A coalition of authors, performers, and other rightsholders across the EU’s cultural and creative sectors strongly opposes the third draft of the General-Purpose AI (GPAI) Code of Practice, arguing that it undermines the objectives of the AI Act, contravenes EU law, and disregards the intentions of EU legislators.
Our key Concerns:
- Weakens Copyright Protection – The draft fails to ensure that GPAI providers comply with EU copyright law, reducing their responsibility to conduct due diligence and prevent copyright infringements.
- Lack of Transparency – It removes the requirement for GPAI providers to disclose compliance with copyright reservations and only recognizes robots.txt as a method for rightsholders to reserve their rights, ignoring more comprehensive solutions.
- Ineffective Enforcement Mechanisms – The proposed copyright complaints process lacks concrete measures for resolution, making it an empty gesture.
- Contradicts EU Law – The draft misinterprets copyright laws, particularly regarding lawful access to content and right reservation mechanisms.
- Fails to Ensure Responsible AI Development – Instead of protecting creative industries, it sets a low compliance bar, increasing risks of copyright infringement and harming EU’s cultural sector.
The coalition asserts that the third draft is unacceptable and should not be approved without major improvements. If left unchanged, no Code would be better than this flawed version. They call for stronger measures ensuring AI developers respect copyright law, provide transparency, and uphold EU legislation.
The statement is supported by a wide range of organizations representing authors, performers, journalists, musicians, publishers, and the audiovisual industry across Europe.
The signatories conclude that no Code at all would be preferable to the fundamentally flawed third draft. They call for substantial revisions before adoption.
List of Signatories
The statement is endorsed by a wide range of organizations representing authors, performers, and other creative professionals across various sectors, including:
- AAPA (Audiovisual Anti-Piracy Alliance)
- AEPO-ARTIS (European Performers’ Collective Management Organizations)
- BIEM (International Organization of Mechanical Rights Societies)
- CEATL (European Council of Literary Translators’ Associations)
- CEPI (European Audiovisual Production Association)
- CEPIC (Picture Libraries and Agencies)
- CISAC (International Confederation of Societies of Authors and Composers)
- EANA (European Alliance of News Agencies)
- ECSA (European Composer and Songwriter Alliance)
- EFJ (European Federation of Journalists)
- EGAIR (European Guild for AI Regulation)
- EMMA (European Magazine Media Association)
- ENPA (European Newspaper Publishers’ Association)
- EPC (European Producers Club & European Publishers Council)
- EUROCINEMA (Association of Film and Audiovisual Producers)
- EVA (European Visual Artists)
- EWC (European Writers’ Council)
- FEP (Federation of European Publishers)
- FERA (Federation of European Screen Directors)
- FIA (International Federation of Actors)
- FIAPF (International Federation of Film Producers’ Associations)
- FIM (International Federation of Musicians)
- FSE (Federation of Screenwriters in Europe)
- GESAC (European Grouping of Societies of Authors and Composers)
- IAO (International Artist Organisation)
- ICMP (Global Trade Body for Music Publishing)
- IFJ (International Federation of Journalists)
- IFPI (International Federation of the Phonographic Industry)
- IFRRO (International Federation of Reproduction Rights Organisations)
- IMPALA (European Association of Independent Music Companies)
- IMPF (Global Trade & Advocacy Body for Independent Music Publishers)
- IVF (International Video Federation)
- News Media Europe
- SAA (Society of Audiovisual Authors)
- STM (Global Trade Association for Academic and Professional Publishers)
- UNI MEI (Union for Media, Entertainment, and Arts Workers)
- UVA (United Voice Artists)
These organizations collectively represent millions of authors, performers, musicians, journalists, filmmakers, publishers, and other creatives across Europe, advocating for stronger protections against AI-related copyright infringements.
Read the full statement below:
Right holders joint statement on the Third Draft Code of Practice 28 March 2025-1