EUROPEAN PRODUCERS CLUB

The European Producers Club (EPC) is an association of 185 influential independent film and TV drama producers from all over Europe.

Lobbying Activity

Response to State aid rules for public service broadcasting - Evaluation

14 Jan 2026

The Broadcasting Communication of 2009 clarified the complex application of State aid rules for Public Service Media funding. It acknowledges the competence of the Member States to define and finance the remit in full transparency. EPC believes that the Broadcasting Communication is still fit for purpose. Provisions are clear and simple enough, offering the necessary flexibility. They dont need to be reviewed. Regulatory status quo should prevail in the more competitive context dominated by non-European online platforms. PSM are central to the financing of European independent productions and the diversity of expression, artistic freedom and competitiveness which PSM working in partnership with independent producers brings. If a targeted update of the text is envisaged, EPC calls on the European Commission to ensure that the PSM ability to contribute flexibly to the EU's democratic, social and cultural objectives will be preserved and reinforced. Simplification of the text should not be to the detriment of the clarity of its provisions, in order to guarantee effective implementation. It would be crucial in particular to continue the implementation of Article 92 of the Communication which provides that PSM should respect the principle of proportionality also with regard to the acquisition of premium rights, and to provide rules for the sub-licensing of unused exclusive premium rights.
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Response to Update of EU rules on audiovisual media services

20 Dec 2025

Please find the EPC contribution attached.
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Meeting with Thomas Schmitz (Cabinet of Executive Vice-President Henna Virkkunen)

25 Nov 2025 · Audiovisual

Response to EU’s next long-term budget (MFF) – EU funding for cross-border education, training and solidarity, youth, media, culture, and creative sectors, values, and civil society

24 Nov 2025

The European Producers Club (EPC) welcomes the AgoraEU proposal and the European Commission willingness to reinforce EU funding to the cultural and creative sectors. In this context, EPC would like to make sure that the MEDIA programme, a success story for 35 years with its specificity and own identity (incl logo) is preserved and reinforced. The MEDIA programme has been indeed instrumental to support the audiovisual and cinema value chain in different areas: coproductions, trainings, markets, festivals, cinemas as well as the circulation of European works (distribution and international sales). Looking in details at the MFF and AgoraEU proposals, we lack clarity and certainty as to the possibility to pursue this impactful initiative with sufficient transparency and predictability. We are concerned to see MEDIA merged with news media funding, that is serving different objectives and beneficiaries of a different nature. While it is proposed that the Culture strand of Creative Europe gets its own specific chapter with a proposed budget increase of 115%, there is no dedicated budget proposed for the support to the audiovisual and film sector. We call on the European institutions to ensure a clear earmarked budget for the MEDIA programme (for the film and audiovisual sector) to avoid constant uncertainty on the allocation of funds. The reinforced financial support for independent and local journalism announced by the European Commission in the framework of the European Democracy Shield should be ensured by the new Media Resilience Programme, without impacting funding to the creative and cultural sectors. We ask to reintroduce the reference to independent producers in the Agora EU proposal (in the article 5 in particular). Independent producers, that are mainly SMEs, are at the heart of the three main AgoraEUs objectives: contributing to cultural diversity, competitiveness, and democracy (artistic and creative freedom, plurality of views..). Independent producers, they are not owned or controlled by an audiovisual media service provider, should remain at the core of the funding programme, as it is the case at national level. The AgoraEU proposal is missing critical precise information regarding the different sectors the programme aims to support that were detailed in an annex in the current Creative Europe regulation. These can either be introduced either in an annex or in article 5. We also observe that the drafting of the article 5 lacks precision and does not mention important keywords such as training, film distribution (in addition to the reference to independent producers). We observe that less emphasis on the notion of level playing field has disappeared. Measures aiming at a level playing field are critical in ensuring easy access to all countries of the EU, especially given the different production capacities. These provisions are key to promote cultural and linguistic diversity. The importance given to the video games industry appears disproportionate and AgoraEU should not be the main support of this large-scale industry. The complementarity with the Competitiveness Fund and Horizon should be better exploited. As regards transparency and accountability, the EPC calls to reinstate a clear decision-making process on the annual work programmes, involving Member States representatives (committee) and with input from all relevant stakeholders.
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Meeting with Henna Virkkunen (Executive Vice-President) and

4 Sept 2025 · Roundtable with representatives of the media industry

Meeting with Henna Virkkunen (Executive Vice-President) and

30 Jun 2025 · Exchange of views on the Creative Europe MEDIA Programme, EU audiovisual regulatory framework and recent market developments in the EU and overseas

Response to Apply AI Strategy

4 Jun 2025

The European Producers Club (EPC) is an association representing nearly 200 independent European producers from 36 countries, with strong expertise in international co-productions. We welcome the initiative for an AI Continent, which should: -Implement a protective and trustworthy framework for rights holders, enabling the audiovisual sector, including SMEs and VSEs, to fully seize the potential of AI technologies. -Insist on legal certainty through full compliance with copyright rules. -Ensure innovation is equitable and does not exclude the creative forces that form the backbone of Europes cultural identity. TRANSPARENCY, COPYRIGHT PROTECTION & FAIR REMUNERATION Transparency and copyright protection are inseparable pillars of a fair, innovative, and competitive AI ecosystem. Together, they form the foundation for a responsible digital future in Europe. AI systems must provide clear, meaningful and enforceable disclosures about how data, including copyrighted works, is used. This is vital for rights holders and audiences alike. For rights holders, this means: -Knowing if, how and to what extent their works were used to train or power AI systems -Easily and effectively exercising opt-out rights -Accessing standardised templates detailing data usage -Receiving clear information on the use of protected content without obstruction from vague claims of trade secrets Transparency is not only technically optional, it is legally essential. It empowers creators to license their works, enforce their rights, and prevent unlawful use. For audiences, it ensures clarity between human and AI-generated content, preserving trust in storytelling and democratic discourse. At the heart of transparency lies robust copyright protection and fair remuneration. European IP is a core asset of our creative economy. AI systems must be trained only on lawfully accessed content, respecting EU copyright frameworks. This includes: -Respecting opt-out rights of creators -Obtaining licenses and permissions before using copyrighted content -Guaranteeing fair remuneration when creative works are used to train or generate AI outputs Copyright protection is not a constraint on innovation: it drives sustainable and ethical progress. Compliance is not optional; it is a legal and economic necessity that upholds the integrity of Europes creative industries and enables a healthy AI licensing market. A future-ready AI Strategy must embrace both transparency and copyright protection, enabling responsible innovation while safeguarding the rights and value of European creators. TRUST & LEGAL CERTAINTY FOR A HEALTHY MARKET Trust is essential for any inclusive and functional AI ecosystem. Without clear rules and enforcement, rights holders are left to pursue litigation, creating friction that slows progress. To foster trust, the AI Strategy must: -Establish predictable legal frameworks for AI developers and rights holders -Promote structured collaboration between tech and creative sectors -Encourage a rules-based digital environment over conflict. Only with trust can innovation flourish, allowing creators to explore AIs potential without fear of exploitation or loss of control. ACCESSIBILITY AI holds vast potential for the audiovisual sector, from driving innovation to streamlining production and unlocking new creativity. But this potential must be accessible to all, not just dominant players. To ensure inclusivity, Europe must: -Implement policies supporting access to AI tools for small and independent producers -Support development of AI tailored to the audiovisual sector -Provide financial incentives for SMEs and VSEs to -explore and adopt AI technologies Widening AI access strengthens European cultural diversity and competitiveness. Conclusion: Protecting European IP is essential to securing digital sovereignty. In the long term, this will make Europes market more attractive, fair and globally competitive.
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Response to A Culture Compass for Europe

13 May 2025

The European Producers Club (EPC) is an association representing nearly 200 independent European producers from 35 countries, with strong expertise in international co-productions. We have closely followed all initiatives impacting the audiovisual sector, from regulations - such as the Audiovisual Media Services Directive, the AI Act and its Code of Practice, the geo-blocking regulation, and the Copyright Directive - to EU funding programmes like Creative Europe MEDIA and MediaInvest. The EPC welcomes the proposal to adopt a Culture Compass: a new strategic framework for culture in Europe. This initiative should explicitly include the film and audiovisual sector. It offers a valuable opportunity to align the promotion of cultural diversity and the key role audiovisual works play in shaping cultural identity and democratic values with the goals of economic competitiveness and innovation. We see 5 main priorities for the audiovisual sector as part of the Culture Compass. 1. A Culture Compass to promote cultural diversity in the audiovisual sector Films and audiovisual works are not mere commodities: they are cultural expressions that reflect, question, and shape society. The European audiovisual ecosystem -development, production, distribution, exhibition, and preservation - is both economically strategic and structurally fragile. It requires tailored treatment and strong, ambitious public policies at both national and EU levels, combining regulation and financial support. Amid increasing pressure from global platforms and recent US policy shifts, now is a crucial momentum to reaffirm Europes commitment to safeguarding cultural diversity and upholding the principle of cultural exception. Over 100 associations across the audiovisual sector have jointly called for a strong cultural policy at EU level. We must embrace the Culture Compass to compete by celebrating Europes cultural richness, resisting cultural homogenization, and positioning the Culture Compass alongside the Competitive Compass. 2. A Culture Compass open to the world The Culture Compass must also extend to third countries. Strengthening the external dimension of EU cultural initiatives is essential. Countries in Asia, Africa, South America, and Australia are inspired by EU audiovisual policy, and audiences there are eager for more European films. We should support their distributors, cinemas, broadcasters, and platforms in showcasing European works. At the same time, we should foster artistic collaboration and international co-productions that deepen creative and cultural exchange. 3. A Culture Compass grounded in values: artistic freedom and pluralism The Culture Compass must safeguard core values such as pluralism, artistic freedom, and cultural diversity. In todays AI race, it is critical to ensure transparency in access to viewing data. This prevents dominant global platforms from becoming unaccountable black boxes ruled by opaque algorithms. Pluralism and transparency are essential pillars of a democratic media ecosystem. 4. Addressing the impact of generative AI While generative AI presents opportunities for the audiovisual sector, it also raises significant risks. Clear regulations are needed to ensure it supports human creativity and respects copyright. The Culture Compass must address issues of transparency, consent, and fair remuneration, for both the use of creators works and the use of AI in creative processes. It must promote policies that defend human creativity and uphold authors' rights in the face of rapid technological change. 5.Promoting inclusion, gender equality, and sustainability The Culture Compass must ensure that diversity and sustainability are actively promoted. This includes advancing gender equality, inclusion of underrepresented groups, and environmentally responsible practices. These measures are fundamental to building social cohesion, bringing people together and supporting a vibrant, resilient democracy.
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Response to Evaluation of the Geo-blocking Regulation

10 Mar 2025

EPC urges the European Commission to maintain the current regulatory status quo and uphold the Geo-blocking exception for the audiovisual sector. It is not a plea to restrict access to European content, but a vital necessity to ensure the continued creation, financing, and distribution of European audiovisual works. Removing geo-blocking would not benefit European citizens in the long run and would significantly harm the European audiovisual value chain, leading to less investment in new creative works, reduced cultural diversity, fewer distribution channels and higher prices for the citizens. Territorial exclusivities, enabled by geo-blocking, are the heart of the financing and distribution models for European audiovisual works, as illustrated by FLOW, the Oscar-winning animated feature, which could not have existed or being such success without geo-blocking (see annex). Dismantling it by including audiovisual services within the scope of the Geo-blocking Regulation would have severe, irreversible consequences: -Jeopardizing the financing of European films and TV series. Unlike major US studios, our producers rely heavily on pre-financing from various sources, including AVMS providers (TV channels, online services), public funders, and other investors (sales agents, distributors). These financiers demand exclusivity within specific geographical areas for a defined period as a condition of investment, allowing them to mitigate risks and maximise returns. Without this assurance, the willingness to invest in risky cultural assets will drastically diminish, threatening the existence of numerous European productions. - Undermining effective distribution and promotion. Distributing films and TV dramas country by country allows for tailored strategies to optimise audience reach, selecting the right release moments, platforms and targeted marketing campaigns. Local distributors, whose business models rely on territorial exclusivity, are crucial in this process. If content were universally available online without territorial boundaries, there would be little incentive for these distributors to invest in the promotion, leading to reduced visibility and ultimately less access for audiences. - Negative effect on all European and national public support policies. The importance of territorial licensing is acknowledged in all European funding programmes for cinema and audiovisual (Creative Europe, Eurimages, Ibermedia and national support schemes). They all are intrinsically based on territorial exclusivity as a pillar of the European financing and distribution model for films and series, to extract value from single territories (whether needed as a prefinancing funding for making the films, or as a financial return for rightsholders for their investment). These programmes are all directed at improving/extending producers capability of building effective coproduction schemes, as well as improving distribution across Europe and worldwide. They are thus based on the assumption that unrestricted cross-border availability could disrupt national financing models rather than improve consumerss accessibility to works. Removing geo-blocking will endanger these instrumental programmes for the European audiovisual sector. - Negativ impact on cultural diversity. The strength of European audiovisual production lies in its diversity of stories, languages, and cultural backgrounds. The current system, underpinned by territorial exclusivity, supports this rich tapestry by allowing works to be financed and distributed in a way that caters to different linguistic and regional markets. Removing geo-blocking will push towards a homogenised offer, reducing the variety of content available to European citizens. The market will be concentrated in a few large companies that can afford production and distribution in dominant languages, leading to a loss of European audiovisual identity and diversity.
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