Fédération Internationale des Associations de Producteurs de Films Headquarters ASBL
FIAPF
FIAPF Headquarters asbl' s mandate is to represent the economic, legal and regulatory interests which film and audiovisual producers across the globe have in common.
ID: 332167817125-52
Lobbying Activity
25 Nov 2025
While FIAPF welcomes the Commissions proposal to include important policy objectives and sectors under the broader EU support programme AgoraEU, of which the proposed MEDIA+ Programme for the film/AV sector would form part, we do regret that the Commission has opted not to follow the clear and unanimous call by the Culture Ministers of the EU 27 Member States (January 2025) for a tailor-made EU funding programme in support of the European film and audiovisual sector. We consider a clear and guaranteed autonomous EU funding approach for the film/AV sector with an earmarked and ambitious budget as an essential instrument for protecting and promoting cultural and linguistic diversity, cultural heritage, creativity and private investment in new cinematographic and audiovisual works and distribution opportunities. We note that the European production sector has absorbed the cumulated inflation indexation since 2021 when the current Creative Europe MEDIA sub-programme started. We would therefore strongly urge the EU co-legislators to ensure that the future earmarked budget in support of the film and audiovisual sector at least compensates the 2021-2027 indexation. We stress the concerning distinct lack of business and legal clarity for stakeholders in the proposed Regulation, including as regards the proposed scope of future beneficiaries of development and production support schemes, the merging of cinematographic works with audiovisual works market segments which have specific and differing needs in terms of EU support. The absence of a detailed roadmap for budget, guaranteed future allocations to different segments and beneficiaries leaves key elements unsettled and unpredictable which , together with the absence of a Committee structure involving the Member States and the European Parliament, results in profound lack of legal certainty and budgetary predictability during the period 2028-2034. This is entirely unsuitable for the film and audiovisual sector where legal and business certainty is indispensable to the high-risk endeavor of developing, financing, producing, distributing and publishing cinematographic and audiovisual works across all distribution channels with lengthy development/financing efforts, often over several years, and where different types of funding and financing are interlinked and interdependent of each other. FIAPF calls for the reintroduction of the independent production company criteria set out in the current Creative Europe MEDIA Programme as a mandatory condition for support to development and production at large, including in support to low audiovisual capacity countries, and the reintroduction of the reference to cultural diversity as a joint and complementary policy objective alongside competitiveness. FIAPF also urges the EU co-legislators to reintroduce references to film consistent with 35 years of history of the MEDIA Programme, and the continuation of current support to sales agents, film distributors, cinema theaters and festivals. Future programme and funding support predictability should be ensured through the introduction of provisions providing a governance structure involving the representatives of the eligible MEDIA+ countries on the one hand, and the EU co-legislators on the other hand, as well as a robust framework for exchange between the European Commission and the film and audiovisual sector operators whose diversity is best represented through their European and international trade associations. Both governance elements are missing in the current draft Regulation. EU support to the film and audiovisual sector should be distinct, inclusive, stable and predictable. In the current geopolitical context, we firmly believe that this is more needed than ever both for the film and audiovisual sector itself, but also for audiences and citizens across Europe in the essential effort to uphold and defend common democratic values.
Read full responseResponse to Assessment of the effects of the Recommendation on combating online piracy of sports and other live events
28 May 2025
The Fédération Internationale des Associations de Producteurs de Films Headquarters ASBL (FIAPF below transparency register n°332167817125-52) comprises 37 national associations representing producers of films and audiovisual content from 30 countries across the globe, including 16 national associations in the EU/EEA. FIAPF members' constituencies are involved in the development, production, marketing and in some cases distribution, of all types of films and/or other types of audiovisual productions, ranging from feature-length films, short films, documentaries, television drama and other audiovisual content. We welcome this opportunity to provide input on the 2023 Commission Recommendation on combating online piracy of sports and other live events as piracy, including of our memberships film and audiovisual works, remains a serious problem in the EU. Swift action is crucial to stopping or at least limiting the dissemination of infringing films and audiovisual works, and reduce the economic damage caused by piracy. In the case of live content, the economic value is almost entirely exhausted at the end of the live broadcast. Other content is time-sensitive, for example because of the stage of release through different distribution channels to final audiences, e.g. release of films and/or audiovisual works. As a consequence, for these types of content, a significant degree of value is eroded in a very short time frame. The unauthorised dissemination of such content during that particular time frame therefore causes additional and significant damage to a wide range of rightsholders and ultimately to consumers as well as society as whole. While the current EU framework offers a range of enforcement tools, including dynamic injunctions, there is a continued need for ensuring their effective implementation across all EU Member States, including by way of effective and flexible injunctions, automated and effective site-blocking mechanisms that can be updated in real time, effective cooperation between all stakeholders, including ISPs, effective right of information and KYBC obligations, and effective stay-down obligations.
Read full responseResponse to A Culture Compass for Europe
13 May 2025
FIAPF (Fédération Internationale des Associations de Producteurs de Films Headquarters ASBL transparency register n° 332167817125-52) expresses appreciation for the opportunity given to share views on the Culture Compass. Films and other audiovisual scripted works are in the daily lives of many Europeans and a powerful driver of creativity in and from Europe. The film and audiovisual sector in Europe should therefore be a full part of the Culture Compass if it is to fulfil its objective of making the cultural and creative industries ecosystem in Europe more economically and environmentally sustainable. Likewise, inclusion of our sector is essential to any strategy to reinforce access to cultural works to all European citizens, including disadvantaged groups, youth and citizens in rural or remote areas. FIAPF invites the European Commission to add the continued maintenance of concrete cultural and linguistic diversity in Europe as a core component of its future EU Culture Compass. The protection of such diversity is embedded in the EU Lisbon Treaty and has supported and accelerated the development of an innovative, creative, business-oriented, deeply entrepreneurial film and audiovisual ecosystem to the benefit of the competitiveness of the European Union and its citizens social welfare. A culturally and linguistically diverse film and audiovisual sector in Europe is an essential requirement for guaranteeing that the EU Culture Compass will effectively contribute to the EU competitiveness objectives, but also to promote and ensure artistic and creative freedom, by incentivising creative and financial risk-taking, and ensure that all rightsholders, artists and all professionals in the film and audiovisual sector may make a living from their work. FIAPF wishes to express its full availability to be part of the stakeholders consultations as announced by the Commission background paper with a view to identify the sectoral needs and challenges. In this context we wish to share more detailed comments on two key aspects of direct relevance to the EU Culture Compass ie. AI and the European cultural and creative sector in the context of the current discussions on the EU AI Code of Practice and Transparency Template and the importance of securing effective and sector-tailored EU incentives for the European film and audiovisual sector with budgetary predictability in the future MFF. You will find these comments in the attached document.
Read full responseResponse to Evaluation of the Geo-blocking Regulation
10 Mar 2025
The Geoblocking Regulation prohibits unjustified geo-blocking and other forms of discrimination based on nationality, place of residence or place of establishment. At the time of adoption, the EU co-legislators specifically excluded film/AV services from the scope of the Regulation and the reasons for this exclusion remain valid today. There are no grounds for reviewing the exclusion from scope of film/AV services; in no way does the exclusion stand in the way of the Regulation meeting its objectives. Territorial exclusivity, supported by geoblocking, plays an indispensable role in securing funding for development, creation and production, as well as providing for the optimal marketing, distribution and exploitation of the finished film, TV and other audiovisual content across all distribution channels (theatrical, physical carriers, all forms of broadcasting and all forms of online distribution). A ban on the use of geoblocking to support territorial exclusivity for film and audiovisual content and services would severely jeopardize the creative and economic sustainability of the film and audiovisual sector in Europe. This would result in a drop in the number and range of films and audiovisual content produced, with a smaller variety of languages. Distribution and circulation would be drastically reduced across the EU. This would have a direct and negative impact on consumer welfare: significant reduction of choice in content, distribution, and access options as well as a surge in prices. The importance of territorial exclusivity for the European film and audiovisual sector is widely documented in case studies illustrating that up to 60% of financing is often raised through territorial exclusivity such as co-production arrangements between different countries and pre-sales of future distribution rights. Co-productions and pre-sales of future distribution rights offer win-win strategies to share financial risk in production, favour greater multi-territory incubation and increased circulation/distribution that in turn ensures local marketing and tailoring - ultimately driving content awareness and demand across territories. This has also been recognised by EU Member States in consecutive Council conclusions. Consecutive impact-assessments and independent economic analysis conclude that erosion of territorial exclusivity through a ban on the use of geo-blocking in the context of financing and distributing films and audiovisual content would erode the economic value of the rights concerned with a direct and negative impact on the financing and distribution opportunities as well as on recoupment of investments as well as on consumer welfare resulting in less choice in content, distribution, and access options as well as higher prices. The impact of including AV in the EU Geo-blocking Regulation, by Oxera, concludes that erosion of territorial exclusivity would have a significant short-term impact on industry and consumers, with up to 9.3bn of welfare lost per annumas well as medium- to long-term outcomes that would be worse than they are today (a welfare loss of up to 4.5bn per year. The EU markets enjoy a dynamic, diverse and rich offer of content, services and access options as documented in research by the European Audiovisual Observatory and by the European Parliaments Research Service. According to the EAO, on average, European consumers have access to more than 8,500 European films online, of which 82% (~7000) are produced in other European countries an exponential growth in content and services offered to consumers and a market development welcomed by the film and audiovisual sector in Europe.
Read full responseMeeting with Alina-Stefania Ujupan (Cabinet of Executive Vice-President Margrethe Vestager)
8 Dec 2020 · The impact of the current sanitary crisis on the audio-visual sector
Meeting with Agnieszka Skonieczna (Cabinet of Commissioner Thierry Breton) and Association of Commercial Television and Video on Demand Services in Europe and
24 Aug 2020 · Impact of COVID-19 and recovery measures for the media and audiovisual ecosystem
Response to Intellectual Property Action Plan
31 Jul 2020
FIAPF (FIAPF Headquarters - ID 332167817125-52)’s members are 34 film and TV producer organizations from 27 countries, including 15 in the EU/EEA. Their activities include the development and production of films and audiovisual content which are distributed offline and online via all forms of authorised and legal online distribution channels.
The film and audiovisual works produced by FIAPF's membership are among the copyrighted content most impacted by illegal activities online with resulting severe economic losses for our membership.
FIAPF therefore supports the IP Action Plan's policy objective of improving the EU IP framework and the way it is used in practice. We submit that the Commission's efforts in this respect should focus on recognising the need to strengthen enforcement against online piracy services and ensuring respect for exclusive rights and freedom of contract. This is essential in order to support the future growth and sustainability of creators and businesses in the film and audiovisual sector which forms an important part of Europe’s strategic economic ecosystems. Further detailed suggestions can be found in the complementary FIAPF 31 July 2020 Submission on the IP Action Plan Roadmap.
Read full responseResponse to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services
30 Jun 2020
FIAPF (International Federation of Film Producers Associations - FIAPF Headquarters - ID 332167817125-52)’s members are 34 film and TV producer organizations from 27 countries, including 15 in the EU/EEA. Their activities include the development and production of films and audiovisual content which are distributed offline and online via all forms of authorised and legal online distribution channels.
Film and audiovisual content are among the copyrighted content most impacted by illegal activities online. Illegal use of our members’ copyrighted content has been a driver for the take-up of the Internet and online services. Severe economic losses and major challenges to the recoupment of our members’ significant investment in development, production, marketing, and distribution of film and audiovisual content result from this form of illegal availability outside authorised and legal distribution channels. Our membership deploys the full range of tools available under EU and national legal instruments to defend and enforce their rights against unauthorised and illegal access to and use of their content.
We understand that the policy objective for the EU Digital Services Act is a modern legal framework for digital services, respecting Union rights and values and protecting fundamental rights which include protection of intellectual property and the right to private property. We consider it key in this regard to ensure that the legislative path for the DSA does not lead to broader safe harbours/liability privileges and/or erosion of responsibilities/potential liabilities for digital services. In this context, the key DSA objectives from our perspective are:
• Address identified problems through tailored solutions/a “per-problem” approach. Rather than a broad review and horizontal harmonisation of the EU liability framework, a targeted approach should be preferred with the creation of new tailored obligations for service providers complementing the existing legal framework provided by the EU E-Commerce Directive. These should include “know your business customer” provisions for digital services to give a real, tangible, complementary solution to Art. 5 ECD, with minimal burdens on legitimate businesses. Elements such as stay-down procedures, repeat offenders, and trusted flaggers, could helpfully be addressed as well, though avoiding a “one-size-fits-all” approach in order to build in considerations for different types of content and illegal activities.
• Preserve the key principles of the ECD, including the country of origin regulatory principle and specific limitations on potential liability as clarified and updated with case law from the European Court of Justice (e.g., “active/passive” distinction). It is imperative not to erode existing EU law that defines the boundaries of Art. 12-15 ECD (such as Recital 42 of the ECD and the relevant CJEU case law).
• Pursue the stated policy goal of “upgrading” liabilities and responsibilities through “more stringent” rules. We urge the Commission to dismiss stakeholder efforts to seek broad new liability privileges and any assertion that such broad liability privileges are somehow necessary “to remove disincentives for voluntary actions to address illegal content”.
• Clarify access to WHOIS data through the DSA legislative process. Access to WHOIS data is essential in combating illegal and harmful content online. Misinterpretations that have unnecessarily hampered access to Internet domain registration data should be redressed and the DSA should confirm the need for access to WHOIS data as necessary for the public interest.
In conclusion, FIAPF and its members consider the DSA an opportunity for the EU to address the rules for responsibility online in full respect of Union rights and values and protecting fundamental rights.
Read full responseMeeting with Stig Joergen Gren (Cabinet of Vice-President Andrus Ansip) and Association of Commercial Television and Video on Demand Services in Europe and European Audiovisual Production Association
27 Apr 2018 · CabSat Regulation
Meeting with Manuel Mateo Goyet (Cabinet of Commissioner Mariya Gabriel)
11 Oct 2017 · Copyright
Meeting with Günther Oettinger (Commissioner) and IFPI Representing recording industry worldwide and
8 Jul 2016 · Value gap
Meeting with Maximilian Strotmann (Cabinet of Vice-President Andrus Ansip), Stig Joergen Gren (Cabinet of Vice-President Andrus Ansip) and
27 Jun 2016 · Copyright, cross-border access
Meeting with Andrus Ansip (Vice-President) and
9 Feb 2016 · Copyright, cross border access to online content, AVMSD