The European Commission has opened the DSM Directive review: Article 30 of the 2019 Copyright in the Digital Single Market Directive allowed it to start no sooner than 7 June 2026, and a single call for evidence, open until 25 June 2026, feeds both the review and a possible new legislative proposal planned for the first quarter of 2027. Platforms, publishers, music companies, AI developers and collecting societies operating in the EU should expect changes to licensing, anti-piracy remedies and music royalties.
Update (October 2026): the call for evidence closed on 25 June 2026. On 29 September 2026 the Commission launched a targeted consultation, open until 3 November 2026, on AI, piracy of live events, single equitable remuneration and research (European Commission, 29 September 2026).
Key takeaways
- Article 30 requires a review and a report to the Parliament, the Council and the European Economic and Social Committee no sooner than 7 June 2026.
- DG CNECT runs one call for evidence for two processes: the review report and a targeted legislative initiative, indicatively planned for Q1 2027.
- Four themes: AI licensing and remuneration, piracy of live events, royalties for third-country music and copyright in research.
- The listed stakeholders include hosting and cloud services, content delivery networks (CDNs), content-sharing platforms and collecting societies.
What does Article 30 of the DSM Directive require?
Directive (EU) 2019/790, known as the DSM or CDSM Directive, had to be transposed by 7 June 2021 (Article 29). It created the text and data mining exceptions, the press publishers’ right, the liability regime for online content-sharing service providers in Article 17 and the transparency and fair remuneration rules for authors and performers. Article 30 says the Commission shall carry out a review “no sooner than 7 June 2026” and that Member States must supply the information it needs. Spain transposed the Directive through Book Four of Royal Decree-Law 24/2021 of 2 November.
According to the call for evidence published on 13 May 2026 (Ares(2026)4845636), the review will assess whether the Directive made it easier to use protected content online, improved licensing practices and fostered a fairer marketplace. It will cover all Member States, taking into account late transposition in some. An external study, with surveys, interviews and case studies, is already under way.
What is on the table in the DSM Directive review?
Alongside the review, the Commission is preparing a targeted initiative. The call for evidence describes these problems and options; none is a decision yet.
| Theme | Problem identified | Options mentioned |
|---|---|---|
| Generative AI | Rights holders struggle to control, license and be paid for AI uses; performers face AI imitations | Better information on use of content, mediation or arbitration, remuneration measures, protection against impersonation |
| Piracy of live events | The 2023 Recommendation had limited effect; illegal IPTV and apps keep growing | Stronger remedies for live content, with safeguards, and more cooperation between national authorities |
| Music from third countries | EU pays single equitable remuneration to countries that do not reciprocate | Material reciprocity under Article 8(2) of Directive 2006/115/EC |
| Research | Uneven national research exceptions | Harmonising the exception; an EU secondary publication right |
Why music royalties paid outside the EU are part of the review
When recorded music is broadcast or played in public in the EU, performers and producers receive a “single equitable remuneration”. After the Court of Justice’s RAAP judgment (Case C-265/19), the EU must pay it to third-country nationals even where their countries do not grant EU artists the same right. The Commission says this imbalance can divert royalties away from European performers and producers, and it is considering material reciprocity. For record labels, collecting societies and broadcasters, that could change how much is collected and for whom.
What this means for your business
- Use the window. Evidence can be submitted until 25 June 2026 on the Commission’s Have your say portal; a targeted consultation will follow.
- Gather data: licensing deals and their terms, Article 17 practices (filters, notices, complaints), text and data mining opt-outs and the cost of live-event piracy.
- Build change clauses into multi-year licences, especially for AI training, platform uploads and music used in broadcasts or venues.
- If you operate in Latin America or Africa as well as the EU, map which of your recordings could be affected by reciprocity rules.
Where copyright meets AI regulation, the META Channel group also advises on the AI Act. Our team for copyright and digital works in the EU can prepare a submission and review your licences.
When to bring in an adviser
- When your position depends on how Article 17 was transposed in several Member States, with different rules in each.
- When AI training or output licences assume today’s rules will stay in place until the contract ends.
- When you collect or pay music royalties across borders and reciprocity could shift the amounts.
- When you want your evidence to count: unsupported submissions carry little weight.
Frequently asked questions
When could the EU change its copyright rules?
The call for evidence gives indicative planning of the first quarter of 2027 for the Commission’s report and the targeted legislative proposal. A proposal would then go through the European Parliament and the Council, and a directive would need national transposition, so changes would take effect years later. The Commission stresses that timing and content may change.
Does the DSM Directive review change Article 17 now?
No. The review assesses how Article 17 and the rest of the Directive have worked, and the national laws transposing it remain fully applicable. Platforms must keep complying with their national rules, such as Royal Decree-Law 24/2021 in Spain, until any amendment is adopted and transposed.
Who can respond to the call for evidence?
Anyone can submit feedback on the Have your say portal until 25 June 2026. The Commission specifically lists rights holders, AI providers, internet service providers, hosting and cloud services, CDNs, content-sharing platforms, collecting societies, live event organisers, research bodies, national authorities and consumer organisations.
Can IP Global Guard prepare our submission and adapt our licences?
Yes. We help organise the evidence, draft the submission and review licensing contracts so they can absorb future changes. For filings before EU bodies, we act directly where our professionals are entitled and otherwise through qualified representatives, with a single point of contact.
How IP Global Guard can help you prepare
IP Global Guard, the IP services line of META Channel Corporation Limited, handles copyright, licensing and AI and digital asset protection across more than 25 jurisdictions in Europe, Latin America and Africa, with one strategy and one billing relationship.
Tell us which content you license in the EU, how you use it with AI and where you collect royalties. We will identify which parts of the review affect you and what to put on record now. Talk to our copyright team.
This article is general information, not legal advice; it reflects the position on the date of publication.
Sources
- Directive (EU) 2019/790, Article 30 (review), via legislation.gov.uk
- Directive (EU) 2019/790, Article 29 (transposition), via legislation.gov.uk
- European Commission, call for evidence on the CDSM review and targeted copyright initiative (13 May 2026)
- Department of Enterprise (Ireland), Copyright consultations (2026)
- BOE, Real Decreto-ley 24/2021, de 2 de noviembre
- European Commission, targeted consultation on copyright (29 September 2026)
