BSA strongly supports a copyright framework that works fairly for creators, rightholders, and those who rely on data access for innovation. We believe the current framework, built around the CDSM Directive and complemented by the AI Act, is well-positioned to deliver that balance – provided it is given the time and space to operate.

Our central recommendation is that the Commission complete its evidence-gathering process in full before drawing conclusions about whether new legislation is needed. The review of the CDSM Directive and the accompanying evaluation, feasibility and impact assessment studies represent the right vehicle for that analysis. BSA urges the Commission to let those processes reach their conclusions before making any commitment to a legislative proposal, and to approach the question of Article 4 in particular with the caution that a foundational provision of the EU’s innovation framework deserves.