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Rakuten Group, Inc

Rakuten Group’s mission is to contribute to society by creating value through innovation and entrepreneurship.

Lobbying Activity

Response to Update of EU rules on audiovisual media services

21 Dec 2025

Rakuten TV Europe, SLU (hereinafter "Rakuten TV"), a Spanish subsidiary of Rakuten Group, Inc., which is headquartered in Tokyo, is a major Pan-European Video-on-Demand (VOD) platform headquartered in Spain. Operating across up to 43 countries, we provide European audiences with access to diverse content through a unique hybrid ecosystem combining Transactional VOD (TVOD), Advertising-based VOD (AVOD), and Free Ad-supported Streaming TV (FAST). In response to this Call for Evidence, Rakuten TV proposes four key pillars to restore the Audiovisual Single Market and enhance European competitiveness: 1. Simplification and Harmonization: We support maintaining the "Directive" instrument but urge the strict harmonization of key definitions at the EU level to eliminate the excessive administrative burden caused by the fragmentation across 27 Member States. 2. Adaptation to Diverse Business Models: The "one-size-fits-all" approach based on SVOD for VOD and traditional linear TV channels must be revised. We call for a fair application based on the principle of proportionality for models with different revenue structures, such as AVOD, TVOD and FAST, with a re-evaluation of the current existing definition of Audiovisual Media Service to adapt the emerging formats in a technology-neutral approach. 3. Level Playing Field: Video-Sharing Platforms (VSPs) and other media services such as influencers or audio/video podcasts must be subject to strict protection standards equivalent to those of Media Service Providers (MSPs) to ensure a safe environment and fair competition. 4. Innovation and Commercial Freedom: We caution against excessive intervention in the name of "Prominence" for Services of General Interest (SIG) in some countries that restricts commercial partnerships on hardware and limits user choice.
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