The European VOD Coalition response to the proposal for a European Media Freedom Act

The European VOD Coalition (the “Coalition”) welcomes the opportunity to further discuss the European Commission’s proposal for a European Media Freedom Act (EMFA).

The Coalition represents video-on-demand (VOD) companies active across the EU and who operate a range of business modelsin different EU markets but have a common focus on investing in audiovisual content and distribution. Our members are driving investment in the EU’s cultural and creative sector, and beyond, by creating jobs and partnering locally with thousands of EU SMEs.

Media regulation is an important topic for the Coalition. The media sector is a significant part of the European economy and plays an invaluable role in democratic societies. As part of this ecosystem, VOD services offer an increasingly wide range of diverse content that entertains, informs, and educates citizens across the EU every day.

The Coalition has four core asks for co-legislators in response to the Commission’s proposal:

▪ Support the proposal’s use of the single market as its legal basis and a Regulation as the best legal instrument to avoid further regulatory fragmentation in the media landscape.

▪ Change to a principle-based approach on new market concentration measures that reflect the realities of the media ecosystem by extending the scope beyond media service providers.

▪ Refine user customisation rights on interfaces to safeguard commercial and innovation freedom, editorial decisions, and align with established customisation practices.

▪ Support a more consistent approach to best practice sharing for cross-media measurement methodologies that reflects the realities of the media and advertising ecosystem.

Please find our full consultation response below.