Lobbying by International Federation of Reproduction Rights Organisations

International Federation of Reproduction Rights Organisations

IFRRO

IFRRO, the International Federation Reproduction Rights Organisations (RROs), is an independent body which promotes efficient Collective Management of rights through RROs, works to increase the lawful use and to eliminate the unauthorised use of copyright works, and provides various opportunities and proactive support for rightholder on a European as well as international level.

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ID: 860729437196-92

Lobbying Activity

Meeting with Henna Virkkunen (Executive Vice-President) and

19 Jan 2026 · Exchange of views on currently relevant topics in the field of copyright

Response to Digital package – digital omnibus

13 Oct 2025

IFRRO is an independent, non-profit membership association with over 160 members across over 90 countries, including more than 70 members from the European Union. We facilitate the collective management of reproduction and other rights in text and image-based works through the cooperation of our member Reproduction Rights Organisations (RROs). IFRRO members represent millions of authors, visual artists, and publishers whose works are frequently used, often unlawfully, for the training of generative AI models. We welcome the opportunity provided by the European Commission to comment on the Simplification-digital package and omnibus consultation. The European Union has established a comprehensive, complementary and ambitious framework regulating the digital environment. While most of these regulatory instruments have been adopted only recently and their application in practice remains to be fully tested, the framework already reflects a differentiated approach that recognises the varying capacities of market participants. In particular, SMEs and start-ups benefit from proportionate obligations, which in several cases are notably generous. Larger companies, equipped with greater resources, therefore bear enhanced responsibilities to ensure full compliance with the EUs digital regulatory standards, as is appropriate. In relation to the AI Act, the European Commission must safeguard the continued relevance and effectiveness of the Unions copyright acquis, insofar as it intersects with the AI regulatory framework. The proper and consistent application of the AI Act must not undermine the operation of Article 53(1)(c) and (d) and under no circumstances should a greater flexibility in applying these rules be proposed. The copyright policy that GPAI model providers are required to put in place and implement, together with the transparency obligations set out in these provisions, play a key role in enabling rightsholders to effectively exercise and enforce their copyright in connection with the development and training of GPAI. With regard to the more specific obligation for GPAI model providers to identify and comply with the reservation of rights expressed pursuant to Article 4(3) of Directive (EU) 2019/790, it is important to stress that the Text and Data Mining (TDM) exception is not a free pass to use protected works. Where rights have been reserved, explicit permission remains necessary. Several studies have indicated that TDM does not extend to AI training processes, which go beyond the scope of the exception. The CJEU has been called upon to clarify this crucial issue. Until such guidance is provided, AI developers cannot rely on the TDM exception as a lawful basis for activities such as training, fine-tuning, or grounding, but they should ask for authorisation and licenses from the relevant authors and rightholders which will allow them to use these protected works. As the Commission seeks to achieve optimal implementation of the AI Act, the Digital Package on Simplification process presents an opportunity to revisit and refine the AI Act implementation package adopted in July, featuring the GPAI Code of Practice, the template of the training data and the GPAI guidelines, which represented a missed opportunity to provide meaningful protection of intellectual property rights in the context of generative AI and fell short of the EU AI Acts own objectives. The Commission should revisit the GPAI Code of Practice, the template for the summary of training content, and the GPAI guidelines to ensure effective enforcement of AI Act's Article 53 and strengthen these instruments in a way that enhances legal certainty for all stakeholders while ensuring that the EUs AI and digital frameworks remain coherent, innovation-friendly, and firmly respectful of intellectual property rights, in light of the relevant input submitted by the cultural and creative sector during the discussion of these instruments, which was highly disregarded.

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Meeting with Nela Riehl (Member of the European Parliament, Committee chair) and Society of Audiovisual Authors and

3 Sept 2025 · Stakeholder Roundtable on Creators & Performers

Response to European Data Union Strategy

17 Jul 2025

Please find our feedback enclosed in the attached document.

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Meeting with Emmanuelle Du Chalard (Head of Unit Communications Networks, Content and Technology)

26 Jun 2025 · Exchange of views on the GPAI Code of Practice, the template for the summary of training content, and licensing practices.

Meeting with Desislava Dimitrova (Cabinet of Commissioner Glenn Micallef)

2 Jun 2025 · Introductory meeting

Meeting with Emmanuelle Du Chalard (Head of Unit Communications Networks, Content and Technology)

20 May 2025 · Copyright and artificial intelligence

Response to A Culture Compass for Europe

9 May 2025

IFRRO is an independent, non-profit membership association with over 161 members from around 90 countries. We facilitate the collective management of reproduction and other rights in text and image-based works through the cooperation of our member Reproduction Rights Organisations (RROs). IFRRO members represent millions of authors, visual artists, and publishers. Our comments will complement those of national and international stakeholder groups within our membership, who will also submit their own views and concerns. The European Cultural and Creative Sectors & Industries (CCSIS) are vital for innovation and technological progress, generating around 8 million jobs across the EU. Europe also hosts some of the world's leading cultural institutions, positioning it as a global hub for creativity and cultural excellence. Culture remains one of Europes most valuable assets and a key pillar of its economy. We welcome the Commission's consultation on Culture Compass and stress the importance of including the sector in all relevant initiatives. Transparent and inclusive dialogue with CCSIs is essential to ensure effective policymaking. Every EU policy should be measured by a test of its impact on culture. If such a test existed, it would require every DG to consider the consequences for the cultural sector when designing a law and involve DG EAC in the process. Copyright and IP are fundamental to encouraging creativity and innovation. They secure economic value for rightsholders (RHs), deter misuse, and incentivise continued investment in creative work. With the digital transformation and the rise of digital platforms, the use of protected workstext, music, and illustrationshas surged. Robust copyright frameworks support digital commerce and enable RHs to earn income while granting users access through clear and efficient licensing processes. Access to creative, scientific, and literary works is crucial for society. At the same time, for RHs, content such as books, newspapers, images and sheet music represents a key source of income. For users, straightforward and efficient rights clearance encourages legal access and payment of royalties. RROs play a crucial role in this balance, ensuring fair remuneration to RHs and ease of access for users. A pressing issue today is the continuous advancement of AI technologies operating unfairly in the marketplace and disregarding the rights of RHs. AI offers significant opportunities but also raises legal & ethical questions, especially regarding the use of copyrighted content for AI training. To uphold the goals of copyrightsupporting knowledge, culture and innovationAI policies must ensure strong protections for RHs. Since many AI systems rely on creative works, it's essential to strike a fair balance that supports both AI development and RHs. Key Principles -Protect RHs: AI policies must preserve the integrity of copyright and licensing frameworks. Undermining these could reduce the availability of creative and educational content, harming both RHs and society. -Base Changes on Evidence: Copyright law has successfully adapted to past technological shifts. Changes should be driven by clear evidence, not assumptionsespecially since there's no proven market failure that justifies weakening protections in the context of AI. -Support Licensing: Licensingboth individual and collectivehas long provided a fair mechanism for using copyrighted works. These systems are effective for large-scale uses such as AI training and should be respected and supported. -Ensure Balanced Policies: Copyright law is built on balancing the interests of RHs and users. AI policies must uphold this balance, particularly when considering exceptions and limitations. -Promote Education and Transparency: Effective copyright policy requires awareness of legal responsibilities and the societal value of copyright. Transparency is keyAI developers should disclose what copyrighted content is used and for what purposes.

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Meeting with Dimitris Tsiodras (Member of the European Parliament)

21 Mar 2025 · AI and intellectual property

Meeting with Thomas Schmitz (Cabinet of Executive Vice-President Henna Virkkunen)

24 Feb 2025 · AI and copyright

Response to Evaluation of “Marrakesh” Directive and Regulation

11 May 2023

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Meeting with Tomasz Frankowski (Member of the European Parliament, Rapporteur) and European Disability Forum and

21 Mar 2023 · The future of the European book sector-consultation meeting with stakeholders

Response to Data Act (including the review of the Directive 96/9/EC on the legal protection of databases)

13 May 2022

IFRRO, the International Federation of Reproduction Rights Organisations, is the international network of collective management organisations and creators’ and publishers’ associations in the text and image spheres, with over 150 members in 85 countries. Our members represent many millions of authors, visual artists, and publishers of books, journals, newspapers, magazines and printed music. IFRRO welcomes the opportunity to provide feedback and has the following preliminary remarks: - It is vital that copyright rules are not affected and are fully respected by the Data Act – this can be better clarified in the text While the Explanatory Statement states that the proposal “does not affect existing rules in the areas of intellectual property (except the application of the sui generis right of the Database Directive)…” (p.5), it is preferable – for legal certainty - that this is addressed in the legal text and that it is clear that copyright rules are not affected by the Act. We welcome that Recital 28 states that “…Any trade secrets or intellectual property rights should be respected in handling the data”. Concerns have been raised, for example, that data falling within the scope of data access rights could potentially encompass creative works such as e.g., photographs, with ‘data’ being defined as “any digital representation of acts, facts or information and any compilation of such acts, facts or information, including in the form of sound, visual or audio-visual recording”. It is important that the text is as clear as possible to ensure that copyright protected works remain fully protected. - Proper safeguards are essential to avoid that ‘obligations to make data available based on exceptional need’ unfairly prejudice rightholders In our response to the Commission’s 2021 consultation on the Data Act, IFRRO highlighted the risks of compulsory business-to-government data sharing, in particular that such a measure could potentially unfairly prejudice rightholders. We also emphasised the need for safeguards. We recognise that some important safeguards have been included in the proposed Data Act under Chapter V. It is essential that these safeguards are in no way weakened and that any amendments rather focus on ensuring that the safeguards in place are sufficiently robust, to ensure that rightholders will not be unfairly prejudiced. - Investments in databases must continue to be encouraged and protected We welcome that the proposal does not involve changes to the Database Directive Art. 7 concerning the sui generis right, while noting that Chapter X (Article 35) clarifies that the sui generis right “does not apply to data bases containing data obtained from or generated by the use of a product or related service”. We believe it would be more prudent, however, if “data bases containing data obtained from or generated by the use of a product or related service” were instead eligible for an exception (with accompanying safeguards), that would allow for the use of machine-generated data but without denying such databases any protection. This would avoid potentially negative consequences on the market, in particular as regards “mixed” databases. It is important that the sui generis right is not undermined, as it is vital to encourage and protect investments in databases in a world driven by the exploitation of such data. It importantly allows for the prevention of unauthorised extraction and / or reuse of all or substantial parts of the content of databases. Without the Database Directive, database authors / makers would risk being left with insufficient protection at national level and the database market in Europe would be put at risk. - Provisions on “international contexts non-personal data safeguards” (Chapter VII) must not unnecessarily further complicate international data transfers, adding to an already complex legal situation following the Schrems II judgment, in particular for SMEs.

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Response to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services

30 Mar 2021

IFRRO, the International Federation of Reproduction Rights Organisations, is the international network of collective management organisations operating in the field of text and image (known as Reproduction Rights Organisations, or RROs). IFRRO welcomes the DSA proposal and the recognition that online platforms have now acquired a reach into our daily life, economy and democracy that requires greater responsibilities and the need for updated rules for digital services. The DSA goes some way towards clarifying the current legal framework for digital service providers and creating obligations that will help create an environment that is less hostile for authors and publishers faced with widespread illegal uses of their works. We agree with the approach of building on the key principles of the e-Commerce Directive (2000/13/EC), which remain valid, and with the principle of “what is illegal offline is also illegal online”. The devil is, however, in the detail and there are problems that remain unaddressed. A particular concern is that there has been an increase in the levels of unauthorised sharing of text and image works via messaging services, but they do not fall within the DSA’s scope. If the DSA is to ultimately improve the current situation faced by authors and publishers, whose works have become even more vulnerable to piracy and unauthorised uses since the Covid-19 pandemic began, then we consider that certain aspects will need to be reviewed. We believe that, with some adjustments, the DSA can help make a difference in enabling a sustainable future for authors and publishers in the text and image sector by helping to address the spread of illegal content online, which has seriously impacted the growth of the sector. It is crucial that the DSA ensures that fight against piracy and unauthorised use of content becomes much easier and cheaper than it currently is. IFRRO’s (non-exhaustive) comments, set out in the position paper attached, are focused on the perspective of its RRO members, complementing the comments by national and international stakeholder groups of authors, visual artists and publishers within the IFRRO membership. Those stakeholders will make submissions highlighting their own concerns and perspectives. One area in which there is a divergence of views amongst the IFRRO membership is on the question of the impact of the proposed DSA on press freedom and how the text should be amended accordingly. For that reason, while the suggestions put forward in our position paper represent IFRRO’s view, following a consultation with its members, they do not reflect the view of all IFRRO members.

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Response to Intellectual Property Action Plan

14 Aug 2020

IFRRO welcomes the opportunity to provide feedback on the Commission’s Roadmap. The following is a summary of our comments on the five points put forward by the Commission in the Roadmap, with more details underpinning these comments in the paper attached. 1. “Upgrade the system for IP protection” We welcome that the Roadmap highlights the importance of the prompt implementation of the Copyright in the Digital Single Market Directive (2019/790). It is also crucial however that national implementation of the Directive is balanced and interpreted in line with the spirit of the text, which aims amongst other things to ensure a fairer environment for authors and publishers for uses of their works. We are particularly concerned that the way exceptions are implemented could potentially have a detrimental effect. It is vital that the “three-step test” is fully respected. 2. “Promote a better uptake and deployment of IP” The proposal to provide support to mitigate the impact of the Covid-19 crisis is welcome. The Roadmap refers to helping “all SMEs, researchers, innovators etc. have access to information and advice on IP”. It is important that authors and publishers (most of which are SMEs or smaller) have access to such advice, including on copyright, so they are more aware of their rights and how to protect and enforce them. 3. “Promote better licensing and sharing of IP-protected assets” We welcome that the Roadmap promotes “better licensing” including e.g., promoting the “efficient use of high quality rights-management metadata in the copyright market”. We believe that “better licensing” is ultimately about making it even easier for users to copy / use works and at the same time ensuring that authors and publishers of those works are rewarded. This is vital if EU citizens want to continue to enjoy quality, innovative and culturally diverse content and also for the EU’s competitiveness and economy. 4. “Fight IP theft” It is positive that the Roadmap addresses the current unacceptable high level of piracy and counterfeiting, which is a major concern to those who create and publish works. In recent months, with economies closing down and people staying at home, the publishing sector has seen an increase in online piracy, with millions of copies of books, along with newspapers and magazines, being traded or made available across the world illegally, including in the EU. Robust enforcement of copyright rules is also essential when it comes to ensuring legal income streams via the collective management of rights. We hope that the new IP Action Plan will see the Commission being more pro-active in taking action against Member States that blatantly fail to implement IP legislation, sending a clear message that these rules are important and that there will be consequences for non-compliance. 5. Promote a global fair play We support the idea of promoting global fair play and harnessing the EU’s capacity to act as a global standard-setter in key areas such as IP. Stepping up technical co-operation and engagement in dialogues with the developing world is also important in contributing to high global standards and compliance with international treaties. It also helps ensure that authors and publishers around the world, including from EU Member States, have adequate legal protection and are able to enforce their rights. This builds confidence and inclusivity into the global IP system. It is equally important that there is respect for IP in all third countries, both developing and developed, that the EU is trading with and where EU companies are also operating. It must be clear to all these countries that non-application of IPR provisions in trade agreements is unacceptable. We believe that in its role as a global standard-setter, the EU should continue playing its important role at WIPO, supporting a balanced approach to copyright.

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