EuroISPA contribution to the Targeted initiative to support the CDSM review process

EuroISPA contribution
to the Targeted initiative to support the CDSM review process

EuroISPA welcomes the opportunity to contribute to the European Commission’s targeted initiative reviewing the Copyright in the Digital Single Market Directive (CDSM Directive) and the Intellectual Property Rights Enforcement Directive IPRED

Our members — from large telecoms operators to hosting providers, CDN operators, DNS resolvers, and VPN providers — sit at the heart of the digital infrastructure that underpins both the creative economy and the broader EU digital single market. We share the Commission’s commitment to an effective, fair, and future-proof copyright framework. Any policy response must be proportionate, evidence-based, and directed at actors who have the practical ability to act.

Our contribution addresses three areas of direct relevance to our members:
On online piracy:

• Prioritise effective enforcement of the DSA and the existing EU copyright framework before considering additional legislative measures
• Minimise collateral damage to lawful services, broad IP and DNS-based blocking has repeatedly caused overblocking, making more targeted approaches preferable
• Subject enforcement mechanisms to proportionality assessments, adequate review periods, and clear accountability where lawful content or services are affected

On generative AI and the TDM framework:

• Preserve the TDM exceptions in Articles 3 and 4 of the CDSM Directive as an important foundation for AI development and broader data-driven innovation across the European economy
• Ground any review of the AI–copyright framework in demonstrated and cross-sectoral evidence, balancing the interests of rightsholders with the wider innovation ecosystem

On private copying:

• Greater harmonisation of the private copying exception could reduce legal fragmentation, regulatory complexity, and competitive distortions arising from divergent national approaches

EuroISPA looks forward to engaging with co-legislators on these important matters. For more details on EuroISPA’s position, we invite you to read our full contribution below.