Advocacy

Since its foundation in 2014, IMPF has grown from 15 founding members to over 180 members today. During that time, we have enjoyed some noteworthy achievements:

Delivered a strong message and a dynamic offering
Constructed an enhanced, informed and involved membership
Developed and carried out a pro-active international advocacy and outreach programme
Rolled out a wide-ranging programme of networking events both online and offline in-person

Established a focused and geographically representative Board
Raised the independent publishers’ profile and message across our key stakeholder groups
Undertaken and published three global studies on the independent music publishing market

IMPF is the recipient of a Creative Europe grant to help build the capacity of independent music publishers. This IMPF network project is co-funded by the European Union.

IMPF addresses the many current industry challenges we face through a pro-active advocacy. IMPF provides support to its publisher partners both directly and via its coalition partners, to identify laws and policies which need adaptation so as to support and enhance the industry internationally. IMPF influences global laws and policies through strategic initiatives, linked directly to our local and national members as IMPF aims to respond to issues when invited to engage. Those issues include – fair remuneration for composers and authors, recognition of the value of the song, antitrust practices and buyouts, growing and leveraging the streaming pie. IMPF monitors and engages on legislation and policy internationally at EU and WIPO level and at national level when asked by our members.

IMPF regularly attends meetings with legislators, policy makers, coalition partners and collective management partners. Please see latest activities here.

Here is information on IMPF’s recent campaigning and advocacy work.

IMPF and... International Governmental and Intergovernmental Institutions EU and USA

IMPF and... National Governments and National Associations

IMPF and... Formal Submissions

IMPF Industry Reports

Other Industry Reports

IMPF and … International Governmental and Intergovernmental Institutions EU and USA

The EU AI Act and Copyright Rules – Note from the Rightsholders Community 19 Mar 2024

See the letter here.

IMPF, and creators and rightsholders everywhere, welcome the approval of the EU AI Act by the European Parliament. We applaud the MEPs for the crucial role they have played in supporting us throughout this process. The EU AI Act is a world-first legislation regulating the development and use of AI and sets an example for responsible AI governance.

See the joint statement here.

IMPF and its worldwide membership along with over 200 Creative & Cultural organisations calls on Member States of the EU to show global leadership by approving the AI ACT at the COREPER Meeting on 2 February 2024.

See the joint statement here.

IMPF issues two statements on Artificial Intelligence

As part of the advocacy of the AI Working Group, IMPF issued two statements on AI. One addressed the EU Trialogue negotiations directly, and the second is a global open letter “Global Creators and Performers Demand Creative Rights in AI Proliferation” sent to governments around the world to be used as the basis for lobbying and policy work. See the statements here and here. As a member of the Human Artistry Campaign, IMPF also supported the statement addressing the Biden Administration’s recent meeting with AI developers and their agreement to voluntary commitments regarding safety, security, and trust in AI. See that statement here. IMPF has also made submissions to the UK and Australia governments enquiries on AI and both of those can be found here and here.

Meeting with Lauriane Bertrand, Creative Europe, European Commission.

In November 2022, IMPF and other organisations from the music sector wrote to Commissioner Gabriel (Culture) regarding concerns in relation to the EU’s support of the music sector. Since then, the EC acknowledged the need to make their support to music more strategic. In a recent meeting the Commission confirmed that the music sector is “underprivileged” compared to the audiovisual sector and said that Commissioner Gabriel is keen to work more closely with us on this issue. IMPF will continue to push with the rest of the sector to get the support we deserve.

IMPF joins the European Cultural Community in condemning the horrifying invasion of Ukraine by Russia.

The European Cultural Community is united in condemning the horrifying invasion of Ukraine by Russia. We deplore in the most absolute terms the damage caused to a free country and express our unwavering solidarity with the people of Ukraine – our friends, our colleagues, our artistic and cultural partners. See letter here.

IMPF alongside organisations from a diverse range of sectors calls on the European Parliament not to miss the opportunity to create a more trustworthy internet. (DSA)

IMPF joins organisations from a diverse range of sectors urging the European Parliament not to miss the opportunity for a safer internet (DSA). See Statement here.

IMPF joined the international cultural and creative sector in expressing serious concerns over the EU Council’s general approach on the Digital Services Act (DSA).

IMPF joined the international cultural and creative sector in expressing serious concerns over the EU Council’s general approach on the Digital Services Act (DSA). See letter here.

IMPF calls DSA – A missed opportunity and a step backwards

IMPF along with a broad coalition of organizations, representing the creative sector in Europe, write a letter raising serious concerns about the approach taken by the EU co-legislators on the Digital Services Act. See letter here.

Claiming a front row seat for Music

76 International, European & national music organisations including IMPF are “Claiming a front row seat for music” calling for policy makers to fully acknowledge the artistic, social and economic value of the music sector and to live up to these words in political decision making! See letter here.

Rightsholders letter on the EC Guidance on Article 17 (DSM Directive)

IMPF joined rights holders in Europe’s Creative Sectors to express their concerns around the European Commission’s Guidance on Article 17. See letter here.

EU-US Summit Call to Support the Cultural Relations

When EU and US leaders met more than 100 organisations from across Europe and America’s cultural and creative sectors united their voices to call for greater support on EU–US cultural relations, of particular importance in recovering from the Covid 19 crisis. See letter here.

Europe creative sector letter on the German DSM implementation proposal

IMPF along with representatives of a broad group of right holders in Europe’s creative sectors have written to German MPs and the Commission and Commissioners to express serious concerns regarding the draft law proposal (‘the proposal’) on the implementation of the DSM Copyright Directive (‘the Directive’), which is now being discussed in the Bundestag. See letter here.

Letter on Article 17 Guidance ahead of College of Commissioners approval

IMPF and other organisations representing authors, record labels and music publishers in the European Union, wrote about their concerns on the European Commission’s application of Article 17. The concern is that the Guidance will undo what has been agreed by the EU legislature and will be detrimental to European music creators and their business partners. If followed by Member States, it would undermine the fine political balance achieved during the legislative process and is highly likely to fragment the digital single market, leading to a plethora of litigation at national level and to future cases before the CJEU. See letter here.

European right holders’ letter on the German draft law implementing the DSM Directive (Article 17)

A broad Group of rights holders write to express their serious concerns regarding the German draft law on the implementation of the DSM Copyright Directive (‘the Directive’) which was presented on 23 November 2020 and is currently being coordinated within the German Government and regarding Article 17 (the ‘value gap’ provision) in particular. See letter here.

Letter to the European Commission and National Governments – EU CCS

Letter to the EC on behalf of Europe’s cultural and creative sectors. As our societies are going through an unprecedented turmoil, we call on the EU and its Member States to make sure that culture is placed at the core of each and every recovery plan, which aims at a sustainable, inclusive and future-looking revival of our social and economic life. See letters here and here.

Joint letter – Support for culture in RRF report

IMPF and organisations from the CCS write to Members of the European Parliament to ask them to support a number of amendments tabled on the draft Report on a Recovery and Resilience Facility. See letter here.

Include Culture in Your National Recovery Strategies and Reactivate Cultural Life in Europe

110+ representatives of the multifaceted European cultural ecosystem, call on the Member States and the European Commission to secure a future for culture and cultural life in Europe. See letter here.

InvestEU – CCS sector letter

IMPF and organisations from CCS write to Commissioners Breton and Gentiloni regarding InvestEU 2021-2027. As organisations from the cultural and creative sector, we are very concerned that the proposed severe cuts to the EU’s flagship investment programme could have a dramatic impact on the ability of Europe’s cultural and creative businesses to access much needed affordable debt and equity financing. See letter here.

Music sector joins together to call for EU and national investment to address current crisis and promote diversity

Music organisations urge Member States and the European Commission to take a stance and significantly increase the national and EU budgets dedicated to culture, and within that to music. Secondly, under the EU Coronavirus Response Investment Initiative, it is imperative that each Member State provides Europe’s creative sector with swift and comprehensive access to Structural Funds in order to offset the harm in the shorter term. See letter here.

Letter from Commissioner Mariya Gabriel

Response from Mariya Gabriel to representatives of the Music Sector. See letter here.

CCS Joint Call Covid-19

Europe’s cultural and creative sectors call for ambitious EU budgetary measures to get through the COVID-19 crisis. See letter here.

Joint Statement of Rightsholders

Copyright Directive impasse in LIBE Committee Right holders call to improve draft Opinion via effective compromises. See letter here.

Statement to Mr Voss on Transfer Value / Value Gap

IMPF joins representatives from the Creative Industries in a statement to European Parliment member Mr. Voss regarding the critical issue of the ‘value gap/transfer of value’ which is hampering the growth and potential of our sectors. See statement here.

Creative industries call to ensure a level playing field in Europe’s Digital Single Market

IMPF along with others from the Creative industries formed an alliance to campaign for a solution to a major problem holding back our sector and jeopardising future sustainability – the Transfer of Value, otherwise known as the Value Gap. Call to Bulgarian Presidency of the Council of the EU. See here.

IMPF and … National Governments and National Associations

Letter from international music producers and publishers organisations – Concerns regarding last minute amendment to Belgian copyright law.

Music producers and publishers write a letter about their concerns regarding a specific amendment proposed by the Belgian Government on the implementation of the EU Directive on Copyright in the Digital Single Market. The amendment to Article XI.228/10-11 is currently before the Commission de l’Économie de la Chambre (DOC 55 2608/005). See letter here.

Creative Sector in Europe letter to Finland (the Finnish Ministry of Culture) commenting on the proposed legislation implementing the DSM Directive, and the suggested transposition of Article 17.

Creative Sector in Europe letter to Finland (the Finnish Ministry of Culture) commenting on the proposed legislation implementing the DSM Directive, and the suggested transposition of Article 17. See letter here.

Letter to President Zelensky regarding the urgent need to adopt and implement Bill N5572,

IMPF joins the international community of songwriters and collective rights management organisations and asks for the speedy adoption and implementation of Bill N5572 which aims to rectify the shortcomings in the accreditation of collective management organisations in Ukraine. Bill N5572 would allow for a new transparent and objective accreditation procedure. See letter here.

Submission IMPF Letter to Croatian Government and Parliament re Article 213

IMPF wrote letters to remark on the wording of the new Croatian Copyright Bill which contains a troubling provision in Article 213. The understanding being that this Article would make it mandatory that a large scope of the author’s or composers rights be executed exclusively through a collective management organisation (CMO). Such an approach would deny authors and composers (the rightsholders) the right to execute their intellectual property rights (IPRs) as they see fit, i.e., directly or through their chosen representative. See letters here and here.

AIMP IMPF Letter to NMPA

The IMPF and AIMP write to the NMPA to voice shared concern regarding practices carried out by the NMPA with respect to the signing of worldwide deals for reproduction and performing rights. See letter here.

Letter to South Africa Government – Concerns regarding the current Copyright Amendment Bill

IMPF President of BoD writes to the South African Minister, Deputy Minister, Members of Parliament, DG, to express disquiet regarding some of the retrograde elements of the current Copyright Amendment Bill. See letter here.

IMPF letter to Government of Hungary on Value Gap

IMPF write to Deputy State secretary to ask the Hungarian government to support the Value Gap provisions (Article 13 and the related recitals) of the European Commission’s proposal for a Directive on Copyright in the Digital Single Market. See letters here and here.

Letter to the Polish Gov. Deputy Prime Minister re New Statue ZAiKS

IMPF President writes on behalf of independent music publishers in Poland who are members of IMPF, regarding the wording on the new Statutes of the Authors’ Association ZAiKS. See letter here.

Letter from IMPF on Canada Copyright Board Public Consultations

IMPF shows full support for the submission of the Canadian Music Policy Coalition (CMPC)’s to the Copyright Board Consultations. See here.

Statement of IMPF Board of Director on the U.S. DoJ’s 100% Licensing Scheme

IMPF Board reaction to the U.S. Department of Justice making a decision to leave the outdated consent decrees as they are. See statement here.

IMPF and … Formal Submissions

IMPF Submission to the Senate Select Committee on adopting Artificial Intelligence (Australia)

Submission to the Senate Select Committee on the adoption of AI (Australia). See here.

IMPF Submission Canada Consultation on Copyright in the Age of Generative Artificial Intelligence

Submission of IMPF to Canada on Copyright in the age of Artificial Intelligence. See here.

Submission of IMPF to U.S. COPYRIGHT OFFICE (COLC) on Artificial Intelligence and Copyright.

Submission of IMPF to U.S. COPYRIGHT OFFICE (COLC) on Artificial Intelligence and Copyright. IMPF Comments to U.S. Copyright Office Artificial Intelligence and Copyright. See here.

Submission to UK Gov. Department for Science, Innovation and Technology and the Office for Artificial Intelligence

IMPF submitted response to the open consultation on AI regulation: a pro-innovation approach – policy proposals. See position paper here.

Submission to UK House of Commons DCMS Committee Inquiry on behalf of IMPF

IMPF submitted information to the UK Government DCMS Committee as it was a significant opportunity to state the importance of having a streaming market that is equitable, fair, transparent, efficient, and pro-creator. See letter here.

IMPF response to targeted consultation on Article 17

IMPF entreat the EC to accurately follow the objective of the DSM Directive when elaborating the final Guidance document, that is to create a level playing field in the online Digital Single Market and to strengthen the ability of European rightsholders to create and invest in new and diverse content across Europe. When implementing Article 17, we urge Member States to faithfully follow the intention of the Directive and remember that any Guidelines for interpretation are by no means binding. See letters here and here.

EC Consultation on the IPR Enforcement Directive

EC Consultation on the IPR Enforcement Directive, 2016. See here.

Enforcement Submission to the European Commission DG for Internal Market

Enforcement Submission to the European Commission DG for Internal Market. See here.

Public consultation on the role of publishers in the copyright value chain and on the ‘panorama exception.’

Submission sent online 2017.