Sdružení pro internetový rozvoj
SPIR
SPIR is a professional association active in the field of internet advertising since 2000.
ID: 135859024229-13
Lobbying Activity
Response to Update of EU rules on audiovisual media services
19 Dec 2025
SPIR (Association for Internet Progress) represents the most important Czech companies active in the digital industry and is a local certified self-regulatory body for AVMSD. As for the scope of the directive, our members provide local VoD services (TV broadcasters´ VoDs and video/interviews databases of press publishers) and local video-sharing platforms. As such, we recognise the importance of an effective and future-proof EU audiovisual regulatory framework. However, we strongly caution against reopening the Audiovisual Media Services Directive (AVMSD) at this stage and encourage the Commission to maintain the current framework for various reasons described below: AVMSD remains fit for purpose The AVMSD continues to provide a balanced, principles-based and technology-neutral framework that has proven adaptable to evolving media and market realities. Challenges observed in the audiovisual ecosystem are not the result of deficiencies in the Directive itself, but rather of fragmented implementation, uneven enforcement and limited practical guidance at national level. These issues can be addressed without legislative revision, through improved coordination, clarification and consistent application of existing rules. Such clarification might indeed be necessary to standardise the scope of how AVMSD applies to large influencers. Regulatory stability and legal certainty must be preserved A stable and predictable regulatory environment is essential for media pluralism, investment and innovation. Reopening the AVMSD would introduce uncertainty at a time when media actors are already adapting to significant new obligations under recently adopted legislation (EMFA, DSA, AIA, upcoming digital omnibus or DFA). Frequent or premature legislative changes risk undermining confidence in the EU regulatory framework and increasing compliance costs, particularly for press publishers whose audiovisual offerings are ancillary to core journalistic activities. Effective self- and co-regulatory approaches should be strengthened Experience across Member States demonstrates that self- and co-regulatory mechanisms deliver effective, flexible and proportionate outcomes, especially in fast-evolving digital environments. These approaches allow for tailored solutions, rapid adaptation and close involvement of regulators and market participants, without the rigidity of prescriptive legislation. Reopening the AVMSD risks weakening these proven systems by replacing them with inflexible rules that may quickly become outdated. The priority should be implementation, not new legislation The Commissions focus should be on improving enforcement consistency, providing clearer guidance and fostering cooperation between regulators and self-regulatory bodies. These measures would address the real challenges identified in the market without reopening the Directive. Maintaining the AVMSD as a stable, high-level framework is the most effective way to safeguard legal certainty, media diversity and innovation. For these reasons, we respectfully urge the Commission to refrain from reopening the AVMSD and instead prioritise effective implementation of the existing framework.
Read full responseResponse to Digital package – digital omnibus
14 Oct 2025
For over 20 years, the Association for Internet Progress (SPIR) represents the most important players of the Czech Internet economy from among media publishers, media agencies and technology companies with an annual turnover of more than 37 billion Czech crowns (1.5 billion EUR). The services offered by SPIR members are used by over 90% of the population of the Czech Republic. SPIR welcomes and fully supports the European Commission's initiative to simplify robust and complex EU legislation while maintaining the same level of protection for European consumers. In particular, we appreciate that one of the omnibus measures is dedicated to the digital sector, which has been subject to a large number of new regulations in recent years. Unfortunately, this has led to digital regulation becoming very complex, complicated, and particularly burdensome for smaller businesses. Simplifying this regulation while maintaining a reasonable level of consumer protection is therefore appropriate. However, we must point out that the excessive complexity of the legislation is not caused solely by the legislation itself, but also by the disproportionate extension of individual rules through soft law (including the European Commission's own guidelines) or CJEU case law. It is therefore sensible to review how these rules align with the dynamic digital environment and assess their effectiveness in protecting European citizens while minimising adverse effects on European businesses. In the following paragraphs, we would like to share our views on potential simplifications to the ePrivacy Directive, the AI Act and also the Digital Services Act. Please see the full argementation attached.
Read full responseResponse to A Culture Compass for Europe
29 May 2025
Free media are an essential part of Europe's cultural and democratic infrastructure. They serve not only as vehicles for information and public accountability, but also as cultural actors that reflect, shape and preserve the diversity of European societies. We therefore believe that ensuring the sustainability of the media is fundamental to the objectives of the Culture Compass. Therefore, we suggest including following 3 policy priorities into the Compass: 1) Safeguard existing revenue models of media; 2) Leveling the online marketing playing field; 3) Ensuring the protection of intellectual property rights for human-created content. Please find the detailed argumentation attached.
Read full response28 May 2025
SPIR represents all the major local players active in the Czech advertising market, including agencies, adtech and publishers. In order to guarantee the effective implementation of the Regulation (EU) 2024/900, we established a working group dedicated to answering practical compliance questions, especially in the area of online advertising. We therefore welcome this opportunity to share this working group's position on the recently published Implementing Regulation and its annexes. In our comments, we have mostly identified areas which would benefit from further clarification in order to avoid any misinterpretation of the text. We would like to express our gratitude for your consideration of our feedback. Please find our individual comments attached.
Read full responseResponse to Protection of Minors Guidelines
30 Sept 2024
Please see SPIR's (Association for Internet Progress) preliminary thoughts on the forthcoming guidelines: First and foremost, the EC should conduct an analysis to determine which types of services are actually harmful to children and focus the guidelines on those services only. The EC should reflect the dynamic nature of the internet and carefully tailor the rules based on various aspects such as: - the size of the platform; - typical content on the platform (is it intended for/often visited by minors); - Registered user versus random visitor; - Age of the minor (less restrictive for 15/16+); - who provides ad targeting (platform itself vs. ad tech provider). The internet should remain a fundamentally anonymous place for sharing information, so mandatory identity checks (if any) should be used with great caution. Age verification, if required, should be convenient for both the user and the online platform provider, it should be automatic, effective and not financially burdensome for the service provider. The EC should be wary of imposing (further) restrictions on European platforms, especially the smaller ones, as compliance costs risk hampering their growth and putting them at a disadvantage compared to (often non-European) VLOPs.
Read full responseResponse to Implementing Act on transparency reports under Regulation (EU) 2022/2065 (Digital Services Act)
24 Jan 2024
About SPIR: For over 20 years, the Association for Internet Progress (SPIR) represents the most important players of the Czech Internet economy from among media publishers, media agencies and technology companies with an annual turnover of more than 37 billion Czech crowns (1,5 billion EUR). The services offered by SPIR members are used by over 90% of the population of the Czech Republic. Member companies pay 3 billion Czech crowns (120 million EUR) a year in taxes and other fees to the state budget and employ 7,500 people throughout the Czech Republic. SPIR operates the only official measurement of Czech Internet traffic NetMonitor, monitoring of Internet advertising AdMonitoring and provides expert analyses of the development of the Czech Internet market. SPIR is a member of IAB Europe (Interactive Advertising Bureau), Europe's largest professional organization covering companies in digital marketing and advertising ecosystems. As DSA is concerned, SPIR represents companies in the following categories: intermediary services, hosting services, online platforms (including online marketplaces). General remarks: We very much appreciate the Commission's efforts to develop model reports on content moderation. However, we must also point out that these reports should not place an excessive burden on service providers. In particular, they should not require those service providers that do not fall into the category of very large online platforms (VLOPs) to collect additional or excessively detailed information. These smaller operators, unlike VLOPs, do not have sufficient resources to produce such detailed reports and imposing such extensive obligations will only put them at a further disadvantage compared to VLOPs. In fact, the Digital Services Act recognises and takes into account the differences in administrative and technological capacities between smaller and very large platforms in the structure of the Regulation and it would therefore be appropriate to reflect them in this implementing act too. We would like to strongly point out that in practice, 'micro or small provider' (which are exempted from numerous DSA obligations) are not the only entities that do not have sufficient resources to meet the Commission's excessive obligations. Even large companies often operate a range of intermediary services, but these are, from their perspective, a rather insignificant additional activity. As such, it is irrational for these owners to invest disproportionate resources into compliance of such services. It is precisely such services that are the most at risk of excessive administrative burdens. As such, many providers who operate such services only as ancillary part of their portfolio will find it more reasonable to end operation of these services. Such unnecessary requirements by the Commission will not only impose unnecessary costs on service providers, but will also impose a burden on users using the notice & action mechanism, as providers have to logically pass on these requirements to them (e.g. categorisation of illegal/incompatible content would be too detailed for them and demotivate them from reporting such issues in the future). At the same time, we would like to point out that Article 15 (3) of the DSA allows the Commission to adopt implementing acts setting out templates for the messages in such a way, as it is foreseen in Article 15 (1). Therefore, they do not allow the Commission to expand the scope of the information required. In general, it would be advisable, especially for non-VLOP providers, to allow some flexibility for these providers so that they can adapt the format/content of the reports to their needs and reality of their services. Please find the specific remarks and the full opinion of our association attached.
Read full responseResponse to European Media Freedom Act
23 Jan 2023
SPIR (Association for Internet Progress) is a long-established association representing the most important Czech players in the local Internet economy from among media (publishers, TVs), advertising agencies and technology companies with a total turnover of more than 37 billion CZK per year. The services offered by SPIR members are used by over 90 % of the population of the Czech Republic. Member companies pay 3 billion crowns a year in taxes and other fees to the state budget and employ 7,500 people throughout the Czech Republic. SPIR also operates the only official audience measurement of Czech Internet traffic NetMonitor, monitoring of Internet advertising AdMonitoring and provides expert analyses of the development of the Czech Internet market. SPIR welcomes the intent of The Commission to support a free, diverse and high-quality media sector. The presented draft act suggests several points which do support this goal, however, it also contains several key provisions which might prove to be harmful to the media sector. Since any regulation of media has to be done with extreme caution due to its possible impacts on the entire society, we analyzed the draft act thoroughly and we would like to share with the Commission the resulting detailed and structured breakdown of the act itself, as well as of the accompanying Recommendation (EU) 2022/1634. As an association providing audience measurement, we also tackled the Article 23. Please find the document attached (in Czech language). We would like to thank the Commission for careful consideration of our feedback. In case of any questions, please do not hesitate to contact us.
Read full responseResponse to Child sexual abuse online: detection, removal and reporting
12 Sept 2022
SPIR (the Association for Internet Progress) welcomes EC's dedication to fighting online child sexual abuse. We support the aim to ensure that technology is developed and used safely with special attention paid to protection of children and we share its vision of a responsible internet where children can explore online spaces safely. Child sexual abuse is a particularly serious and reprehensible offense, that needs to be addressed by effective measures at the EU level. Thus, we also welcome the EC's effort to strengthen the cooperation among member states and the establishment of a new EU authority with a leading role in this mission.
Although we fully support the Proposal goals, we also believe that any legislation must respect all fundamental rights, including the rights to private life and data protection, and remain limited to what is necessary, proportionate, and feasible. Therefore, we are concerned about the impact of some proposed measures on individuals’ privacy. For example, proposed measures for the detection of grooming in interpersonal communication are particularly problematic given the likelihood of errors generated by technologies used to scan users’ communications. This is especially intrusive in the context of email communication protected by the secrecy of letters. Also, the lack of clarity and precision of the conditions for issuing a detection order for CSAM and child solicitation does not ensure that only a targeted approach to CSAM detection will effectively take place. We are concerned that with the current wording, detection orders could be abused for a generalized and indiscriminate scanning of electronic communications.
In conclusion, we are deeply committed to combating the sexual abuse of children and we are ready to participate in further discussions on this proposal that shall lead to effective solutions striking the right balance between all protected values.
Read full responseResponse to EU action against abusive litigation targeting journalists and rights defenders
29 Jun 2022
As an association representing (among other) publishers, news agencies and TV companies, we perceive the difficult situation of journalists in some of the EU member states. Therefore, we understand and support the goals of the proposed directive against SLAPPs. Nevertheless, we would like to share some concerns which we identified during our analysis of the document and provide the Commission with constructive feedback for the upcoming discussions. Please see the detailed opinion attached (in Czech language).
Read full responseMeeting with Věra Jourová (Vice-President) and Kantar Media UK Ltd
17 Jun 2022 · MFA, DMA
Response to Data Act (including the review of the Directive 96/9/EC on the legal protection of databases)
13 May 2022
As an umbrella association of Czech online publishers, TVs, technological companies, advertisement agencies and e-commerce players, we welcome the intention of the European Commission to propose a new regulation aiming to introduce a fair and effective tool for exchange of IoT data. Unfortunately, there seems to be a certain level of unclarity regarding the impact of the proposal on other types of data. According to our interpretation, the scope of the draft indeed covers only IoT/industrial data, nevertheless, we would welcome a clearer guidance and wording so that there can be no doubt about that the almost exclusive focus of the act is IoT data. More details in the attached file (in Czech).
Read full responseResponse to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services
30 Mar 2021
For 20 years, the Association for Internet Progress (SPIR) has represented the most important players in the Czech Internet economy from among publishers, media agencies, and technology companies with a turnover of more than 37 billion crowns per year. The services offered by SPIR members are used by over 90% of the population of the Czech Republic. Member companies pay 3 billion crowns a year in taxes and other fees to the state budget and employ 7,500 people throughout the Czech Republic. SPIR operates the only official measurement of Czech Internet traffic NetMonitor, monitoring of Internet advertising AdMonitoring and provides expert analyses of the development of the Czech Internet market. SPIR is a member of IAB Europe (Interactive Advertising Bureau), Europe's largest professional organization covering companies in digital marketing and advertising ecosystems.
SPIR's comments on the DSA proposal are attached.
Read full response30 Jun 2020
We are very well aware of the unequal conditions European companies face in national, EU and global market due to the growing power of a small number of large platforms, and their network effects. Thus, we fully agree with the EC’s findings and the need to undertake necessary measures to ensure fair competition and real consumer choice, prevent self-preferencing of the dominant global platforms and increase transparency, in line with current legislation, such as P2B Regulation. Therefore, we welcome the EC’s initiative.
As for the suggested approaches, enforcement of the current legislation and rules should be paramount and any new regulatory initiative must be preceded by a thorough assessment of the impacts of the legislation in force.
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