MTE Response to AVMSD Review Consultation

Middle Tech Europe welcomes the opportunity to contribute to this review of the Audiovisual Media Services Directive. MTE strongly supports the European Commission’s objective of simplifying and streamlining the rules in the AVMSD to ensure they remain fit for purpose.

As the digital regulatory landscape has evolved significantly since 2018, particularly with the adoption of the DSA, the parallel application of both regimes has created legal uncertainty and unnecessary administrative burdens without providing additional protection for users.

This position paper outlines MTE’s core recommendation for the ongoing review of the AVMSD: the Video-Sharing Platform (VSP) related duties on audience protection under the AVMSD, and VSP advertising obligations should be folded into the DSA and the UCPD to eliminate double regulation, streamline compliance, and strengthen the Digital Single Market. MTE does not take a position on other obligations under the AVMSD beyond those applicable to VSPs.

For our full submission, download the attached document.

Positioned between the tech giants and smaller startups, our members operate a wide variety of services ranging from video-sharing and e-commerce to e-mail, forums, communication, media, and hosting services – representing the often missing “middle-voice” in tech policy discussions.