribute to the revision of the GBER. Please find our response in the attached pdf. CineRegio stands ready to provide further evidence, analysis, and dialogue. Summary of main points: (A) We find that the current framework under Article 54 is functioning effectively. It provides legal certainty for granting authorities and beneficiaries, and it has enabled stable practices across Member States and regions. In times of uncertainty, maintaining regulatory stability is crucial. We therefore strongly recommend that no substantive changes be made to Article 54 without a direct consultation with the film agencies and industry stakeholders. Any modification risks introducing legal uncertainty into a sector that is already vulnerable due to structural market failure. (B) Public support to culturally significant games is today possible through notification procedures. In line with the Commissions own strategy encouraging Member States to strengthen support for the games sector, it is foreseeable that new national and regional funding schemes will emerge. To ensure coherence, we recommend that the Commission: I. Carefully assess whether support for games could be integrated into GBER; II. Take into consideration the Creative Europe MEDIA Programme and the EUs cultural policy objectives; and III. Consider whether inclusion should occur within Article 54 or through a separate dedicated article, to avoid undermining the stability of film and audiovisual support. (C) Article 9 - Transparency threshold: reduction of the reporting threshold from EUR 500.000 to EUR 100.000 has imposed a disproportionate administrative burden. In practice, the number of aid awards requiring entry into the Transparency Award Module (TAM) has multiplied, with each award often having to be entered manually. We note that: I. Market distortions are highly unlikely at the level of EUR 100.000, and even EUR 500.000, given the cultural nature of the sector; II. The administrative burden risks diverting resources from cultural policy objectives; III. There is no equivalent reporting system in third countries, creating an uneven playing field for European producers. We therefore respectfully propose that the Commission: Reinstate the EUR 500.000 threshold for audiovisual works under Article 54, or, Alternatively, consider a tailored transparency regime for cultural aid, recognising that such aid is by definition justified by market failure and public interest objectives. We thank the European Commission, Member States, and regional governments for their continuous support to the European film and audiovisual sector. Further details in the attached pdf.
Read full responseResponse to Evaluation of the Geo-blocking Regulation
11 Mar 2025
CineRegio AISBL is the European network of 52 regional film & av funds (incl. autonomous regions and communities). CineRegio continues to advocate for the continued exclusion of audiovisual services from Regulation (EU) 2018/302 (the Geo-blocking Regulation) which was adopted in February 2018 to ensure better access conditions to goods and services for individuals and businesses. The Regulation does not apply to several services sectors, one of them is audiovisual services. CineRegio members support and invest in a large number of the European films and tv-series made in Europe, and which are enjoyed by Europes citizens at local, regional and national level and in a variety of languages. The titles supported reflects our societies, promoting values of democracy, diversity and social cohesion and most of these titles would not be made (read: financed) without the current geo-blocking exception. Challenging this principle would be a serious political, economic, and cultural mistake. CineRegio is a strong advocate of a Europe where Cultural Diversity is considered an opportunity and a driving force for growth, employment and creativity, - a creative eco-system that should be celebrated and defended. In our view removing geo-blocking will destabilize the European independent film production ecosystem. Without the geo-blocking exception for the audiovisual sector the European co-production and distribution funding model will collapse. Bottom line is that we stand at a crossroad where the European legislators will have to choose between cultural diversity - as agreed upon via the UNESCO Convention on the Protection and Promotion of the Diversity of Cultural Expressions (ratified by the EU - but not the US) - or achieving a Digital Single Market for film and audiovisual works. What we must understand is that we cannot have both (for now).
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