PROG Producers of Germany
PROG
Der Produzent*innenverband ist ein kreatives, wirtschaftliches und innovatives Netzwerk.
ID: 183025496842-52
Lobbying Activity
Response to Update of EU rules on audiovisual media services
21 Dec 2025
PRELIMINARY POSITION - NO NEED TO REVISE THE AVMS DIRECTIVE INTRODUCTION PROG Producers of Germany represents more than 150 independent and arthouse producers. We are an ecosystem composed of flexible SMEs that are the most efficient tool for diversity and artistic boldness. Our members´ films regularly win prizes at majour film festivals like Berlinale, Cannes, Venice or else where in the world. Works of our members are regularly nominated for the International Oscars. They make European stories travel and visible worldwide. Within the current political context, it is essential that measures are taken at EU level to actively promote cultural diversity. Any potential revision of the AVMS directive should focus on cultural policy objectives and be carried out through a directive. This would allow and encourage each Member State to adopt and develop tailored national cultural policies while ensuring that independent producers maintain their exploitation and ownership rights over the works they create and produce. EVALUATION PROG´s focuses on Art. 13-18 of the AVMS directive. These provisions strike a fair balance between broadcasting freedom and cultural diversity by supporting European independent production. The Art. 13-18 are future proof. However, there is much room for improvement regarding the control of the compliance of broadcasters and streamers. The Statute of the German Media Authorities on European Works (Satzung zu europäischen Produktionen gemäß § 77 Medienstaatsvertrag) provides sanctions in case of non-compliance. So far, we have never seen any sanctions although quotas are not always fulfilled. PRELIMINARY POSITION OF PROG: NO NEED TO REVISE THE AVMS DIRECTIVE PROG supports the Commission objectives to grant adequate visibility and awareness of European media to grant competitiveness between traditional and new digital players when it comes to advertising to adequatly protect viewers, particularly younger ones, when watching audiovisual content online. PROG does not see any need to open the directive at this stage. Especially, we do not see any necessity to change Articles 13, 16 18 as they leave enough room for manouvre for Member States to adapt the rules to their national needs. However, there is a need to control the compliance of broadcasters and streamers with these provisions more effectively. In the case that the AVMS directive is revised and Articles 13 to 17 are under revision, PROG would recommend that The definition of EU works must be independent from the CoE Convention A work should not be qualified as EU if the producer does not own the rights on the work produced along with the exploitation rights. The prominence rules of articles 13.1 should be dealt with guidelines through the Board. A more effecitve regime to control the application of Art. 13, 15-17 is granted and sanctions for non-compliance are provided. The control mechanisms must be improved and become more effective. The producers should have access to the comsumption data of their works on audiovisual media services. PROG is member of the umbrella organisation Spitzenorganisation der Filmwirtschaft (SPIO). We fully endorse the SPIO position - attached. Berlin, 19.12.2025
Read full responseMeeting with Thomas Schmitz (Cabinet of Executive Vice-President Henna Virkkunen) and EUROCINEMA, Association de producteurs de cinéma et de télévision and Unknown Organization
3 Dec 2025 · Audiovisual