Independent Music Publishers International Forum
IMPF
IMPF is the Global Trade Body for Independent Music Publishers.
ID: 532322794162-63
Lobbying Activity
Response to Update of EU rules on audiovisual media services
19 Dec 2025
IMPF is the global trade and advocacy body for independent music publishers, representing more than 300 companies worldwide. Our members are deeply rooted in local cultural and economic ecosystems, investing in songwriters and composers, supporting cultural diversity, and enabling repertoire to reach audiences across borders. Independent music publishers collectively account for over 26% of the global music publishing market, generating more than 2.7 billion in annual revenues, with sustained growth over recent years. This growth is underpinned by a functioning copyright framework that enables investment, risk-taking, and long-term cultural development. IMPF welcomes the European Commissions decision to launch an evaluation and review of the Audiovisual Media Services Directive (AVMSD). Since the last revision of the AVMSD in 2018, market realities have evolved significantly. Convergence between audiovisual, music, social media and platform-based services has accelerated, while algorithmic recommendation systems, cross-border streaming services and AI-driven content moderation increasingly shape what European audiences see and hear. These developments directly affect music creators and publishers, whose works are widely used, monetised and promoted across audiovisual, user-generated and platform environments. IMPF therefore submits this contribution to ensure that music publishing interests and the position of songwriters and composers, they represent, are fully considered in the evaluation and future review of the AVMSD. From the perspective of independent music publishers and the songwriters they represent, IMPF urges the Commission to ensure that the AVMSD review: 1. Recognises media convergence and the central role of music within audiovisual and platform-based ecosystems; 2. Addresses the regulatory gap affecting music streaming and content platforms, particularly regarding discoverability and algorithmic governance; 3. Extends prominence, transparency and reporting principles to European musical works where platforms function as de facto media gatekeepers.
Read full response20 Nov 2025
In September, IMPF along with organisations from the Music Sector published a joint call for a comprehensive EU music strategy backed by an ambitious budget. In this joint call, We welcome the European Commissions proposal to establish AgoraEU, recognising its potential to strengthen Europes cultural ecosystem. We stress that the proposed 1.796 billion allocation to the Creative Europe Culture strand, representing 21% of AgoraEU, is a positive step forward, but must be treated as a baseline, not a ceiling. We highlight that this increased budget presents a unique opportunity to design a music sector specific approach, building on existing evidence, momentum, and political will. We emphasise that AgoraEU must deliver more than funding, it must provide a coherent policy framework that reflects musics economic, social, and cultural significance. This requires: Dedicated calls and programmes tailored to the music sectors needs A European Music Observatory to underpin evidence-based policymaking Ethical and fair principles guiding digital transformation and AI adoption You can find the full joint call here https://www.impforum.org/wp-content/uploads/2025/09/Call-for-a-comprehensive-policy-strategy-and-an-ambitious-budget-for-Europes-music-sector-within-Agora-EU.pdf
Read full responseResponse to Apply AI Strategy
3 Jun 2025
Music has entered a new era with AI, which will have a transformative impact on many levels. Whilst it can enhance royalty management and offer creative tools, GenAI also poses unprecedented challenges. IMPF welcomes that the European Commission envisages a separate AI strategy for the cultural and creative sector, which aims to ensure AI enables and reinforces human creativity rather than replace humans, and that it contributes to safeguarding European cultural and linguistic diversity. However, culture should not only be discussed in isolation but should be positioned as a cross-cutting priority in EU policies. The importance of culture as well as the cultural and creative sector and its contribution to Europes economic growth and job creation must have a place in all relevant policy discussions. The European Commission must therefore ensure close cooperation with European creators and stakeholders representing the cultural and creative sector at the outset and across the different initiatives including the Apply AI and the Data Union Strategy. IMPF welcomes continued dialogue with the European Commission. IMPF is concerned that the Commissions focus on innovation, investment and potential productivity gains is over-looking the concerns of the cultural and creative sector today and will not be sufficient to ensure sustainable AI adoption in Europe. AI innovation and copyright protection are however not opposing forces but can - and must - reinforce each other in support of the development of a competitive, ethical , and human-focused AI ecosystem in Europe. GenAI models depend on massive datasets, often sourced by scraping copyrighted materials such as lyrics, compositions, and recordings. These models are trained without permission, payment, or even disclosure, effectively by-passing the foundational mechanisms that enable the cultural and creative sector, including music publishers and the songwriters and composers they represent, to function. AI developers frequently claim it is impractical to license content at scale. Yet, they have entered into licensing deals when pressured, demonstrating that where there is a will, there is a way. Assertions that individual works contribute negligible value to AI models also collapse under scrutiny. Just as every musician in an orchestra matters, every work in a dataset contributes to the models overall utility, particularly in fine-tuning and retrieval-augmented generation stages. In the AI Continent Action Plan, the Commission correctly highlights the importance for the EU to maintain its own distinctive approach to AI by capitalising on its strengths and what it does best and ensuring AI is trustworthy and aligned with EU values. IMPF calls on the EU to continue leading in setting global norms for ethical, human centric and rights-respecting AI. This must be paired with robust transparency obligations, including detailed disclosure of training data sources and processes. A transparency-first, license-based approach will ensure AI's success is built on respect for human creativity, not its exploitation.
Read full responseResponse to A Culture Compass for Europe
12 May 2025
IMPF, the global trade for independent music publishers, welcomes the Commission's consultation on the Culture Compass. Independent music publishing continues to assert its critical role within the global music industry, showcasing steady growth and cultural significance, as important partners, key agents of cultural diversity and custodians of songs. Independent publishers captured a 26.3% global market share in 2023. The global value of independent music publishing reached 2.57 billion in 2023, representing a 5.7% year-over-year growth. This marks an impressive 105.6% increase since 2018. This continued growth demonstrates the value independent music publishing delivers on both a local and international level supported by a healthy copyright framework, the cornerstone of innovation. It empowers songwriters, composers, and lyricists to take risks and experiment, knowing their work is protected and their efforts will be rewarded. Copyright transforms ideas into investments. Cultural Integration in Policy-Making: Culture should be positioned as a cross-cutting priority in EU policies. The importance of culture but also the cultural and creative sector and their role in economic growth and job creation must have a place in policy discussions. Investing in Cultural Sectors: The Creative Europe Programme is affording smaller publishers the opportunity to run camps, have B2B exchanges across borders and work with like minded orgs - such as ECSA, EMEE, and others and has been game changing in terms of strengthening the sector. The EUs next long-term budget should maintain a standalone culture funding stream, the Creative Europe programme. AI and Copyright: Music has entered a new era with AI, which will have a transformative impact on many levels. Whilst it can enhance royalty management and offer creative tools, GenAI also poses unprecedented challenges. We have to be clear that this is a different kind of disruption and therefore effective guardrails that empower rather than replace songwriters and composers will be essential. The European Commission has to ensure the effective implementation of the EU acquis and in particular the EU AI Act and the Copyright Directive. Weakening copyright will not make Europe more competitiveit will benefit foreign tech giants while harming local creators and publishers. A transparency-first, license-based approach will ensure AI's success is built on respect for human creativity, not its exploitation. Sustainable music eco-system: The music business is the business of songs. Yet, the remuneration of publishers, songwriters and composers does not reflect the full contribution of songs to the music ecosystem. Streaming has further accelerated this gap and independent music publishers call for a better balance in the allocation of royalties between recording and publishing in the digital world. ensuring that the value of the song and its creator is fully recognised and remunerated fairly. In order to achieve this, collaboration between record labels, music publishers, and creators is essential. To ensure a fairer streaming market that values and compensates all creators, we must have a transparent and constructive dialogue. Cultural Diversity: Recent trends indicate a growing market concentration. Consolidation and acquisition of catalogues and publishing companies has reduced the market share of independent music companies. This is of concern because independent publishers serve a key role in the music eco-system. The reduction of the number of companies and catalogues available, and the new levels of investment in catalogue acquisition, closes independent routes to the music market, and has a negative impact on cultural diversity. The level of concentration we are now seeing has become an issue which should be addressed. Encourage Data Collection and Research to inform policy decisions with accurate data. IMPF has long called for and raised the need for a Music Observatory.
Read full responseResponse to Establishment of the scientific panel of independent experts under the AI Act – implementing regulation
15 Nov 2024
IMPF, the global trade and advocacy body for independent music publishers, welcomes technological developments, in as far as they improve our business and the capacity to assist the writers we represent. We however are concerned with the considerable impact generative AI poses to the creative industry, including indie music publishers and their songwriters. In fostering the development of responsible and sustainable AI, the implementation and application of the EU AI Act is crucial to address malpractices such as the ingestion of unauthorised copyrighted content at scale, and ensure accountability in the AI industry. Whilst it is positive that the European Commission recognises the importance of including experts in the field of fundamental rights, this covers indeed several different specialisms. Considering the high risk generative AI poses to the creative industry, IMPF strongly recommends that the scientific panel includes experts who have deep expertise in copyright law as well as the impact of generative AI on the cultural and creative ecosystem. This should also be expressly noted in the implementing regulation subject to this consultation.
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