Creativity Works!, Europe’s leading alliance of the creative and cultural sectors since 2013, wishes to express itsconcerns following continued calls for the application of a network fees regime. We oppose any type of such a regime, either through a mechanism based on mandatory negotiations or through direct or indirect payments to providers of electronic communication networks (ECNs) from content and application providers including over-the-top media services (OTTs) and creative content providers, to support the cost of telecom infrastructure investment. Such proposals pose a threat to the sustainability of the European creative sectors and their ability to provide diverse content and services to European consumers.
As the results of the European Commission’s exploratory consultation show, the concerns of the creative and cultural sectors are shared by a large and diverse group of stakeholders, and there is a wide range of evidence displaying the dangers of a network fees regime.
- The creative sectors already invest in content, which in turns contributes to drive sustained and sustainable demand for telecoms services and benefits the internet ecosystem;
- Creative content services already invest in the internet ecosystem;
- There is no market failure preventing investment in performant, sustainable digital infrastructure: investments are flowing in connectivity and the interconnection market is working well;
- Network fees would fundamentally affect the way the internet works to the detriment of the creative
sectors and consumers;
- Pirates free ride on the internet ecosystem and generate congestion;
- Less content would be produced and distributed in Europe – reducing consumer choice and European
competitiveness in the creative sector