Summary

IMPF’s ongoing advocacy across EU policy and a range of wider issues impacting independent music publishers continued through 2024. See further details on IMPF Policy and Advocacy here.
We actively engaged in several advocacy initiatives to protect and promote the interests of independent music publishers globally. IMPF’s efforts focused on addressing critical issues affecting the music publishing sector, including copyright policies, enforcement challenges, and emerging topics like generative AI. Key activities included engagements at international organisations, collaborations with trade bodies, and participation in strategic discussions with stakeholders.

IMPF’s advocacy work significantly contributed to advancing the interests of independent music publishers worldwide. Through active participation at WIPO and EUIPO, and strategic collaborations with key trade bodies, IMPF championed fair policies, robust enforcement measures, and transparent practices that safeguard the rights of independent music publishers and the songwriters and creators they represent. Moving forward, IMPF remains committed to advocating for a sustainable and equitable future for the independent music publishing sector.

Activity

IMPF’s advocacy work was spread across a number of specific initiatives, projects and campaigns in 2024:

The most pressing issue currently facing publishers, songwriters and creators generally is the growing prevalence of artificial intelligence and the potential for copyright infringement in its training. Throughout 2024, IMPF has moved alongside other creative industry collectives and organisations to lobby governments internationally, stand up to the corporations behind AI tech and make sure the voices of creators and IP owners are part of the conversation.

We were part of a coalition of organisations that issued statements calling for the EU Parliament to approve the AI Act in February and March (February 1st, 2024 – February 3rd, 2024 – March 13th, 2024), as well as being a signatory on a note to AI and copyright leads in the EU Commission on March 19, discussing the AI Act, copyright rules and the need for the involvement of key stakeholder voices in the development of the AI marketplace. See the letter here.

The European AI Office consulted on the EU AI Act and the topics covered by the first Code of Practice including in particular on the template for the summary about the model training data and accompanying guidance. IMPF stressed in its submission that transparency is a prerequisite for understanding how these models work, ensuring responsible AI development, enabling rightsholders to exercise and enforce their rights under EU law. Thus, the information provided by GPAI providers needs to be both meaningful and comprehensive, to the extent that it can serve as a basis to create a genuine licensing market. As part of our work within the wider EU rightsholders coalition we jointly submitted a more detailed proposal detailing the categories of information as well as the granularity thereof. 

Later in the year, in October, we joined a coalition of creators and rightsholders organisations writing to hundreds of European politicians and decision makers calling for the full and effective implementation of the EU AI Act in order to enable creators and rightsholders to exercise and enforce their rights when it comes to ingesting and copying copyright-protected works for training by AI models.

IMPF participated to the Plenary session of the European Union Intellectual Property Office in October 15 and 16 at its headquarters in Alicante.  Andrea Di Carlo, Deputy Executive Director, EUIPO presented the organisation’s priorities, emphasizing the importance of strong enforcement of intellectual property (IP) rights and ongoing development in key areas such as artificial intelligence. Patricia García-Escudero Márquez, Director of the Observatory reviewed the Observatory’s activities, noting an increased focus on copyright, with new members joining from the book publishing and motion picture sectors (MPA). She also discussed advancements in IP enforcement (IPEP), and a presentation by the Spanish National Police highlighted the growing recognition of IP crime as a threat to the EU. There were various interventions discussing generative AI’s impact on IP rights with topics including copyright exceptions, legality, opt-out mechanisms for authors, remuneration models, and ethical implications, referencing the 35 ongoing lawsuits internationally. IMPF is a stakeholder to the Observatory and EUIPO.

Outside of the EU, we have engaged with international governments on the topic of AI. In May, IMPF made a submission to Australia’s Senate Select Committee On The Adoption Of AI. See here and later welcomed the Committee’s final report, which expressly recognises ‘the unprecedented theft of copyrighted works’ in November. We also responded to the Australian government’s consultation around ‘mandatory guardrails’ for AI, expressing the importance of including comprehensive and meaningful transparency requirements regarding the AI model training and data used.

We have also co-signed a statement denouncing the unlicensed use of creative works for the training of generative AI and calls for others to join.  Over 35,000 signatories include creators of many repertoires:  musicians, writers, actors, artists, photographers, and more.  Nobel-winning authors, Academy Award-winning actors, Oscar-winning composers, and multi-platinum selling musicians have joined in signing the statement. For further details, and to sign the statement, go here.

Far from being anti-AI, we have supported projects that use the technology in a responsible and empowering way. For example, EMERGE is an AI-powered chat interface for sync professionals, linking European music with sync prospects such as film producers, advertising agencies, the gaming industry, and sync agents. It facilitates audio-visual professionals to find the perfect track to sync for their new production. IMPF is a partner to the project, represented by Katja Jainski-Manteuffel (VP Marketing & Synch Licensing, Budde Music). See news link here.

More broadly, IMPF also participated in the WIPO Romania: Sixth Regional Conference on IP in the Digital Economy for Small and Medium-sized Enterprises (SMEs). Tatjana Bukvić, MD of Tin Drum Music and Board Member of IMPF spoke on the topic of ‘Rights management in the music sector – international perspectives.’ The key points raised included fragmented licensing processes, technology gaps, and transparency and data management.

Who we worked with

IMPF engaged with a number of high level international bodies during these advocacy efforts including WIPO and the EUIPO Observatory of Intellectual Property Rights; trade bodies including CIAM, ECSA, GESAC and CISAC.

With CIAM (International Council of Music Creators), we worked together to address the challenges posed by digital streaming, advocating for a fairer revenue share for music creators. Joint campaigns highlighted the importance of transparent reporting and accurate attribution of rights.

With ECSA (European Composer and Songwriter Alliance), IMPF supported legislative proposals that would enhance protections for songwriters in Europe. The collaboration aimed at ensuring that creators have more control over their works and are adequately compensated in the digital market.

With GESAC (European Grouping of Societies of Authors and Composers) and CISAC (International Confederation of Societies of Authors and Composers), we collaborated on several initiatives promoting the role of collective management in protecting authors’ rights, emphasising the need for robust enforcement of copyright laws across the EU. As part of its global advocacy strategy, we tackled issues related to global licensing, data management, and copyright enforcement. IMPF supported CISAC’s efforts to modernise licensing systems to ensure that independent publishers benefit from streamlined processes that enhance efficiency and transparency.

Outcomes/Next Steps

A summary report is available here.  A final report will be available in March 2025.

Summary

IMPF’s ongoing advocacy across EU policy and a range of wider issues impacting independent music publishers will continued throughout 2023. See the full details on IMPF Policy and Advocacy here.

Activity

IMPF was represented at the Private Sector stakeholders meeting of the European Observatory on Infringements of Intellectual Property Rights on 28 February 2023 and at the Working Groups of the Observatory on Enforcement and IP in the Digital World, held from March 21 to 24 2023. IMPF was also represented at the WIPO for Creators, 8th Advisory Board Meeting on 14 March 2023 and at the WIPO Standing Committee on Copyright and Related Rights (SCCR) Forty-Third Session from March 13 to 17 and at the Forty Fourth Session in November.

IMPF was represented by Jirina Petrova, MD of Schubert Music Czech Republic and Slovakia at a panel on “Fairness of the Streaming Model” during the the CISAC European Committee in Prague from 19 to 20 April 2023.

IMPF joined the Human Artistry Campaign as a member. The Human Artistry Campaign was launched to ensure AI technologies are developed and used in ways that support human culture and artistry – and not ways that replace or erode it.

IMPF supports its music publisher members in Italy and SIAE in the Meta negotiations. IMPF issued a statement condemning Meta’s exclusion of Italian songwriters and publishers.

At the Stockholm meeting in April, the Board agreed to engage with other rightsholders and set up a working group on AI, which will also discuss with AI developers the music publishing community’s concerns. The purpose of the AIWG is to keep track of developments in the area, aiming to get indie music publishers involved early, conduct monitoring, and build a repository for political and legal developments and see how to license. All of this to culminate in an AI discussion and applications in Palma at the Global Music Summit. The working group members are Elisa Amouyal, Talit Muzik Publishing (Chair); Simon Platz, Bucks Music Group; Jennifer Mitchell, Red Brick Songs, Emmanuel Delétang, Delphine Dickson, 22D; John Fishlock, Active Music Publishing; John Telfer, Rocking Gorillas Music; Francesca Trainini, Oyez; NiclassBjörlund, Editions Björlund.

The Board of Directors approved a paper outlining our approach to regulating AI. The paper (see  here) was drafted by the IMPF AI Working Group. The guidelines advocate for labelling AI generated music, requiring transparency with regards to the datasets used for training AI models, protecting copyright by requiring consent from rights holders, and keeping platforms and developers accountable for possible copyright infringement of AI generated works.

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.

During the IMPF Summit in Palma this year Independent music publishers released their  ethical guidelines to AI developers which was developed by the AI IMPF Working group.  See the guidlines here.

Formal submissions and comments have also been made to the US and Canada.

IMPF is supporting the effort of the European Commission to enhance the collaboration between cultural sectors through the use of technological innovation via two proposals:
We are participating to the application of Eurosonic Noorderslag(ESNS) and Soundcharts to develop, promote and administer the EIT Culture & Creativity Call, EP3 Breakthrough Lab to bring about a much-needed technological advancement that would strengthen both the European music and audio/visual sectors.   And IMPF is also endorsing the FAIRPLAY proposal, which aims at developing novel re-traceable learning methods and knowledge-based approaches for music generation and access, and to formulate a proposal for a fairer legal framework to regulate copyright and authorship attribution in a world where creative humans co-operate with artificial intelligence. FAIRPLAY has the potential to deliver unique assets to the creative industry and the community of artists, producers and independent music publishers working in the music domain and beyond.  And it can help with new insights for a better understanding of the complexities of the legal implications in the creative sector involving artificial intelligence technology.

Outcomes/Next Steps

IMPF will continue to advocate and lobby across these issues and others as they arise during 2024.

Summary

IMPF’s ongoing advocacy across EU policy and a range of wider issues impacting independent music publishers has remained central to its work on behalf of its global membership.

Activity

Highlights in 2022 included working on the Credits Due campaign and collaborating with other Brussels based trade bodies on DSA and DMA advocacy. IMPF also attended the WIPO Standing Committee on Copyright and Related Rights and is on the Advisory Board of WIPO for Creators. Top level regulatory advocacy included responses to national government on the Copyright Directive transposition, development of position and policy papers on, AI and NFTs and copyright.

Over the course of the year, IMPF lobbies on a wide range of issues affecting its members, including the Digital Single Market, Fair Use, buy outs, gender balances, Brexit, NFT licensing models, Equitable Remuneration.  There was also extensive work done with UACRR and the IMPF membership on the war in Ukraine.  Work started in October 2022 on the Global Independent Music Publishing Market Study 3^rd Edition.

Who we worked with

ECSA, The Ivors Academy, IMPEL, IMPALA, GESAC, WIPO, CISAC, ESMAA, EUIPO, UACRR Ukraine, MPC Canada, CIAM, IPA, The MLC and others representing RH industries in Brussels and Geneva.

Beneficiaries

IMPF members, the wider music and creative industries.

Outcomes/Next Steps

 IMPF will continue to advocate and lobby across these issues and others as they arise, collaborating closely with RH colleagues In Brussels and Geneva.

This report is available to download here below.